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ATTORNEYS

July 29, 2005

Securities and Exchange
Commission

450 Fifth Street, N.W.

Washington, D.C.  20549-0406

Attention:                                         Stephen
Krikorian

Accounting Branch Chief

Re:                               NWH,
Inc,

Form 10-K For the Fiscal Year Ended October 31, 2004

Form 10-Q For the Fiscal Quarter Ended January 31, 2005

Form 10-Q For the Fiscal Quarter Ended April 30, 2005

File No.: 000-26598

Greetings:

We are in receipt of the
Commission’s letter of comment, dated July 19, 2005, and, on behalf of NWH,
Inc. (“NWH” or the “Company”), have the responses set forth below.  Please be advised that the numbers of the
following responses correspond to the bulleted paragraphs in the Staff’s
letter.

Form 10-Q for the Quarterly Period Ended April 30,
2005

Item 2. Management’s Discussion and Analysis of
Financial Condition and Results of Operations

Use of Non-GAAP Financial Measures, page 22 (the
numbered paragraphs correspond to the three bullet points on the 2nd
page of the Commission’s comment letter)

1.     Almost all
the interest payable by the ENS segment is payable to its parent, NWH.  The level of the debt to the parent reflects
the history of NWH’s financing of ENS and affects the value of the minority
interest in ENS only.   It has no
relation to the ENS’ performance and should be factored out.

The depreciation of equipment and amortization of
software development costs do not represent current, controllable cash
expenditures.  When the chief operating
decision maker

488 Madison Avenue •
New York, N.Y. 10022 • Phone (212) 736-1000 • (212) 478-7200

Fax (212) 478-7400 •
Email: thefirm@hahnhessen.com

July 25, 2005

evaluates ENS’ performance in order to make decisions regarding the
allocation of resources and to assess ENS’ debt capacity and ability to service
its debt, ongoing revenues and current, controllable cash expenditures are the
primary items reviewed.  Depreciation and
amortization reflect current, non-cash expenses for purchase decisions made up
to five years prior to the currently reported financials.  Given the fast pace of change in today’s
business environment, a current review of these old decisions is irrelevant to
making current resource allocation decisions.
For these same reasons, this non-GAAP measure is useful for NWH’s
investors to evaluate ENS’ performance.

2.     We believe
that our non-GAAP measure is a measure of liquidity. It is appropriate to
reconcile our non-GAAP measure to ENS’ segment net income in order to fully
disclose all income and expenses of ENS.
The only differences between ENS’ income from operations, as disclosed
in Note 7, and ENS’ EBITDA are net interest expense to third parties,
depreciation of equipment and amortization of software development costs.  We did not reconcile EBITDA to cash flow from
operations because the changes in current assets and liabilities have not been
significant and would not cause the chief operating decision maker to make
different decisions.

3.     In light
of the disclosure requirements of the referred Question 8, NWH has disclosed
the utility of the non-GAAP measure as a useful indicator of the entity’s
liquidity only.  We believe that our
historical disclosures along with the explanations above, which will be
incorporated into future filings, fully address the requirements of Question
8.  As a general matter, NWH has prepared
its disclosure of non-GAAP measures in accordance with your guidance.

Please contact the undersigned at (212) 478-7250 if
you have any comments regarding the foregoing or need additional information.

  Very truly yours,

  /s/ James Kardon

Enclosures

cc:                               Terrence
S. Cassidy

McGladrey Pullen LLP

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