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CORRESP
1
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      September 1, 2005 - corresp 1

    Mr.
      Larry
      Spirgel

    Assistant
      Director

    United
      States Securities and Exchange Commission

    Washington,
      D.C. 20549

    June
      15,
      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”) and represents further clarification of
      our position regarding your question number 4 in response to our phone
      conversation on June 7, 2005.

    As
      further clarification of our position and in response to our phone conversation
      on June 7, 2005, we have attached a copy of an enrollment agreement that is
      used
      for all enrollments. The enrollment agreement is signed by the student and
      a
      Company representative and legally binds and obligates the student as the
      responsible party for payment of all program cost. The enrollment agreement
      also
      sets forth the Company’s refund policy (which is in compliance with federal and
      state regulations). Note that the Company is not obligated to make any refunds
      to the student and/or federal or state lenders or grantors if the student
      completes 60% of the course.

    In
      addition, by signing the enrollment agreement, the student specifically
      authorizes the Company to sell, discount or transfer rights under the Agreement
      and/or Retail Installment Contract / Tuition Payment Addendum. The Company
      has
      utilized and its bank has accepted enrollment agreements as collateral for
      an
      operating line of credit.

    In
      summary, the Company believes that the recorded account receivable contains
      the
      three essential characteristics of an asset as set forth in Statement of
      Financial Accounting Concepts 6 because:

            a)

              entering
                a binding contract establishes 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 as demonstrated by its ability to pledge the
                receivable as collateral for its line of credit, and

            c)

              the
                transaction or other event (execution of the contract and beginning
                of
                classes) giving rise to the Company's right to or control of the
                benefit
                has already occurred.

    You
      requested information regarding the amount of time students remain in their
      program of study before they withdraw. Approximately 70% of our students
      complete their program of study. Students withdraw at various times during
      their
      program. If we use an example of 100 students starting the program 70 will
      complete the program, thirty will withdraw over the length of the program.
      Approximately 6 or 19% of those students withdraw within 30 days of beginning
      the program. An additional 5 or 17% will withdraw in the next 30 days. The
      chart
      below outlines the withdraw rate.

              #
                of students

              Based
                upon

              #
                of days in program before withdrawn

              100
                starts

              From

              To

                (A)

              &
                30 withdraws

              1

              30

              18.9%

              6

              31

              60

              17.2%

              5

              61

              90

              12.2%

              4

              91

              120

              10.4%

              3

              121

              150

              7.9%

              2

              151

              180

              6.5%

              2

              181

              end
                of program

              26.8%

              8

              100.0%

              30

    (A)
      This
      is the percentage of withdrawn students that fall within the associated time
      period. For example, 18.9% of withdrawn students withdraw from one to 30 days
      from the beginning of the program.

    If
      you
      have any questions you can contact me at (913) 831-9977

    Best
      regards,

    /s/
      Paul
      R.Gardner

    Paul
      R.
      Gardner

    Chief
      Financial Officer

    Concorde
      Career Colleges, Inc.

    5800
      Foxridge Drive, Suite 500

    Mission,
      Kansas 66202

    cc
      Jack
      L. Brozman, Chief Executive Officer, Concorde Career Colleges, Inc.

    Theodore
      J. Hempy, BKD LLP

    Thomas
      J.
      Lynn, Bryan Cave LLP