SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

June 20, 2005

Mr. Robert P. Heller
Vice President of Finance and Chief Financial Officer
National Home Health Care Corp.
700 White Plains Road
Scarsdale, NY  10583

Re:	National Home Health Care Corp.
	Form 10-K for the fiscal year ended July 31, 2004
	File No. 000-12927

Dear Mr. Heller:

      We have reviewed your filing to those issues we have
addressed
in our comments.  In our comments, we ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may 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 filing.
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 for the year ended July 31, 2004 filed on October 29,
2004

Management`s Discussion and Analysis, page 19

Critical Accounting Policies, page 21

1. Please provide to us the following information:

a. For each period presented, quantify the amount of changes in
estimates of prior period contractual adjustments that you
recorded
during the current period. For example for 2004, this amount would
represent the amount of the difference between estimates of
contractual adjustments for services provided in 2003 and the
amount
of the new estimate or settlement amount that was recorded during
2004.

b. In a comparative tabular format, please provide the payor mix
concentrations and related aging of accounts receivable.  The
aging
schedule may be based on management`s own reporting criteria (i.e.
unbilled, less than 30 days, 30 to 60 days etc.) or some other
reasonable presentation.  Please indicate the past due amounts and
a
breakdown by payor classification (i.e. Medicare, Medicaid,
Managed
care and other, and Self-pay).  We would expect Self-pay to be
separately classified from any other grouping.  If your billing
system does not have the capacity to provide an aging schedule of
your receivables, confirm that fact for us and clarify how this
affects your ability to estimate your allowance for bad debts.
c. If you have amounts that are pending approval from third party
payors (i.e. Medicaid Pending), please provide the balances of
such
amounts, where they have been classified in your aging buckets,
and
what payor classification they have been grouped with.  If amounts
are classified outside of self-pay, tell us why this
classification
is appropriate, and tell us the historical percentage of amounts
that
get reclassified into self-pay.
d. Provide to us a description of the steps you take in collecting
accounts receivable, including when you determine a receivable is
recorded as a bad debt and when a write off is recorded.  State
the
threshold (amount and age) for account balance write-offs.
e. Tell us why you do not believe that the above information
should
be disclosed in your filing.

2. We noted in the Notes to the Consolidated Financial Statements
that you defer recognition of revenue for amounts received prior
to
completion of services rendered.  Please provide to us how you
determine the amount of revenue to be deferred and your policy for
recognizing this deferred amount during the episode of care.

*    *    *    *
	Please respond to these comments within 10 business days of
the
date of this letter or tell us when you will provide us with a
response.  Please furnish a letter that keys your responses to our
comments and provides any requested information.  Detailed letters
greatly facilitate our review.  You should file the letter on
EDGAR
under the form type label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Christine Allen, staff accountant, at (202)
551-3652 or Kevin Woody, Branch Chief, at (202) 551-3629 if you
have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 551-3679.

								Sincerely,

								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
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Mr. Robert P. Heller
National Home Health Care Corp.
June 20, 2004
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