SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

August 4, 2005

Mr. John T. Casey
Chairman, CEO and Director
MedCath Corporation
10720 Sikes Place
Charlotte, NC 28277

      Re:	MedCath Corporation
		Form 10-K for Fiscal Year Ended September 30, 2004
	           Filed December 14, 2004
		File No.  0-33009

Dear Mr. Casey:

      We have limited our review of your filing to those issues we
have addressed in our comments.  In our comments, we ask you to
provide us with information so we may better understand your
disclosure.

	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 10-K for the year ended September 30, 2004

Item 6. Selected Financial Data, page 25

1. We noted that you have disclosed Adjusted EBITDA and Adjusted
EBITDA, before pre-opening expenses and that you consider this a
financial performance measure.  Please tell us how you concluded
that
these non-GAAP measures are useful to investors and appropriate
under
item 10(e) of Regulation S-K.  Please refer to Questions 8 and 9
of
Frequently Asked Questions Regarding the Use of non-GAAP Financial
Measures found on our website at
www.sec.gov/divisions/corpfin/faqs/nongaapfaq.htm.

Management`s Discussion and Analysis

Critical Accounting Policies

Revenue Recognition, page 30

2. Please provide us the following information in disclosure-type
format to help us evaluate the adequacy of your disclosure:
a) State if your billing system generates contractual adjustments
based on fee schedules for the patient`s insurance plan for each
patient encounter or if an estimate of contractual allowances is
made.  If an estimate is made, state what factors are considered
in
determining the estimate.
b) Provide your policy for collecting co-payments.
c) For each period presented, quantify and provide the amount of
changes in estimates of prior period contractual adjustments that
you
recorded during the current period. For example for 2004, this
amount
would represent the amount of the difference between estimates of
contractual adjustments for services provided in 2003 and the
amount
of the new estimate or settlement amount that was recorded during
2004.
d) Quantify and provide the reasonably possible effects that a
change
in estimate of unsettled amounts from 3rd party payors as of the
latest balance sheet date could have on financial position and
operations.

Allowance for Doubtful Accounts, page 31

3. Please provide us the following information in disclosure-type
format to help us evaluate the adequacy of your disclosure:
a) Provide 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 information 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, provide that fact
and
clarify how this affects your ability to estimate your allowance
for
bad debts.

b) If you have amounts that are pending approval from third party
payors (i.e. Medicaid Pending), please provide the balances of
such
amounts, where they have been classified in your aging buckets,
and
what payor classification they have been grouped with.  If amounts
are classified outside of self-pay, explain why this
classification
is appropriate, and provide the historical percentage of amounts
that
get reclassified into self-pay.

Liquidity and Capital Resources, page 44

4. Please provide us the following information in disclosure-type
format to help us evaluate the adequacy of your disclosure:

a) State the steps you take in collecting accounts receivable.
Provide your policy with respect to determining when a receivable
is
recorded as a bad debt and when a write off is recorded.  Clarify
the
threshold (amount and age) for account balance write-offs.

b) Provide the day`s sales outstanding for each period presented.
Disclose the reasons for significant changes from the prior
period.

Form 10Q for the period ended March 31, 2005

Notes to the Consolidated Financial Statements

3. Discontinued Operations, page 8

5. Please tell us why you allocated $4.9 million of goodwill to
the
Heart Hospital of Milwaukee in the divesture entry when it was an
internally developed facility opened in October of 2003.
Paragraph
39 of FAS 142 would appear to indicate that allocation be made
only
to the extent the entity sold realized benefits of acquired
goodwill.

*    *    *    *

      Please provide us the supplemental information requested
within
10 business days of the date of this letter or tell us when you
will
provide a response prior to the expiration of the 10-day period.
Please furnish a letter with your supplemental responses that keys
your responses to our comments. Detailed letters greatly
facilitate
our review.  You should file the letter on EDGAR under the form
type
label CORRESP.  Please understand that we may have additional
comments after reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 comments, please
provide,
in your letter, 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.

      You may contact Sasha Parikh, Staff Accountant, at (202)
551-
3627 or Joel Parker, Accounting Branch Chief, at (202) 551-3651 if
you have questions regarding the comments. In this regard, do not
hesitate to contact me, at (202) 551-3679.

							Sincerely,

							Jim B. Rosenberg
							Senior Assistant Chief
Accountant
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Mr. John T. Casey
MedCath Corporation
Page 4

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