Via Facsimile and U.S. Mail
Mail Stop 6010


November 18, 2005


Mr. John R. Potapchuk
Senior Vice President, Chief Financial Officer, Treasurer and
Secretary
(Principal Financial and Accounting Officer)
Gentiva Health Services, Inc.
3 Huntington Quadrangle, Suite 200S
Melville, NY 11747-4627

      Re:	Gentiva Health Services, Inc.
		Form 10-K for the Fiscal Year Ended January 2, 2005
      File No. 001-15669

Dear Mr. Potapchuk:

      We have reviewed your response dated November 9, 2005 to our
comment letter dated October 21, 2005 and have the following
comments.  Where indicated, we think you should revise your
document
in response to these comments. If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.


January 2, 2005 Form 10-K, filed March 17, 2005

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 17

Critical Accounting Policies and Estimates, pages 32 - 34
1. Please refer to your response to our prior comment number
three.
We note that for several critical accounting estimates, you have
determined that "it is not possible to predict the degree of
change
that might be effected".  Please disclose, and elaborate on the
specific circumstances that preclude this information from being
disclosed, as referred to by this statement.  Include a discussion
of
how these constraints may affect or preclude your ability to make
reasonable and reliable estimates.
2. Additionally, with respect to your estimates of revenue, costs
of
claims incurred, and obligations under insurance programs, please
revise your disclosure to clarify whether changes in estimates
have
been material for each period presented.  For each disclosure,
please
quantify any material changes in estimate.  It does not appear
that
disclosure regarding costs of claims incurred and obligations
under
insurance programs provide the discussion required by Release 33-
8350.  Further, since the amount of expense recognized in each
period
presented for these two estimates, it is difficult to assess the
significance of these two critical estimates.  Please expand the
disclosure as necessary.

Revenue Recognition, page 32
3. We note your response to our prior comment number four and have
the following comments:
a. We continue to believe that the accounts receivable aging
report
provides meaningful information to investors, especially given the
significance of your accounts receivables and should at a minimum
should indicate the past due amounts and a breakdown by payor
classification.
b. Please refer to the third paragraph of your response to our
prior
comment number four.  We note that "all payers are reviewed and
analyzed separately".  However, your proposed disclosure does not
provide information about the review process at this level.
Please
revise your disclosure to address how accounts receivable is
reviewed
and analyzed by payor-type.


*    *    *    *

      As appropriate, please amend your January 2, 2005 Form 10-K
and
respond to these comments within 10 business days or tell us when
you
will provide us with a response.  You may wish to provide us with
marked copies of the amendment to expedite our review.  Please
furnish a cover letter with your amendment that keys your
responses
to our comments and provides any requested information.  Detailed
cover letters greatly facilitate our review.  You should file the
letter on EDGAR under the form type label CORRESP.  Please
understand
that we may have additional comments after reviewing your
amendment
and responses to our comments.

      You may contact Tabatha Akins, Staff Accountant, at (202)
551-
3658 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551-
3614
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3679 with any
other questions.


Sincerely,



Jim B. Rosenberg
      Senior Assistant Chief Accountant

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John R. Potapchuk
Gentiva Health Services, Inc.
November 18, 2005
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