no
ROI = return on investment, how much on average you profit. Profit does not = winnings, it's how much you win - expenses.
the formula is (total winnings-expense / expense) x 100
If you spent $100 in entrance fees and rake and won $200 in total then your ROI would be 100%.
In your case, if you won a total of $55, and paid $38, your ROI would be:
55-38/38 x 100 = 44.7%
If your total PROFIT was $55, after factoring in the costs, then your roi would be 144%