SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 3-8

											May 5, 2005

By Facsimile and U.S. Mail

Mr. John H. Treglia
President, Chief Executive Officer, Secretary and Director
Comprehensive Healthcare Solutions, Inc.
45 Ludlow Street, Suite 602
Yonkers, New York 10705

		RE:	Comprehensive Healthcare Solutions, Inc.
			Form 10-K/A for the fiscal year ended October 2,
2004
			Filed March 30, 2005
			File No. 033-08955
			Form 10-QSB/A for the period ended May 31, 2004
			Filed April 1, 2005
			Form 10-QSB/A for the period ended August 31, 2004
			Filed April 4, 2005
			Form 10-QSB/A for the period ended November 30,
2004
			Filed April 4, 2005

Dear Mr. Treglia:

		We have reviewed your filings and have the following
comments.  We have limited our review to only your financial
statements and related disclosures and will make no further review
of
your documents.  Where indicated, we think you should revise your
documents in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K Amendment No. 3 for the fiscal year ended February 28,
2004

General

1. Please take into consideration all of the following comments on
your Form 10-K, as applicable, when you revise your Form
10QSB/A`s.

2. You filed your amendment on a Form 10-K however it appears in
certain cases you have followed the disclosure requirements of
Regulation S-B.  For example, you only present the fiscal 2004
year
end balance sheet in your audited financial statements.  A
reporting
company may enter the S-B system only at the beginning of a fiscal
year, and must determine at the time of its first filing in a
fiscal
year (first quarterly report, Form 8-K, or registration statement)
whether it will enter the S-B reporting system. A reporting issuer
cannot enter the S-B system during a fiscal year if it has already
filed Exchange Act reports for periods included in that fiscal
year
under Regulation S-X.  Please amend your filing to comply with the
disclosure requirements of Form 10-K.  After review of the amended
Form 10-K we may have further comments.

Item 1. Business

Comprehensive Network Solutions, Inc., page 16

3. Your references to "Nantucket" here, and in other sections of
your
filing, are confusing.  Please revise your filing to replace
references to Nantucket with more appropriate references to the
current name of the company.

Item 5. Market for the Registrant`s Common Stock and Related
Security
Holder Matters, page 20

4. Please revise to disclose the approximate number of holders of
record of common stock.  Refer to Item 201(b) of Regulation S-K.

Item 6. Selected Financial Data, page 21

5. Certain fiscal 2004 amounts in your summary statements of
operation and summary balance sheet data do not agree with the
financial statements.  Please revise.

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Results of Operations, page 24

6. Please revise to include discussion of net sales and gross
margin
attributed to each product or service category, for example net
sales
and gross margin attributed to audiological testing and hearing
aids,
if considered material.  Your disclosures should indicate whether
you
expect trends, if applicable, to continue and why or why not.
Refer
to SEC Release No. 33-8350 and Item 303 of Regulation S-K.

7. You state that selling, general and administrative expenses
("SG&A") were $337,881 for fiscal 2004.  Per the financial
statements
SG&A totaled $360,381.  Please revise and consider whether
additional
discussion is necessary to explain the change in SG&A.

Liquidity and Capital Resources, page 24

8. Please revise to discuss material changes between periods in
your
cash flows from operating, investing, and financing activities.
Refer to SEC Release No. 33-8350 and Item 303 of Regulation S-K.

Item 8. Financial Statements and Supplementary Data

General

9. You have made changes to the financial statements that were
previously issued.  Please revise to provide all disclosures
required
by APB 20.  In particular, you should ensure that you disclose the
previously filed amounts, changes made and restated amounts for
each
financial statement line item affected.  Each adjustment should be
explained.

Report of Independent Public Accounting Firm

10. Please revise your filing to include an audit opinion related
to
the balance sheet as of February 28, 2003 and the related
statements
of operations, changes in shareholders deficiency, and cash flows
for
the years ended February 28, 2003 and 2002.  If you plan to refer
to
the predecessor auditor please ensure you follow the guidance in
AU508.

11. We note your independent accountants, Jewett, Schwartz &
Associates, are located in Florida while you are headquartered in
New
York.  Please have your accountants supplementally confirm to us
that
they are registered to practice in New York, or confirm that no
such
registration is necessary.  If your accountants are registered in
New
York, please have them provide us with their license number.

Consolidated Statements of Operations, page F-4

12. It is our understanding that net sales substantially refers to
fees earned from audiological testing as well as the sales of
hearing
aids.  Net revenues from the sale of tangible products and
services
along with the related cost of sales should be stated separately
in
the statements of operations.  Refer to Rule 5-03 of Regulation S-
X.
Please revise.

13. Depreciation and amortization should be included as an
operating
expense rather than other expenses.  Refer to Rule 5-03 of
Regulation
S-X and SAB Topic 11.B.  Please revise.

Consolidated Statements of Stockholders` Equity, page F-5

14. Per Note 9 in June 2002 you terminated a consulting agreement
and
rescinded 1,200,000 shares of common stock.  Please supplementally
explain how the 1,200,000 shares of common stock were accounted
for
at the date of execution of the consulting agreement and then upon
rescission.  Tell us where in your financial statements the
transactions were reflected.  Please cite authoritative guidance
supporting your accounting.

15. Please supplementally explain the common stock subscribed and
subscription receivable activity.  Please revise your balance
sheet
to present the subscription receivable as a separate line item in
stockholders` equity if the amount is receivable from officers or
directors.  Please revise to disclose the nature of the
transaction
in the notes to the financial statements.  Refer to EITF 85-1 and
SAB
Topic 4E.

16. In fiscal 2003 and fiscal 2004 you issued shares in private
placement sales at $0.21 and $0.25 per share, respectively.  Your
valuation of shares issued in fiscal 2004 for the consultant
agreement was $0.26 per share.  Your valuation of shares issued
for
executive compensation in fiscal 2003 and 2004 was valued
significantly lower at $0.06 and $0.07, per share, respectively.
Please supplementally explain how you determined the value of
shares
issued to executives and why such values differed significantly
from
the values ascribed to your shares in transactions with unrelated
third parties.

17. Please supplementally explain the fiscal 2004 convertible debt
transaction.  Please supplementally explain the consolidated
balance
sheet and consolidated statements of cash flow presentation of the
transaction.  Please revise the notes to the consolidated
financial
statements to disclose the transaction.

Consolidated Statements of Cash Flows, page F-5

18. Please supplementally explain the line item "(Increase)
decrease
in other assets."  Please revise if necessary.

19. Cash inflows from financing activities include proceeds
received,
for example, from issuing equity instruments, bonds, mortgages,
notes, and from other short- or long-term borrowing.  Based on
review
of your notes to the consolidated financial statements it does not
appear that you received proceeds that should be classified as
financing activities totaling $762,400 in fiscal 2004.  Please
supplementally explain and revise if necessary.  Note that the
value
of equity instruments issued as non-cash compensation to employees
and non-employees which are expensed should be included as non-
cash
adjustments in the operating activities section of the statements
of
cash flows.  Refer to SFAS 95.

20. Please provide a supporting schedule to your revised
consolidated
statements of cash flows.  The schedule should include a
reconciliation to applicable consolidated balance sheets.

Notes to Consolidated Financial Statements

Note 1. Reorganization

General

21. In a reverse acquisition shareholders` equity should be
determined and presented on the consolidated balance sheet as if
the
consolidated financial statements are a continuation of the
accounting acquiror / legal acquiree (Accutone, Inc.).  The
retained
deficit and other surplus accounts in the consolidated financial
statements immediately after the reverse acquisition would be the
same as the accounts of the accounting acquiror / legal acquiree
at
that date.  The retained deficit and other surplus accounts of the
legal acquiror (Nantucket Industries, Inc.) at the date of the
legal
combination would be eliminated in consolidation.  We assume your
accumulated deficit of $13,153,009 as of February 28, 2002
principally relates to operations of Nantucket Industries Inc.
prior
to the January 25, 2002 reverse acquisition.  If so, please revise
your filing to eliminate the retained deficit and additional paid
in
capital of Nantucket included in your February 28, 2002 equity
accounts.

Basis of Presentation and Going Concern, page F-7

22. You refer to SFAS 7.  SFAS 7 refers to the accounting and
disclosure requirements of developmental stage enterprises.  Do
you
consider yourself a developmental stage enterprise in accordance
with
SFAS 7?  If so, it does not appear you have followed the
accounting
and disclosure requirements of SFAS 7.  Please supplementally
explain
and revise.

23. You disclose that you have not commenced planned principal
operations and you have not generated revenues from prospective
customers.  Based on review of this filing, neither of these
statements appear accurate.  Please revise or advise.

Note 2. Summary of Significant Accounting Policies

Intangible Assets, page F-12

24. Please supplementally provide your fiscal 2004 impairment test
performed on your intangible assets.  Please supplementally
provide
support for your assumptions.  In light of your unfavorable
operating
history, negative cash flows and weak liquidity position, it is
unclear how you support recoverability of the assets.

Segment Information, page F-13

25. You disclose that adoption of SFAS 131 is not expected to have
a
material impact on your financial statements.  You also disclosed
that the adoption of SFAS 130 is not expected to have a material
effect on your financial statements.  It appears that these items
were disclosed in order to meet the disclosure requirements for
recently issued accounting standards.  It appears that the current
disclosures referring to SFAS 130 and 131 are no longer needed.
Please consider removing these disclosures and update your filing
in
accordance with the disclosure requirements for recently issued
accounting standards if any are deemed necessary.  Refer to SAB
Topic
11M.

Impairment of Long-Lived Assets, page F-13

26. SFAS 121 was superseded by SFAS 144.  SFAS 144 was effective
for
financial statements issued for fiscal years beginning after
December
15, 2001 and interim periods within those fiscal years.  Please
revise your disclosure and also revise the impairment testing
performed, if needed.  You also state that no impairment loss was
required in fiscal 2003.  Please revise to update for fiscal 2004.
Please supplementally provide the impairment analysis in
accordance
with SFAS 144.  Please supplementally provide support for your
assumptions.

Note 4. Acquisition of Audiology, page F-14

27. You disclose that the contract executed with Park Avenue
Medical
Practice Associates, P.C. and Park Avenue Health Care Management,
Inc. calls for Brad I. Markowitz to join your Board of Directors.
Mr. Markowitz is not listed as a Director in Item 10 of the
filing.
Please revise or advise.

Note 5. Property and Equipment, page F-15

28. Please revise to disclose the estimated useful lives for each
category of property and equipment disclosed.  Please also revise
to
disclose the depreciation expense for the periods presented.
Refer
to APB 12.

Item 9A. Controls and Procedures, page 26

29. We note that your certifying officers disclose their
conclusions
as to the adequacy of your disclosure controls and procedures.
However, Item 307 of Regulation S-K requires that your certifying
officers disclose their conclusions regarding the effectiveness
(not
adequacy) of your disclosure controls and procedures.  Please
revise
accordingly.

30. We note that your certifying officers disclose their
conclusions
as to the adequacy of your disclosure controls and procedures
"within
90 days before the filing date of this report."  However, Item 307
of
Regulation S-K requires that your certifying officers disclose
their
conclusions regarding the effectiveness of your disclosure
controls
and procedures "as of the end of the period covered by the
report."
Please revise accordingly.

31. Your disclosure also provides that your principal executive
and
financial officers evaluated the effectiveness of your disclosure
controls and procedures "(as defined in rule 13a -14(c) and 15d -
14(c) under the Securities Exchange Act of 1934, as amended)."
However, Exchange Act Rules 13a-15(e) and 15d-15(e) define
disclosure
controls and procedures.  Revise your citation to reference the
correct rules.

32. Please revise your disclosure regarding changes to internal
controls and procedures over financial reporting to identify "any
changes," not just "significant" changes, that have materially
affected, or are reasonably likely to materially affect, your
internal controls and procedures over financial reporting.  See
Item
308(c) of Regulation S-K.

Item 14. Principal Accounting Fees and Services

33. Please revise your disclosure to include the aggregate audit
and
tax fees billed each of the last two fiscal years.  In this regard
we
noticed that it does not appear that the audit fees section
includes
billings from Jewett, Schwartz & Associates.

Item 15. Exhibits and Reports on Form 8K

34. Each filing must have an index of exhibits. If the exhibits
are
incorporated by reference, this fact should be noted in the
exhibit
index.  In this regard we would expect to see certain items listed
as
exhibits and included as an exhibit or incorporated by reference
including but not limited to articles of incorporation and bylaws.
In addition, material agreements such as the joint venture
agreement
with Alliance Healthcare, Inc. and the joint marketing agreement
with
Thesco Benefits, LLC should also be filed.  We noted that you
include
exhibits 31 and 32 in the filing however they are not listed in
the
index of exhibits.  Refer to Item 601 of Regulation S-K.  Please
revise.

Exhibit 31

35. Please revise to remove reference to yours