Franklin, Tenn.-based hospital operator Community Health Systems Inc. has announced a cash tender of up to $400 million total to buy back portions of four separate debt issues at prices below par. Considering the prices offered, we consider the offer for the company's 2023 and 2024 junior-priority secured notes (85% and 80% of par, respectively) and the 2028 unsecured notes (55% of par) as distressed. We do not view the offer for the company's 2022 debt maturities to be distressed given the small discount to par and the company's likely ability to repay the debt with cash upon maturity. We are lowering the issuer credit rating to 'CC' from 'CCC+', the issue-level ratings on the junior-priority secured notes due in