August 28, 2024

Todd Meredith
President and Chief Executive Officer
Healthcare Realty Trust Incorporated
3310 West End Avenue
Suite 700
Nashville, TN 37203

       Re: Healthcare Realty Trust Incorporated
           Definitive Proxy Statement on Schedule 14A
           Filed April 9, 2024
           File No. 001-35568
Dear Todd Meredith:

      We have limited our review of your most recent definitive proxy statement
to those issues
we have addressed in our comment(s).

       Please respond to this letter by providing the requested information
and/or confirming that
you will revise your future proxy disclosures in accordance with the topics
discussed below. If
you do not believe a comment applies to your facts and circumstances, please
tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Definitive Proxy Statement on Schedule 14A
Pay Versus Performance, page 38

1.     We note that the peer group identified in the pay versus performance
table and related
       disclosure is not the same group of issuers you use to satisfy your
disclosure obligation
       pursuant to Item 201(e)(1)(ii) of Regulation S-K, and it is not clear
whether such peer
       group is the same group of issuers you use as a peer group for purposes
of your
       disclosures under Item 402(b) of Regulation S-K. In that regard, in
footnote 4 to your pay
       versus performance table, you indicate that your results are excluded
from the total
       shareholder return of your selected peer group, the health care REITs in
the FTSE
       NAREIT All Equity REITs Index; however, you are listed as part of the
peer group used
       to measure relative total shareholder return performance as described in
your
       Compensation Discussion and Analysis. Please advise. Refer to Item
402(v)(2)(iv) of
       Regulation S-K. Please also note that Item 402(v)(2)(iv) of Regulation
S-K provides that
 August 28, 2024
Page 2

       if the peer group is not a published industry or line-of-business index,
the identity of the
       issuers composing the group must be disclosed in a footnote.
2.     Refer to the column titled    Net income (GAAP)    in your pay versus
performance table. It
       appears that for 2022 and 2023 you have included net (loss) income
attributable to
       common stockholders as reported in your audited financial statements in
lieu of net
       income as required by Item 402(v)(2)(v) of Regulation S-K. Please
include net income
       (loss), as reported in your audited GAAP financial statements, for all
years covered by the
       table. Refer to Regulation S-K Compliance and Disclosure Interpretation
128D.08. Please
       note that you may voluntarily provide supplemental measures of net
income or financial
       performance, so long as any additional disclosure is    clearly
identified as supplemental,
       not misleading, and not presented with greater prominence than the
required disclosure.
       See Pay Versus Performance, Release No. 34-95607 (August 25, 2022) [87
FR 55134
       (September 8, 2022)] at Section II.F.3.
3.     We note that you have included Normalized FFO per share, a non-GAAP
measure, as
       your Company-Selected Measure pursuant to Item 402(v)(2)(vi) of
Regulation S-K.
       While Company-Selected Measure disclosure is not subject to Regulation G
or Item 10(e)
       of Regulation S-K, you must disclose how the measure is calculated from
your audited
       financial statements. Please tell us and revise future disclosure to
explain how this number
       is calculated from your audited financial statements. If this
information appears in a
       different part of the definitive proxy statement, you may satisfy the
disclosure
       requirement by a cross-reference thereto; however, incorporation by
reference to a
       separate filing will not satisfy this disclosure requirement.
4.     Please include your Company-Selected Measure in the Tabular List
provided pursuant to
       Item 402(v)(6) of Regulation S-K.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

      Please contact Christopher Dunham at 202-551-3783 or Laura Nicholson at
202-551-
3584 with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Disclosure Review
Program