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May 25, 2005 - Correspondence

Mr. Larry
Spirgel

Assistant
Director

United
States Securities and Exchange Commission

Washington,
D.C. 20549

May 25,
2005

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.
Spirgel,

This
letter is in reference to your inquiry dated May 16, 2005 concerning Concorde
Career Colleges, Inc. (the “Company”). Our responses have been numbered to match
the comments in your letter. We have addressed your comments regarding both the
Form 10-K and Form 10Q in the same response.

    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.

    The Company's
business is providing career vocational training programs in the allied health
field. The Company serves the

    segment of
population seeking to acquire a career-oriented education. The Company only
provides programs that lead to a

    diploma or
associate degree. We do not offer bachelor or graduate degrees or provide online
degrees. The Company’s operations

    are
aggregated into a single reportable operating segment based upon similar
economic and operating characteristics as well as

    similar
markets. The Company’s operations are subject to similar regulatory
environments. Management does not evaluate

    performance
by region or by program category (core, clinical and other). The Company does
not allocate resources by region or

    program
category. The Company conducts its operations only in the United
States.

    Program
categories are identified in the public filings as additional information. The
Company classifies programs in three general

    categories;
clinical, core and other. Clinical programs (Surgical Technology, Respiratory
Therapy, Radiologic Technology, and

    Practical/Vocational
Nurse) are generally 12 to 15 months in length. The weekend Vocational Nursing
program and Radiological

    Technician
are longer, 18 and 24 months respectively. Clinical programs utilize clinical
training that occurs in a hospital or medical

    facility.
Core programs (Medical Assistant, Dental Assistant, Massage Therapy, Medical
Office Management, and Insurance

    Coding and
Billing Specialist) are generally 9 to 12 months in length and utilize an
externship immediately prior to graduation.

    Externships
occur in medical offices, dental offices, medical and dental clinics, medical
facilities, and hospitals. The remaining

    programs are
similar in nature to the core programs but are not currently offered in as many
campuses as the core programs. The

    nature of
training for all program categories is similar. The teaching, testing, and
completion process is similar for all program

    categories.
The target customer is similar for all program categories. The method used to
deliver programs is similar and the

    regulatory
environment is similar for all program categories.

    The Company
created a regional structure to improve oversight and corporate management of
each of our facilities. The regional

    structure
allowed us to locate education and operations experts closer to the respective
schools. This has facilitated travel,

    reduced
travel time and allowed the staff to spend more of their time training and
assisting field staff. Management does not

    evaluate
performance by region. Management evaluates performance by individual campus
irrespective of its region or program

    category mix
because of their similar economic characteristics. The Company believes that we
have only one reportable segment

    pursuant to
FASB Statement No. 131. As such we do not believe it is necessary to restate our
Form 10-K or Form 10-Q for

    segment
reporting.

    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.

    The Company
and BKD, LLP, our independent accounting firm concur with your comment. BKD, LLP
will revise their report to

    comply with
PCAOB Auditing Standard No. 1 and the related SEC Release 34-49707. The Company
requests that it not be subject

    to amending
its Form 10-K for fiscal year ended December 31, 2004 only for this revision.

    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.

    Revenue from
the sale of textbooks and uniforms was 6.8% of total revenues for the 12 months
ended December 31, 2004 and 7.6%

    of total
revenues for the three months ended March 31, 2005. The Company does not believe
any change is required pursuant to

    Rule 5-03 (b)
of Regulation S-X.

    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.

    The Company
believes it is appropriate to record the receivable and corresponding deferred
revenue liability for each student

    upon
commencement of a program of study because an event has occurred that obligates
the student to pay before all services

    are rendered.
That event is the signing of the enrollment agreement, which details the program
charges and program description,

    and the
student sitting in class one day. This event gives the Company the right to bill
and collect the tuition. Cash is received on

    the student’s
account in the following manner, a nominal registration fee is generally paid at
the time of enrollment, 40% of the

    receivable
balance is paid approximately 30 days after the program begins, substantially
all of the remaining receivable balance is

    paid
approximately six months after the program begins. The recorded account
receivable contains the three essential

    characteristics of an
asset as set forth in Statement of Financial Accounting Concepts 6 because: (a)
it embodies a probable future

    benefit that
directly contributes to future net cash inflows, (b) the Company has obtained
the benefit of the account receivable

    and controls
others' access to it, and (c) the transaction or other event giving rise to the
Company's right to or control of the

    benefit has
already occurred. In accordance with SEC Staff Accounting Bulletin No. 104,
revenue is recognized as services are

    rendered
(over the length of the program including any externship) because of the
existence of an agreement establishing a fixed

    price and
because collectibility is reasonably assured.

    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 .

    The Company’s
Form 10-K for the year ended December 31, 2004 included the following language
under Item 9a:

 “The Company conducted an evaluation of the effectiveness of the design
and operation of our disclosure controls and

procedures; as such term is defined under Rule 13a-15(e) promulgated under the
Securities Exchange Act of 1934, as

amended (Exchange Act), under the supervision of and with the participation of
our management, including the Chief

Executive Officer and Chief Financial Officer. Based on that evaluation, 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 at December 31, 2004, and during the period prior to and
including the date of this report. There have

been no material changes in our internal controls or in other factors that could
materially affect internal controls subsequent

to December 31, 2004. The Report of Management on Internal Controls can be found
under Item 8.”

“Because of its inherent limitations, our disclosure controls and procedures may
not prevent or detect misstatements. A

             control
system, no matter how well conceived and operated, can provide only reasonable,
not absolute, assurance that the

objectives of the control system are met. Because of the inherent limitations in
all control systems, no evaluation of controls

can provide absolute assurance that all control issues and instances of fraud,
if any, have been detected.”

     Securities
Act Release No. 33-8238 (June 5, 2003), cited in your comments, includes this
guidance:

“In
disclosures required under current Item 307 of Regulations S-K and S-B, Item 15
of Form 20-F and General Instruction

(6) to Form 40-F, some companies have indicated that disclosure controls and
procedures are designed only to provide

‘reasonable assurance’” that the controls and procedures will meet their
objectives. In reviewing those disclosures, the

Commission staff generally has not objected to that type of disclosure. The
staff has, however, requested companies

including that type of disclosure to set forth, if true, the conclusions of the
principal executive and principal financial officer

that the disclosure controls and procedures are, in fact, effective at the
‘reasonable assurance’ level.

    We understand
that the Commission’s staff regularly objects to attempts to use exculpatory
language or limitations to go beyond

    the
‘reasonable assurance’ limitation described in Securities Act Release No.
33-8238.

    In this case,
the “subject to limitations” is, as is evident from a review of the quoted
material above, simply a statement of the

    ‘reasonable
assurance’ standard; it is not language that is intended to, or that can be
fairly read to, limit the scope of the

    conclusions
as to effectiveness of the disclosure controls and procedures (except as is
permitted by the guidance regarding

    ‘reasonable
assurance’ given in the previously cited release). For that reason, the Company
believes that your comment is

    inapplicable
in this particular case.

    However, in
response to the comment, the Company will revise its disclosures in future
filings, and will re-word the disclosure to

    state (if
then true) that the “conclusions of the principal executive and principal
financial officer that the disclosure controls and

    procedures
are … effective at the ‘reasonable assurance’ level”, and, to avoid any
confusion, will not include the “subject to

    limitations”
language.

    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 .

    Item 308(c)
of Regulation S-K requires registrants to “[d]isclose any change in the
registrant’s internal control over financial

    reporting
identified in connection with the evaluation required by paragraph (d) of
240.13a-15 or 240.15d-15 of this chapter that

    occurred
during the registrant’s last fiscal quarter (the registrant’s fourth fiscal
quarter in the case of an annual report) that has

    materially
affected, or is reasonably likely to materially affect, the registrant’s
internal control over financial report.”

    The Company
did not have any changes in its internal control over financial reporting that
materially affected, or that was

    reasonably
likely to materially affect, the registrant’s internal control over financial
reporting. Because there was no change

    requiring
disclosure under Item 308(c) of Regulation S-K, the Company has satisfied its
disclosure obligations under the item, and

    in our view
no change to the disclosure is necessary under the rule. The Company simply does
not have an affirmative obligation

    under the
rule, as presently written, to make a statement to the effect that there were no
changes in internal control over financial

    reporting
that occurred during the last fiscal quarter that materially affected, or were
reasonably likely to materially affect, the

    Company’s
internal control over financial reporting. For that reason, the Company believes
that a revision to the filing is

    unnecessary.

    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.

  The Company will file all future
reports with exhibits separate from the body of the periodic reports. We request
that we not be

  required to file an amended Form
10-K for fiscal year ended December 31, 2004 or an amended Form 10-Q for the
fiscal quarter

  ended March 31, 2005 for
this correction.

    8.

      Please
      comply with the comments above as applicable to this quarterly report on
      Form 10-Q.

  Please see our comments in the
responses above for Form 10-Q for the fiscal quarter ended March 31, 2005, filed
on May 5, 2005.

The
Company acknowledges 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.

If you
have any questions you can contact me at (913) 831-9977. I will be unavailable
from May