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ATTORNEYS

October 12, 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

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

  File
  No.: 000-26598

Greetings:

We are
in receipt of the Commission’s letter of comment, dated September 27,
2005, and, on behalf of NWH, Inc. (“NWH” or the “Company”), have the
responses set forth below.

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
chief operating decision maker (CODM) has historically reviewed operating
income to assess the performance of ENS and decide how to allocate resources of
the Company.  In the past, a portion of
ENS’ interest expense was largely attributable to loans and capital leases with
third parties.  May 2005 was the
first month in which all third party financing arrangements were repaid by ENS
(except for a loan to a former ENS shareholder which is subordinated to the
loan from NWH to ENS).  Therefore the
remaining interest expense is an intercompany cost whose terms and
enforceability are determined solely by the parent Company.  The table below shows the steady decline in
interest payable to third parties:

  Quarter Ended

  Dec-03

  Mar-04

  Jun-04

  Sep-04

  Dec-04

  Mar-05

  Jun-05

  Interest expense-NWH

  81,149

  80,267

  80,267

  81,149

  79,026

  30,923

  38,059

  Interest expense-related party

  2,823

  2,792

  2,792

  2,823

  2,823

  2,761

  (9,073

  )**

  Interest expense-other

  5,583

  5,417

  27,737

  237

  649

  332

  77

** Excess accrual
of interest to a former ENS shareholder was reversed in June 2005

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

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

In the
past, completion of large software projects and the write off of internally
developed software related to terminated contracts caused amortization to be
volatile and subject to closer scrutiny.
All such large software development projects have been completed and are
being amortized and the Company does not anticipate any significant write offs
in the foreseeable future.  Consequently,
depreciation and amortization expense has been more consistent over the past
year.  The table below shows the
historical changes in depreciation and amortization:

  Quarter
  Ended

  Dec-02

  Mar-03

  Jun-03

  Sep-03

  Dec-03

  Mar-04

  Jun-04

  Sep-04

  Dec-04

  Mar-05

  Jun-05

  Depreciation
  & amortization

  415,589

  275,636

  276,461

  271,867

  383,169

  386,954

  400,047

  414,293

  403,718

  424,965

  448,220

  change from prior
  quarter

  -34

  %

  0

  %

  -2

  %

  41

  %

  1

  %

  3

  %

  4

  %

  -3

  %

  5

  %

  5

  %

Due to
the decreased significance of interest expense and the normalization of
depreciation and amortization expense, the CODM now relies on net income (loss)
before taxes, depreciation, amortization, gain on security transactions,
dividend income and interest income and expense in order to assess the
performance of ENS and decide how to allocate resources.  The Company does not believe that the
disclosures in Management’s Discussion and Analysis of Financial Condition and
Results of Operations  and the footnotes,
taken as a whole, in previous filings are materially different from the revised
disclosures.  All relevant information
used by the CODM for decision making has been and continues to be available to
the public.  Consequently the Company
believes that the change in format of the segment footnote is not material,
and, accordingly, there would be no value to the investing public from a
restatement of any of the previous filings.
In addition, the cost to the Company’s stockholders of any restatement
would be substantial and disproportionate to the concerns raised in your
comments.

Because
of the recent change in how the CODM reviews the Company and our reflection of
the change in our current segment disclosures, we believe that our disclosure
controls and procedures are and have been effective as of each reporting period
affected by this change in segment disclosure.
The Company will elaborate on this change in its next Form 10-K
filed for the year ended October 31, 2005 in order to clarify the reason
for the change in our segment measure.

Please
contact the undersigned at (212) 478-7250 if you have any comments regarding
the foregoing or need additional information.
We would appreciate receiving any further comments at your earliest
convenience.

  Very truly
  yours,

  /s/ James Kardon

  James Kardon

Enclosures

  cc:

  Terrence S.
  Cassidy

  McGladrey Pullen
  LLP

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