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                            July 16, 2020

       Mike Pykosz
       Chief Executive Officer
       Oak Street Health, Inc.
       30 W. Monroe Street
       Suite 1200
       Chicago, IL 60603

                                                        Re: Oak Street Health,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed July 10, 2020
                                                            File No. 333-239818

       Dear Mr. Pykosz:

                                                        We have reviewed your
registration statement and have the following comment.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this comment, we may have additional comments.

       Registration Statement on Form S-1 filed July 10, 2020

       Key Business Metrics, page 88

   1.                                                   You presented Center
Contribution as a metric here on page 88, while providing a
                                                        definition for Platform
Contribution but not for Center Contribution on page 89. Please
                                                        revise accordingly,
ensuring that your business metrics are consistently presented
                                                        throughout the filing.
               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.
 Mike Pykosz
Oak Street Health, Inc.
July 16, 2020
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact Li Xiao at 202-551-4391 or Kevin Vaughn at 202-551-3494
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Jeffrey Gabor at 202-551-2544 or Mary Beth Breslin at 202-551-3625 with any
other questions.



                                                           Sincerely,
FirstName LastNameMike Pykosz
                                                           Division of
Corporation Finance
Comapany NameOak Street Health, Inc.
                                                           Office of Life
Sciences
July 16, 2020 Page 2
cc:       Robert E. Goedert, Esq.
FirstName LastName