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      FPIC Correspondence December 2005

    Kim
      D.
      Thorpe

    Chief
      Financial Officer

    December
      28, 2005

    Mr. Jim
      B. Rosenberg

    Senior
      Assistant Chief Accountant

    United
      States Securities and Exchange Commission

    Division
      of Corporate Finance

    Washington,
      D.C. 20549

    Re:  FPIC
      Insurance Group, Inc.

        Annual
      Report
      on Form 10-K for the Fiscal Year Ended December 31, 2004

        Filed
      March
      15, 2005

        Commission
      File No. 001-11983

    Dear
      Mr.
      Rosenberg:

    We
      have
      reviewed your letter dated December 13, 2005 and the comments contained therein
      with respect to the Annual Report on Form 10-K for the fiscal year ended
      December 31, 2004 (“2004 Form 10-K”) of FPIC Insurance Group, Inc. (the
“Company”) filed with the United States Securities and Exchange Commission (the
“Commission”) on March 15, 2005. As requested, this letter provides additional
      information regarding the disclosure topics upon which the Commission has
      commented. For convenience of reference, our responses are accompanied by a
      restatement of the Commission’s comments.

    Form
      10-K for the Fiscal Year Ended December 31, 2004

    Management’s
      Discussion and Analysis of Financial Condition and Results of Operations for
      the
      year ended December 31, 2004

    Liability
      for Losses and Loss Adjustment Expenses (“LAE”), page
      17

    Comment
      No. 1:

    We
      note your expanded disclosure in response to comment number 3 in our comment
      letter dated July 31, 2003. Please provide us the following, in disclosure-type
      format:

            ·

              More
                detail regarding the specific actuarial techniques and assumptions
                you use
                when estimating the liability for losses and LAE. Specifically address
                the
                factors that led management to determine the best estimate of loss
                reserves within your reserve
                range.

    225
      Water
      Street, Suite 1400 • Jacksonville, Florida 32202

    (800)
      221-2101 • (904) 360-3640 • Fax (904) 475-1159

    kthorpe@fpic.com

        Mr. Jim
          B. Rosenberg

        United
          States Securities and Exchange Commission

        December
          28, 2005

        Page
          2

            ·

              Please
                provide quantified and narrative analyses of the impact that reasonably
                likely changes in one or more of your key assumptions that materially
                affect the reserve balance would have on reported results, financial
                position and liquidity. We note that you provide an analysis around
                the
                total carried reserve balance but do not provide quantitative and
                narrative analyses around the key assumptions that affect the reserve
                balance.

            ·

              In
                addition, because IBNR reserve estimates are more imprecise, please
                provide the amount of IBNR separately from case reserves for each
                line of
                business.

    Response
      to Comment No. 1:

    We
      provide substantial and meaningful disclosure regarding the liability for losses
      and loss adjustment expenses (“LAE”), also referred to as loss and LAE reserves,
      in our Item 7, Management’s Discussion and Analysis of Financial Condition and
      Results of Operations (“MD&A”), and in our Item 8, Financial Statements and
      Supplementary Data. The disclosures are intended to provide investors and other
      financial statement users with additional information necessary to understand
      our loss and LAE reserves and how management establishes such reserves. We
      continuously strive to improve our disclosures and believe that additional
      disclosure addressing the recommendations contained in the Commission’s comments
      would be helpful to readers of our financial statements. We intend, therefore,
      to incorporate as appropriate under the circumstances, disclosures along the
      lines of the matters presented below in our upcoming Annual Report on Form
      10-K
      for the fiscal year ending December 31, 2005, which we will file on or before
      March 16, 2006 (“2005 Form 10-K”).

    Actuarial
      Techniques Used in Establishing Loss and LAE Reserves

    Under
      the
      caption “Critical Accounting Policies and Estimates,” of the MD&A in our
      2004 Form 10-K, we summarized the process used to establish loss and LAE
      reserves. As discussed in this narrative, we set the reserves taking into
      account the results of the application of several different actuarial
      techniques, as well as other factors and assumptions, and utilized and
      integrated the calculations and analyses of an independent actuary.

    The
      primary actuarial methods applied in the process of estimating our loss and
      LAE
      reserves as of December 31, 2004, are listed below in disclosure-type format
      accompanied by a discussion further explaining why we use multiple methods.
      We
      will add similar disclosure to the caption, “Critical Accounting Policies and
      Estimates,” in our MD&A to be included in our 2005 Form
      10-K.

        Mr. Jim
          B. Rosenberg

        United
          States Securities and Exchange Commission

        December
          28, 2005

        Page
          3

    Supplemental
      Disclosure Regarding Actuarial Techniques in Disclosure-Type
      Format:

    The
      actuarial techniques we use that are material to our evaluation of reserves
      are
      the following:

            ·

              Loss
                Development Methods (Incurred and Paid
                Development)

            ·

              Frequency/Severity
                Methods

            ·

              Berquist-Sherman
                Case Reserve Adjustment Method

            ·

              Bornhuetter-Ferguson
                Expected Loss Projection Methods

            ·

              Backward
                Recursive Method

            ·

              ALAE
                Development Methods (Incurred and Paid
                Development)

    Each
      technique has inherent benefits and shortcomings (i.e., biases), particularly
      when applied to company-specific characteristics and trends. For example,
      certain methods (e.g., the Bornhuetter-Ferguson methods) are more relevant
      to
      immature accident years and other methods (e.g., the loss development methods)
      provide more meaningful information for years with a greater level of maturity.
      Because each method has its own set of attributes, we do not rely exclusively
      upon a single method. Various methods are evaluated for the different
      perspectives that each provides and management makes judgmental selections
      based
      on the results of all methods when applied to our historical experience and
      our
      expectations about future claim results and trends.

    --------------------------------------------

    Quantified
      and Narrative Analyses Regarding Key Reserve Assumptions

    As
      is
      also reflected under the caption, “Critical Accounting Policies and Estimates,”
of our MD&A in our 2004 Form 10-K, the important factors or assumptions
      implicit in our estimates that may have an impact on the adequacy of the
      reserves are as follows:

            ·

              Frequency
                and severity trends (number of claims per exposure and how much we
                will
                pay on average for each claim)

            ·

              Frequency
                of claims closed with indemnity payments (the percentage of claims
                reported that ultimately result in a loss payment versus those that
                are
                closed without a loss payment)

            ·

              The
                timing or pattern of future
                payments

            ·

              The
                amount of defense costs we will pay for each claim or group of
                claims

            ·

              Inflationary
                trends that are expected to bear on future loss and LAE
                payments

    Disclosure
      of the above-mentioned factors or assumptions in our 2004 Form 10-K is
      accompanied by further explanation of how they interrelate with the applications
      of the actuarial methods and the overall process used by management in
      developing its best estimate. In addition, the narrative disclosures
      accompanying the 10-year and three-year tabular presentations required by the
      1933 Act Industry Guide 6, which are included under the caption, “Management’s
      Discussion and Analysis of Financial Condition,” provide a comprehensive
      discussion of the factors underlying changes in our reserves.

          Mr. Jim
            B. Rosenberg

          United
            States Securities and Exchange Commission

          December
            28, 2005

          Page
            4

    As
      discussed in these disclosures, our carried reserves, net of reinsurance, at
      December 31, 2004, were approximately 6% higher than the point estimate of
      our
      independent actuary and within the upper end of the range. Our disclosure
      describes the significant factors resulting in management’s more conservative
      estimate, including the newness of tort reform measures passed in our largest
      market in 2003 and related state constitutional amendments passed in 2004,
      installation of a stricter claims defense philosophy beginning in 2001 and
      loss
      and LAE development experienced in certain accident years.

    With
      respect to the Commission’s comments regarding the provision of quantified and
      narrative analyses of the impact that reasonably likely changes in one or more
      key assumptions, we will add to or modify the disclosure regarding the key
      reserve factors and assumptions in our 2005 Form 10-K as follows:

    Supplemental
      Disclosure Regarding Sensitivity of Key Reserve Assumptions in Disclosure-Type
      Format:

    These
      factors can be impacted by internal events, such as changes in business mix
      or
      claims handling philosophy, and external events, such as changes in the legal
      or
      regulatory environment. For example, the removal or significant weakening of
      one
      or more of the tort reforms passed in our largest market, Florida, could result
      in an unexpected increase in claim frequency and/or severity. Determining
      whether such events are reasonably likely to occur and attempting to quantify
      the impact of an individual event are inherently difficult. We utilize our
      experience and judgment and consider these factors as well as historical
      experience and the results of applied actuarial techniques, when evaluating
      the
      adequacy of carried loss and LAE reserves.

    In
      considering the potential sensitivity of the factors and assumptions underlying
      management’s best estimate of loss and LAE reserves, it is also important to
      understand that the medical professional liability sector of the
      property-casualty insurance industry is characterized by a relatively small
      number of claims with a large average cost per claim. For example, in 2004,
      which we ended with 14,047 policyholders, we closed only 350 claims with an
      average indemnity payment (i.e., losses only) of $194,000. Given the magnitude
      of our reserves and these characteristics, even a relatively small change in
      the
      number of claims we expect to pay (i.e., frequency) or a relatively small
      percentage change in the average cost per claim (i.e., severity) may be expected
      to have a significant impact on our reserves and, correspondingly, the Company’s
      financial position and results of operations. This is the case for other key
      assumptions as well, such as the frequency of reported claims and incidents
      that
      will ultimately close with an indemnity payment versus those that will close
      without an indemnity payment.

    --------------------------------------------

    In
      our
      disclosure, we will continue to provide analysis and discussion of the
      significant factors considered in our reserving process. Given the
      characteristics of our business, we continue to believe that the analysis around
      the total carried reserve balance contained in our MD&A provides the most
      meaningful and appropriate presentation, in the least confusing and most
      straightforward terms, as to the impact of a change in loss and LAE reserve
      estimates. We will, however, add to the disclosure in our 2005 Form 10-K along
      the lines discussed above, and continue to consider the adequacy and
      appropriateness of our reserve disclosures and expand the discussion in future
      filings to address the impact on our reported results, financial condition
      and
      liquidity, as appropriate under the circumstances.

          Mr. Jim
            B. Rosenberg

          United
            States Securities and Exchange Commission

          December
            28, 2005

          Page
            5

    Components
      of Carried Reserves (Case Reserves and IBNR Reserves)

    The
      following table provides the components of carried reserves by line of business
      on both a gross basis and a net basis. IBNR reserves include a provision for
      the
      aggregate difference between individually estimated case reserves established
      by
      the claims department and the amounts for which they will be ultimately settled.
      We discuss this in further detail in our response to Comment No. 2.
      We
      will
      add this type of disclosure to future filings.

    Supplemental
      Disclosure of Components of Carried Reserves in Disclosure-Type
      Format:

    As
      of
      December 31, 2004, our liability for losses and LAE presented in the
      consolidated financial statements was comprised of the following components
      (Gross Basis). In the lower portion of this table, we also present such reserve
      components net of reinsurance (Net Basis).

                Case
                  Reserves

                IBNR
                  Reserves (including case reserve development)

                Total
                  Reserves

                GROSS
                  BASIS

                Professional
                  Liability

                $

                531,293

                79,259

                610,552

                Other
                  Lines

                $

                16,904

                7,662

                24,566

                Total
                  Gross Reserves

                $

                548,197

                86,921

                635,118

                NET
                  BASIS

                Professional
                  Liability

                $

                295,921

                3,421

                299,342

                Other
                  Lines

                $

                4,094

                (1,737

                )

                2,357

                Total
                  Net Reserves

                $

                300,015

                1,684

                301,699

    --------------------------------------------

    Comment
      No. 2:

    We
      refer