Consent of Independent Registered
Public Accounting Firm
Summit Healthcare REIT, Inc.
Lake Forest, California
We hereby consent to the incorporation
by reference in the Registration Statement on Form S-8 (No. 333-212231) of Summit Healthcare REIT, Inc. of our report
dated March 25, 2020, relating to the consolidated financial statements which appears in this Form 10-K.
/s/ BDO USA, LLP
Costa Mesa, California
March 25, 2020