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MedCath Corporation

October 18, 2005

VIA EDGAR

Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

Division of Corporation Finance

United States Securities and Exchange Commission

450 Fifth Street, NW

Washington DC 20549

    Re:

    MedCath Corporation Comment Letter Dated August 4, 2005

    File No. 0-33009

Dear Mr. Rosenberg:

MedCath Corporation (the “Company” or “MedCath”), submitted responses on August 18, 2005 (the
“Response Letter”) to your comment letter dated August 4, 2005 (the “Comment Letter”) pertaining to
our Annual Report on Form 10-K for the year ended September 30, 2004 and our Form 10-Q for the
period ended March 31, 2005. As requested in a phone conversation with Ms. Sasha Parikh,
Securities and Exchange Commission Staff Accountant, on October 11, 2005, MedCath is hereby
submitting the following additional information related to such responses.

In providing this additional information, we acknowledge that:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in the
filings;

    •

    staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filings; 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 question 2.c. of the Comment Letter, you requested that, for each period presented, we quantify
and provide the amount of changes in estimates of prior period contractual adjustments that we
recorded during the current period. In the Response Letter and in our conversation with Ms.
Parikh, we indicated that due to limitations in our patient accounting system, we could not
quantify such amounts; however, we did not expect the adjustments to be material to historical
interim or annual periods based on our payor mix and the controls in place to review contractuals.
We support this assertion in consideration of the following:

    •

    The majority of our contractual adjustments are system-generated at the time of billing
based on either government fee schedules or fee schedules contained in our managed care
agreements with various insurance plans. Accounts discounted in this manner would not
normally be subject to subsequent contractual adjustments except for denials, short
payments or other subsequent activity

10720
Sikes Place / Suite 300 / Charlotte, NC 28277 / (704) 708-6600 / Fax
(704) 708-5035

Mr. Jim B. Rosenberg

Securities and Exchange Commission

Page 2

    among these payors, all of which are closely reviewed as part of our accounting business
office processes, allowing for adjustments in the same period such new information arises.

    •

    As noted in 2.a. of the Response Letter, contractual adjustments on other accounts are
manually recognized at the time of billing using historical trends and other current
information on payors, account-type and other known factors relevant to estimating the net
realizable amount of these patient accounts. These estimates are adjusted at least
quarterly, if not monthly, and as account payment and collection activity occurs.

    •

    As noted in 4.b. of the Response Letter, our day’s sales outstanding ranged from 54 to
59 days for each of the three years ended September 30, 2004, which means on average we do
not have a significant amount of accounts receivable extending beyond 90 days to result in
material out-of-period adjustments.

    •

    Individual patient account analysis, combined with some historical trend analysis, is
performed and reviewed by management at least quarterly, if not monthly, to assess the need
for and the materiality of the contractual adjustments. Materiality is assessed in
relation to reporting unit and consolidated operating income as well as in consideration of
consolidated net income for the applicable period.

In questions 2, 3 and 4, you requested additional information in disclosure type format related to
our critical accounting policies surrounding revenue recognition, allowance for doubtful accounts
and liquidity and capital. Please be advised that in future filings
of our reports on Form 10-K and
Form 10-Q we intend to expand our applicable disclosures to incorporate the items included in our
responses.

We trust that you find the foregoing responsive to the staff’s comments. Should you have any
additional questions or require any additional information, please do not hesitate to contact me at
(704) 708-6610.

Sincerely,

/s/ JAMES E. HARRIS

James E. Harris

Executive Vice-President and

Chief Financial Officer