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SEC RESPONSE LETTER

 November 1,
2005

 Via EDGAR

 United States Securities and Exchange Commission

Division of Corporation Finance

 100 First Street, N.E.

 Washington, D.C. 20549

Attn:
Jim B. Rosenberg, Senior Assistant Chief Accountant

Mail Stop 6010

Re:
Radiologix, Inc.

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

Filed March 15, 2005

File No. 001-15861

 Dear Mr. Rosenberg:

 The following are Radiologix, Inc.’s (the “Company’s”) supplemental responses to the comments of the staff of the Commission’s
Division of Corporation Finance in its letter to Michael N. Murdock, Senior Vice President and Chief Financial Officer of Radiologix, dated July 13, 2005, with respect to Radiologix’s 2004 Annual Report on Form 10-K. These supplemental
responses are a result of two phone conversations I had with Ms. Keira Ino of your office, in which Ms. Ino requested additional information on some of the Company’s initial responses.

 For convenience, the staff’s initial comments and the Company’s
initial responses are stated below in their entirety, in italics. The Commission’s supplemental comments are in bold. The Company’s supplemental responses are set out immediately thereafter.

1.
Initial Comment:

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 15

 Liquidity and Capital Resources, page 25

 It is unclear based on your discussion related to your operating cash
flows what resulted in the decrease in the current period. Please explain to us in greater detail the activities that generate and use cash in operations. Include which of these activities specifically caused the significant changes in the current
period. Please note that a reiteration of the cash flow statement is not sufficient to this end. Also include a discussion of what resulted in the significant changes to your days’ sales outstanding in accounts receivable between these periods.

 United States Securities and Exchange Commission

 Division of Corporation Finance

 November 1, 2005

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 2

 Initial Response:

 Our operating cash flows are primarily impacted by the amount of service fee revenue we generate and ultimately collect,
offset by the amount and timing of our payment obligations for resources used to generate service fee revenues, such as costs for payroll, supplies, equipment operating leases, equipment maintenance contracts, equipment repairs, utilities, facility
rent, marketing, interest and general and administrative costs.

 In 2004, the primary reasons for our decrease in operating cash flows relative to the comparable period in 2003 were: (1) higher costs of services in 2004 compared to 2003 resulting in a lower gross profit in 2004, as discussed on
pages 20 and 21 in Item 7, Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A) of our 2004 Form 10-K; (2) substantially higher corporate general and administrative costs as described on
page 21 in Item 7 in our 2004 MD&A of our 2004 Form 10-K; (3) higher estimated federal and state tax payments in 2004; and (4) higher payments made for federal income taxes and physician technical bonuses in 2003 compared to 2004
and 2002.

 Our days sales outstanding decreased as a
result of: (1) the $9.1 million charge we recorded in the 2004 fourth quarter, which increased contractual adjustments and correspondingly decreased service fee revenue and accounts receivable at December 31, 2004; and (2) our reduced
denial rates and overall improved collections in fiscal 2004.

 Supplemental Comment:

 Ms. Ino
requested that the above response be written in a format that could be included in Form 10-K filings.

 Supplemental Response:

 The following paragraphs would be included in future Form 10-K filings under the Management and Discussion and Analysis section entitled “Liquidity
and Capital Resources:”

 “Net cash flow from
operating activities for the year ended December 31, 2004 of $27.3 million decreased from $36.6 million for the same period in 2003. Our operating cash flows are primarily impacted by the amount of service fee revenue we generate and ultimately
collect, offset by the amount and timing of our payment obligations for resources used to generate service fee revenues, such as costs for payroll, supplies, equipment operating leases, equipment maintenance contracts, equipment repairs, utilities,
facility rent, marketing, interest and general and administrative costs.

 United States Securities and Exchange Commission

 Division of Corporation Finance

 November 1, 2005

  Page
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 In 2004, the primary reasons for our decrease in operating cash flows relative to the comparable
period in 2003 were (1) higher costs of services in 2004 compared to 2003 resulting in a lower gross profit in 2004, as discussed in the “Comparable results” section contained in Item 7, Management’s Discussion and Analysis
of Financial Condition and Results of Operations, (2) substantially higher corporate general and administrative costs (also described in the “Corporate results” section contained in Item 7), (3) higher estimated federal and
state tax payments in 2004 and (4) higher physician technical bonuses in 2003 compared to 2004 and 2002.

 Our days sales outstanding on accounts receivable decreased from 73 days at December 31, 2002 to 63 days at December 31, 2003 and to 48 days at
December 31, 2004. We calculate days sales outstanding by dividing accounts receivable, net of allowances, by the three-month average revenue per day. Our days sales outstanding decreased in 2004 as a result of (1) the $9.1 million charge
we recorded in the 2004 fourth quarter, which increased contractual adjustments and correspondingly decreased service fee revenue and accounts receivable at December 31, 2004 and (2) our reduced denial rates and overall improved
collections in fiscal 2004.”

2.
Initial Comment:

 Critical Accounting Policies, page 26

 Revenue Recognition, Contractual Allowances, and Allowances for Doubtful Accounts, page 26

 Please describe to us in greater detail the comprehensive
“retrospective collection analysis of [your] accounts receivable” that took place in the fourth quarter of 2004. Include a discussion of how this allowed you to feel comfortable with the amounts recorded as accounts receivable at year-end.
Also explain how you determined that the $9.1 million charge in the fourth quarter was appropriate.

 Initial Response:

 Prior to using the retrospective collection analysis model, the Company utilized a “Payment Versus Revenue” or “PVR” model and
aging reports to estimate collection rates in arriving at the estimated net realizable value for accounts receivable. The PVR model reflected gross charges and cash collections attributable to each month. Because the receipt of cash collections
typically trailed the timing of initial charges, we would compare revenue from the PVR model recorded 60 days earlier to the current cash collection month in an effort to better match charges to collections. We would also

 United States Securities and Exchange Commission

 Division of Corporation Finance

 November 1, 2005

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average this calculation over a six-month period to arrive at an estimated collection rate for the current period (i.e., we would compare six months of
collections to six months of revenue, with the revenue on a 60-day lag).

 In the summer of 2004, we began the development of a retrospective model to replace the PVR model. This development involved our collaboration with our revenue cycle IT vendor to (1) convert our major
subsidiaries to a single common billing system platform and (2) develop a program that matched cash collections to the original gross charges recorded in our billing system. We worked with our vendor and continued our implementation process
throughout the third and fourth quarters of 2004. We disclosed in our September 30, 2004 Form 10-Q on page 31, the following: “In the fourth quarter of 2004, we expect to finalize a retrospective collection analysis of accounts
receivable” (see the Revenue Recognition, Contractual Allowances and Allowances for Doubtful Accounts paragraph under the Critical Accounting Policies section on page 31 of our September 30, 2004 Form 10-Q).

 Management completed the final review of the retrospective model and the
results generated by this model subsequent to December 31, 2004, but prior to the finalization of our 2004 consolidated financial statements. This review involved the preparation of a retrospective report for each of our major subsidiaries. We
believe the retrospective methodology provides greater objective evidence with which to estimate the collectability of accounts receivable because it allows us to match cash collections to gross charges by month of service over at least an 18-month
period and consequently develop collection percentages and collection trends that are substantially complete. In other words, the retrospective analysis allows us a better method to track the run out of cash on a population of charges over an
extended period of time. Moreover, the retrospective analysis also allows us to better estimate how much we have left to collect on a receivable balance at any point in time and consequently assess the likelihood of collecting the remaining balance
given established collection trends.

 The $9.1 million
charge was appropriate in the fourth quarter of 2004 because the Company could not reasonably determine what periods the charge related to. The retrospective analysis, while providing us with a more accurate picture of the Company’s current
collection rates and accounts receivable, does not provide the necessary data to determine the correct collection rates for periods prior to 2003. We cannot compare the Company’s historical collection rates before 2003 with those as determined
by the retrospective analysis due to the Company’s legacy billing systems and accounting records. A comparison of the collection rates as determined by the retrospective analysis and the Company’s historical rates in 2003 and 2004 shows
that none of the $9.1 million charge relates to periods in those years. Because we cannot reasonably determine when the $9.1 million charge accrued (other than determining that the charge accrued sometime prior to 2003), we recorded the adjustment
in the fourth quarter of 2004, which was the closest period to when the charge was discovered.

 United States Securities and Exchange Commission

 Division of Corporation Finance

 November 1, 2005

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 Supplemental Comment:

 Ms. Ino requested more information on why the $9.1 million charge was a charge to contractual adjustments (reducing
service fee revenue) and not a provision for doubtful accounts.

 Supplemental Response:

 The $9.1 million charge
resulted from a new retrospective analysis that was completed in connection with the December 2004 year-end closing process. This analysis represented a change to our methodology for estimating the amount of net realizable revenues and net
realizable receivables (after contractual adjustments and allowances for bad debt). On the other hand, the provision for doubtful accounts is based on historical write-offs, which did not significantly change during this time period. Thus, based on
an comparison of the results of these two methodologies – the retrospective analysis and the historical write-off experience — we concluded that the $9.1 million charge was not due to any increase in bad debt, but was properly attributed
to contractual adjustments.

3.
Initial Comment:

 Please provide to us a discussion of the following items in a format that represents potential disclosure to be added in these areas in future Forms
10-K or identify for us in your current disclosure how these items are addressed:

 Disclose in a comparative tabular format, the payor mix concentrations and related aging of accounts receivable. The aging schedule may
be based on management’s own reporting criteria (i.e. unbilled, less than 30 days, 30 to 60 days etc.) or some other reasonable presentation. At a minimum, the disclosure should indicate the past due amounts and a breakdown by payor
classification (i.e. Medicare, Medicaid, Managed care and other, and Self-pay). We would expect Self-pay to be separately classified from any other grouping. If your billing system does not have the capacity to provide an aging schedule of your
receivables, disclose that fact and clarify how this affects your ability to estimate your allowance for bad debts.

 Initial Response:

 The table below reflects our consolidated gross accounts receivable (before any reduction for contractual allowances) aging report, which is used to
review accounts receivable aging patterns.

 United States Securities and Exchange Commission

 Division of Corporation Finance

 November 1, 2005

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Payor

Total

 0-30

 Days

31-60
Days

61-90
Days

91-120
Days

121-150
Days

151-180
Days

 >180

 Days

Medicare

20,136,246

9,094,149

4,665,621

1,343,859

916,123

617,563

422,285

3,076,646

Medicaid

5,922,365

1,277,235

1,250,995

869,931

605,174

368,395

296,823

1,253,812

Indemnity

3,735,177

1,147,880

941,452

455,350

321,571

171,592

114,906

582,426

Managed Care

40,285,983

17,466,945

8,995,201

3,112,589

2,135,424

1,264,522

841,583

6,469,719

Self Pay

13,709,030

1,381,837

2,366,044

2,335,793

2,113,913

1,649,004

1,334,750

2,527,689

Workers Comp

5,748,873

867,713

1,154,760

954,974

599,322

327,022

230,233

1,614,849

Other

3,803,494

784,599

419,768

595,901

400,306

265,684

107,821

1,229,415

TOTAL by PAYOR

93,341,168

32,020,358

19,793,841

9,668,397

7,091,833

4,663,782

3,348,401

16,754,556

Other subsidiary (1)

5,329,085

2,280,687

634,868

417,345

485,697

283,745

177,399

1,049,344

98,670,253

34,301,045

20,428,709

10,085,742

7,577,530

4,947,527

3,525,800

17,803,900

(1)
Aging by payor is not available

 Supplemental Comment:

 Ms. Ino requested a reconciliation of gross accounts receivable to accounts receivable, net of allowances.

 Supplemental Response:

 The reconciliation is as follows:

(In thousands)

 Gross accounts receivable per aging

$
98,670

 Accrued gross charges (1)

12,413

 Allowance for contractual adjustments

(58,901
)

 Allowance for doubtful accounts

(8,028
)

 Other

(43
)

 Net accounts receivable

$
44,197

(1)
Procedures have been completed but charges have not been entered into the billing system.

4.
Initial Comment:

 Disclose the timing of the “system driven” charges that result after the “communication cycle is completed and the receivable remains
uncollected.”

 Initial Response:

 We will disclose the following in future Form 10-K filings:

 “Once the communication cycle is complete,
respective patient charges are placed in a file in our billing system generally during the third week of every month. These charges are subject to review by our Reimbursement Operations department based on a nonstatistical sample pulled manually. At
month end, following this review, Reimbursement Operations

 United States Securities and Exchange Commission

 Division of Corporation Finance

 November 1, 2005

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authorizes this file of charges to be written off in the billing system and correspondingly sends the accounts to a collection agency.”

 Supplemental Comment:

 Ms. Ino asked what the “communication cycle” is.

 Supplemental Response:

 The “communication cycle” is a series of billing statements and
letters requesting payment. The statements and letters are normally sent to patients who are without health insurance or who owe us a co-payment or deductible after insurance has been paid. The letters are sent for up to 110 days and increase in
intensity and urgency as the receivable becomes more delinquent. If the receivable remains uncollected after this 110-day period, the communication cycle is complete and the re