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<TYPE>LETTER
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<FILENAME>upload.txt
<DESCRIPTION>ITEM 4 8-K FILED 11/12/04 COMMENT LETTER DATED 12/1/04; WALSH
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Mail Stop 04-06

December 1, 2004

Philip Ranger
Chief Financial Officer
VantageMed Corporation
3017 Kilgore Road, Suite 180
Rancho Cordova, California 95670
(916) 638-4744

Re:   	VantageMed Corporation
Form 8-K filed November 12, 2004
File No. 000-29367

Dear Mr. Ranger:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation
as to why our comments are inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  After
reviewing this information, we may or may not raise additional
comments.

Please understand that the purpose of our review process is to assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing.  We look
forward to working with you in these respects.  We welcome any
questions you may have about our comments or on any other aspect of
our review.  Feel free to call us at the telephone numbers listed at
the end of this letter.

Form 8-K, filed November 12, 2004
1. Revise the disclosure regarding disagreements with your former
accountants to specifically include the two most recent fiscal years,
in addition to the subsequent interim period through the date of
resignation.  Supplementally, explain the circumstances in which you
dismissed Grant Thorton.  Refer to Item 304(a)(1)(iv)(A) of
Regulation S-B.
2. The disclosure in the first paragraph indicates that your new
accountants were retained on November 8, 2004.  Accordingly, revise
the disclosure regarding consultation with Hurley & Company to also
specifically include the subsequent interim period through November
8, 2004.  Refer to Item 304(a)(2) of Regulation S-B.
3. Revise your filing to include, as Exhibit 16, an updated letter
from your former accountant indicating whether or not they agree with
the statements made by you in your amended Form 8-K.  Refer to Item
304(a)(3) of Regulation S-B.

General

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to be
certain that they have provided all information investors require for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comment, please provide, in
writing, a statement from the company acknowledging that:

* The company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* Staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action with
respect to the filing; and

* The company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

Please file your supplemental response and amendment via EDGAR in
response to these comments within 10 days of the date of this letter.
Please note that if you require longer than 10 days to respond, you
should contact the staff immediately to request additional time.  Any
questions regarding the above should be directed to me at (202) 942-
1822, or in my absence, to Robert Benton at (202) 942-1811.

Sincerely,

Melissa Walsh
Staff Accountant

VantageMed Corporation
December 1, 2004
Page 2

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