SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

August 22, 2005

Mr. Thomas Axmacher
Chief Financial Officer
Curative Health Services, Inc.
150 Motor Parkway
Hauppauge, NY  11788

Re:	Curative Health Services, Inc
	Form 10-K for the fiscal year ended December 31, 2004
	File No. 000-50371

Dear Mr. Axmacher:

      We have reviewed your filing and have the following comment.
We have limited our review of your filing to those issues we have
addressed in our comment.  In our comment we ask you to provide us
with information so we may better understand your disclosure.
After
reviewing this information, we may 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 10-K for fiscal year ended December 31, 2004 filed March 16
2005

Critical Accounting Policies and Estimates, page 25

1.  Please provide to us the following information:

a. For each period presented, quantify 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.
b. In a comparative tabular format, please provide 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.  Please 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, confirm that fact for us and clarify how this
affects your ability to estimate your allowance for bad debts.
c. 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, tell us why this
classification
is appropriate, and tell us the historical percentage of amounts
that
get reclassified into self-pay.
d. Tell us why you do not believe that the above information
should
be disclosed in your filing.

      Please respond to this comment within 10 business days of
the
date of this letter or tell us when you will provide us with a
response.  Please furnish a letter that keys your responses to our
comment and provides any requested information.  Detailed letters
greatly facilitate our review.  You should file the letter on
EDGAR
under the form type label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing include 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 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 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 Christine Allen, Staff Accountant, at (202)
551-3652 or Kevin Woody, Branch Chief, at (202) 551-3629 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. Thomas Axmacher
Curative Health Services, Inc
August 22, 2005
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