SecProbe.io

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Mail Stop 04-07

      							May 16, 2005

Via U.S. Mail and Fax (913-831-6556)
Mr. Paul R. Gardner
Chief Financial Officer
Concorde Career Colleges, Inc.
5800 Foxridge Drive
Suite 500
Mission, KS 66202

	RE:	Concorde Career Colleges, Inc.
      Form 10-K for the fiscal year ended December 31, 2004
		Filed March 15, 2005

	Form 10-Q for the quarter ended March 31, 2005
	File No. 000-16992

Dear Mr. Gardner:

      We have reviewed your filing 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.  As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934. Where indicated, we think you should revise your
document 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 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 fiscal year ended December 31, 2004

General
1. Tell us why you believe that you have only one reportable
segment.
In this regard, we note that you classify your programs into three
general categories.  In addition, you have recently created a
regional structure to manage your campuses.  If you have
aggregated
more than one operating segment into a single reportable segment,
tell us how you determined that you met the requirements in
paragraph
17 of SFAS 131 for aggregation, including the requirement that the
segments have similar economic characteristics.

Report of Independent Registered Public Accounting Firm, Part II -
p16
2. Refer to your auditor`s report where they state that their
audit
was conducted "in accordance with auditing standards of the Public
Company Accounting Oversight Board (United States)." The opinion
should state, instead, that the audit was "conducted in accordance
with the standards of the PCAOB." Have your auditors revise their
report to comply with PCAOB Auditing Standard No.1 and the related
SEC Release 34-49707.

Consolidated Statements of Operations
3. It appears that revenue and cost of revenue associated with
your
products and services are not segregated in accordance with Rule
5-03
(b) of Regulation S-X.  If your revenue from the sale of textbooks
and uniforms is greater than 10% of total revenues, revise your
income statement to present these amounts separately.

Note 1- Business and Summary of Significant Accounting Policies

	Revenue Recognition
4. We note that you establish an account receivable and
corresponding
deferred revenue liability for each student upon commencement of a
program of study.  Tell us why you believe it is appropriate to
recognize the receivable prior to earning the tuition revenue and
the
deferred revenue prior to receiving the cash.  Tell us how your
policy of recording receivables complies with the definition of an
asset in Statement of Financial Accounting Concepts 6.

Item 9a - Controls and Procedures, page 34
5. We note your disclosure that "our management, including the
Chief
Executive Officer and Chief Financial Officer, concluded that our
disclosure controls and procedures, subject to limitations as
noted
below, were effective."  Please revise to delete the "subject to
limitations" qualification and state simply whether or not
management
concluded that your disclosure controls and procedures were
effective
at the reasonable assurance level.  Alternatively you may state
simply, if true, that management concluded that your disclosure
controls and procedures were effective.  See Section II.F.4 of
Securities Act Release No. 33-8238 (June 5, 2003), which is
available
on our web site at http://www.sec.gov/rules/final/33-
8238.htm#iif4.
6. We note your disclosure that "[t]here have been no material
changes in our internal controls or in other factors that could
materially affect internal controls subsequent to December 31,
2004."
Please revise to clarify, if true, that there were no changes in
your
internal control over financial reporting that occurred during
your
last fiscal quarter that have materially affected, or are
reasonably
likely to materially affect, your internal control over financial
reporting.  See Item 308(c) of Regulation S-B, which became
effective
on August 14, 2003.  See also Section II.J. of Securities Act
Release
No. 33-8238 (June 5, 2003), which is available on our web site at
http://www.sec.gov/rules/final/33-8238.htm#iij.

Exhibit 31-1
Exhibit 31-2
7. Please revise to remove your exhibits from the body of the
periodic report.  The exhibits should be separately filed and
tagged
on EDGAR as exhibits, and not appended to the body of the periodic
report.

Form 10-Q for the fiscal quarter ended March 31, 2005, filed May
5,
2005
8. Please comply with the comments above as applicable to this
quarterly report on Form 10-Q.

* * * * *

      As appropriate, please amend your Forms 10-K and 10-Q and
respond to these comments within 10 business days or tell us when
you
will provide us with a response.  You may wish to provide us with
marked copies of the amendment to expedite our review.  Please
furnish a cover letter with your amendment that keys your
responses
to our comments and provides any requested supplemental
information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 writing, 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 filings; 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 connection with our review of
your
filing or in response to our comments on your filing.

      You may contact Kenya Wright, Staff Accountant, at (202)
551-
3373 or Melissa Hauber, Senior Accountant, at (202) 551-3368 if
you
have questions regarding comments on the financial statements and
related matters.  Please contact me at (202) 551-3810 with any
other
questions.

								Sincerely,

								Larry M. Spirgel
								Assistant Director

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Mr. Paul R. Gardner
Concorde Career Colleges, Inc.
May 16, 2005
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