May 16, 2025

Jason Clemens
Chief Financial Officer
AdaptHealth Corp.
220 West Germantown Pike Suite 250
Plymouth Meeting , PA 19462

       Re: AdaptHealth Corp.
           Form 10-K for the Fiscal Year Ended December 31, 2024
           Filed February 25, 2025
           File No. 001-38399
Dear Jason Clemens:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. 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.

Form 10-K for the Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Reclassifications, page 38

1.     We see your disclosure that prior to the quarter ended December 31,
2024, you
       classified certain expenses, primarily related to revenue cycle
management costs, as a
       component of Cost of net revenue in the Consolidated Statements of
Operations.
       Beginning in the quarter ended December 31, 2024, you have reclassified
these costs
       within General and administrative expenses to better align with common
industry
       practice. Since it appears that these are significant adjustments,
please tell us more
       about the nature of the expenses that were reclassified and why.
 May 16, 2025
Page 2
Consolidated Results of Operations
Net Revenue, page 43

2.     We see that, overall, you attribute the increase in net revenue to
non-acquired growth
       of $56.3 million. Please respond to the following:
           Tell us and revise future filings to define how you calculate
non-acquired growth
           and disclose any changes in your calculations, if any, and
           Tell us how management uses this measure as part of their overall
analysis, as we
           do not see any significant reference to non-acquired growth in your
Earnings
           Release or on your Earnings Call.
3.     Your discussion of the increases in net revenue from your sleep health
segment and
       respiratory health segment both indicate that the increases were related
to strong
       patient demand which appear vague and repetitive. Please revise your
disclosure to
       provide a more comprehensive and substantive explanation of the key
underlying
       factors that resulted in the increase. In addition, where changes in
financial statement
       line items are the result of several factors, each significant factor
should be separately
       quantified and discussed. Please provide further explanation to us and
revise future
       filings accordingly to address our concerns.
Financial Statements
Note 3. Acquisitions, page 87

4.     We see your disclosure that you acquired certain assets from a provider
of home
       medical equipment for a cash payment of $9.5 million, most of which was
allocated to
       goodwill. Please clarify for us if this is an asset acquisition or a
business combination.
       Since it appears to be an asset acquisition based upon your disclosure,
it is unclear
       why you recorded any amounts to goodwill. See ASC 805-50-30-3.

        In closing, 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 Julie Sherman at 202-551-3640 or Li Xiao at 202-551-4391
with any
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Industrial Applications and
                                                              Services