February 11, 2019

Thomas L. Tran
Chief Financial Officer and Treasurer
Molina Healthcare, Inc.
200 Oceangate, Suite 100
Long Beach, California 90802

       Re: Molina Healthcare, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           File No. 001-31719

Dear Mr. Tran:

        We have reviewed your December 13, 2018 response to our comment letter
and have the
following comment. In our comment, we ask you to provide us with information so
we may
better understand your disclosure.

       Please respond to this comment within 10 business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

     After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
November 8, 2018 letter.

Form 10-K for the Fiscal Year Ended December 31, 2017

Notes to the Consolidated Financial Statements
Note 10: Medical Claims and Benefits Payable, page 95

1.    It appears from your response to the first bullet of our prior comment
that your "inaccurate
      adjudication of provider claims" in 2016 is the result of programmed
claims payment
      configuration in your claims processing systems that was inconsistent
with the specific
      terminology in certain provider contracts. This situation ultimately
caused a backlog
      in claims processing and the understatement of your medical care costs in
2016 and the
      related medical claims and benefits payable at December 31, 2016. Please
address the
      following:
        Tell us why you did not properly reflect the claims payment parameters
in your claims
          processing system.
 Thomas L. Tran
Molina Healthcare, Inc.
February 11, 2019
Page 2

             Tell us why restatement of your financial statements in accordance
with ASC 250-10-
             45 is not necessary.
             To the extent that you believe such restatement is not necessary,
tell us how your
             medical claims and benefits payable at December 31, 2016 would not
have been
             substantially different if you had originally configured your
claims payment
             parameters in your claims processing systems properly.
      You may contact Mark Brunhofer at (202) 551-3638 or Sharon Blume at (202)
551-
3474 with any questions.



FirstName LastNameThomas L. Tran                            Sincerely,
Comapany NameMolina Healthcare, Inc.
                                                            Division of
Corporation Finance
February 11, 2019 Page 2                                    Office of
Healthcare & Insurance
FirstName LastName