SecProbe.io

CORRESP
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      September 1, 2005 - corresp 3

    Mr.
      Larry
      Spirgel

    Assistant
      Director

    United
      States Securities and Exchange Commission

    Washington,
      D.C. 20549

    August
      23, 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 regards question number four in that
      inquiry regarding receivables. We have had three separate conference calls
      with
      the Staff to clarify questions for both the Company and the Staff. The Staff
      has
      been extremely helpful in clarifying the SEC’s position regarding classification
      of receivables.

    Company
      Description

    Concorde
      is a small cap company with a market capitalization of approximately $88,470,000
      based upon outstanding common shares of 5,997,942 at June 30th
      and a
      recent stock price of $14.75. Concorde provides career vocational training
      programs in the allied health field at twelve locations.

    Issue

    We
      have
      historically established an account receivable and corresponding deferred
      revenue liability for each student upon commencement of a program of study.
      We
      believed our accounting methodology in classifying accounts receivables met
      the
      requirements of Statement of Financial Accounting Concepts 6. Our method of
      recording accounts receivable has never been questioned in prior reviews of
      our
      quarterly and annual reports by the Securities and Exchange Commission nor
      was
      it questioned by outside accounting firms. However, in light of the concerns
      raised by the Staff in its review, we have committed to change our method of
      recording accounts receivable on a prospective basis.. We believe that revisions
      to our previously-filed financial statements are not necessary in the current
      circumstance.

    Reasons
      why we request a prospective change

    The
      costs
      associated with implementing and documenting the reclassification of receivables
      would be high if we restate prior years. As a small cap company we have a
      limited number of staff. It would require a lot of time and resources to restate
      prior years. There would be limited benefit to shareholders if we restated
      prior
      periods. A restatement of our previously filed financial statements to implement
      this accounting change would have no effect on earnings, and would only impact
      the balance sheet by reducing the account receivable balance and deferred
      revenue liability. A restatement of our previously filed financial statements
      would not, in our view, provide significant new information to a reasonable
      investor. In light of these considerations, we believe that the burden on the
      Company of a required restatement of its previously filed financial statements
      would far outweigh any hypothetical benefit to the Company’s stockholders and
      the public.

    Description
      of change

    We
      will
      record receivables as follows for future periods:

    When
      a
      student commences his or her program of study no journal entry would be recorded
      in the financial statements. At the completion of each financial period an
      entry
      would be recorded to reflect the appropriate amount of revenue earned and the
      corresponding receivable due for that financial period. Payments will be
      recorded as received and applied to the student account reducing the receivable.
      Payments received for the student account in excess of the receivable due will
      be reflected as a liability due to the student.

    For
      example, a student enrolled in a $20,000 program that is 10 months in length
      would have the following transactions recorded:

          1.

            At
              commencement of the program - no entry

          2.

            Upon
              completion of the first month - Debit to Accounts Receivable for $2,000
              and Credit to revenue for $2,000.

          3.

            Upon
              receipt of cash of $5,000 at the end of the first month - Debit to
              Cash
              for $5,000, Credit to Accounts receivable for $2,000 and Credit to
              Prepaid
              Tuition (a liability account) for $3,000.

          4.

            At
              the completion of the program no balance would remain in Prepaid Tuition
              for the student. An Accounts Receivable balance would remain to the
              extent
              the student had not completed payment for the program.

    We
      formally request that we be allowed to reclassify our accounts receivable,
      as
      described herein, on a prospective basis beginning with the quarter ending
      September 30, 2005. The reclassification will reduce the account receivable
      balance and reclassify accounts receivable to reflect the amount of tuition
      earned in excess of cash received for each student. We will also reclassify
      deferred revenue liability and reflect the balance as cash received in excess
      of
      tuition earned or prepaid tuition. We will reclassify the prior period numbers
      in future reports for comparative purposes.

    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