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                            July 21, 2020

       Stephen Epstein
       Chief Executive Officer
       Healthcare Business Resources, Inc.
       718 Thompson Lane, Suite 108-273
       Nashville, Tennessee 37204

                                                        Re: Healthcare Business
Resources, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed July 13, 2020
                                                            File No. 333-239000

       Dear Mr. Epstein:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our July
2, 2020 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Prospectus Summary, page 2

   1.                                                   We re-issue our prior
comment no. 1 in part. Please explain why you believe that "many
                                                        healthcare
organizations face significant operational and financial changes" and how your
                                                        business model
addresses these changes.
       Executive Compensation, page 29

   2.                                                   We re-issue our prior
comment no. 8. Please file a written description of the CEO's
                                                        compensatory plan as an
exhibit. Refer to Item 601(b)(10)(iii)(A) of Regulation S-K.
 Stephen Epstein
FirstName
Healthcare LastNameStephen  Epstein
           Business Resources, Inc.
Comapany
July       NameHealthcare Business Resources, Inc.
     21, 2020
July 21,
Page  2 2020 Page 2
FirstName LastName
General

3.       We note your response to our prior comment no. 10. Please revise your
risk factor
         disclosure to include the statements that you made in the"Description
of Securities"
         section, specifically that your exclusive forum selection does not
apply to federal
         securities claims, a court could find the choice of forum provisions
to be inapplicable or
         unforeseeable, and shareholders cannot waive compliance with the
federal securities laws.
       Please contact Cara Wirth at (202) 551-7127 or Mara Ransom at (202)
551-3264 with
any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Trade &
Services
cc:      Joel Arberman