November 8, 2018

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 limited our review of your filing to the financial statements
and related
disclosures 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.

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

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

1.    At the bottom of page 97 you disclose that the prior year unfavorable
development
      recorded in 2017 is the result of "inaccurate adjudication of provider
claims at our Florida,
      Illinois, New Mexico and Puerto Rico health plans that created
substantial payment
      backlogs which we were unable to adequately measure when we estimated our
liability at
      December 31, 2016." Please address the following:
        Tell us what you mean by inaccurate adjudication of provider claims,
and provide us
           the facts and circumstances surrounding these inaccuracies as well
as their causes and
           when they occurred and were discovered.
        Tell us how the inaccurate adjudications created substantial payment
backlogs that you
 Thomas L. Tran
Molina Healthcare, Inc.
November 8, 2018
Page 2
             were unable to measure when you estimated your liability at
December 31, 2016 and
             the relevance of these payment backlogs on your estimate of the
December 31, 2016
             liability.
             Tell us the estimated amount of 2017 unfavorable development
attributable to the
             inaccurate adjudications and inability to accurately measure
payment backlogs for
             each of the identified health plans.
       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.

      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
November 8, 2018 Page 2                                     Office of
Healthcare & Insurance
FirstName LastName