Mail Stop 3561
							December 13, 2005


Mr. John H. Treglia
President, Chief Executive Officer, Secretary and Director
Comprehensive Healthcare Solutions, Inc.
45 Ludlow Street, Suite 602
Yonkers, New York 10705

		RE:	Comprehensive Healthcare Solutions, Inc.
			Form 10-K/A for the fiscal year ended October 2,
2004
			Filed March 30, 2005
			File No. 033-08955
			Form 10-QSB/A for the period ended May 31, 2004
			Filed April 1, 2005
			Form 10-QSB/A for the period ended August 31, 2004
			Filed April 4, 2005
			Form 10-QSB/A for the period ended November 30,
2004
			Filed April 4, 2005

Dear Mr. Treglia:

	We have reviewed the responses in your letter dated October
14,
2005 and have the following additional comments.  Please be as
detailed as necessary in your explanation so we may better
understand
your disclosure.  After reviewing this information, we may or may
not
raise additional comments.

	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 the letter.







General

1. Your Form 10-KSB for the period ending February 28, 2005 and
subsequent filings will be subject to review after you adequately
respond to our comments.  Please ensure that all of our comments
have
been addressed in these subsequent filings or that you revise your
filings accordingly.

2. Please submit a complete version of your October 14, 2005
response
letter via EDGAR as a CORRES file.  The submission should include
detailed explanations as to how you plan to revise your periodic
filings or reference to attachments that include your proposed
amendments.  For example, your proposed amendments were provided
to
the SEC in paper form but were not submitted via EDGAR.  Absent
the
detailed proposed amended language, your stand alone responses do
not
adequately address our comment letter dated May 5, 2005.  Further,
you have not included supplemental supporting schedules in all
cases
in which you refer to them in your response.  For example, your
response to comment 20 from our comment letter dated May 5, 2005
states that the supporting cash flow schedule was attached, but
the
schedule is not included in your response.  Please attach this
supporting schedule and any other supplemental schedules you
reference in your October 14, 2005 response letter to be uploaded
to
EDGAR.

Proposed Form 10-K Amendment No. 3 for the fiscal year ended
February
29, 2004

General

3. Please take into consideration all of the following comments on
your Form 10-K, as applicable, when you revise your Forms 10-Q/A.

4. At the beginning of your amended filings please provide a
detailed
summary of the changes made to the filing in order to permit a
reader
to understand the changes made.

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Results of Operations, page 32

5. Your amended Form 10-K should provide discussion on all periods
presented in your financial statements.  The period ended February
28, 2002 should therefore be discussed.  Please revise.  See Item
303
of Regulation S-K.

6. We note your response to comment 6 from our comment letter
dated
May 5, 2005.  In your response you state that net sales and gross
margin attributable to hearing aid sales are not material.
Throughout the filing you refer to your sales of hearing aids.
For
example on page 29 you disclose that you are "in the business of
distributing and dispensing custom hearing aids."  On page F-10
where
you are describing your Company you disclose that you are "in the
business of selling and distributing hearing aids and providing
the
related audiological services."  Your results of operations
section
should provide an understanding of your results of operations.
Given
your disclosures throughout the filing that you sell and
distribute
hearing aids it is necessary that you disclose to what your
revenues
relate and why there have been changes in revenues from year to
year.
Please revise.  Please also revise to discuss your gross margins.
This discussion may require that you disclose the nature of the
expenses classified as cost of sales and the nature of the
expenses
classified as selling, general and administrative.  See Item 303
of
Regulation S-K.

7. We note your response to comment 7 from our comment letter
dated
May 5, 2005.  In your response you state that selling, general and
administrative expenses increased as "a result of an increase in
allowance for doubtful accounts and consulting fees."  Your
revised
disclosure should quantify each contributing factor and discuss
the
underlying reasons why the expenses increased.  See Item 303 of
Regulation S-K.  Please revise.  In addition, on page F-11 of your
proposed amendment you disclose that there was no allowance as
there
have been no bad debts.  Your consolidated statements of cash
flows
include a line item "provision for bad debt" for $22,500.  Please
revise for consistency.

Liquidity and Capital Resources, page 24

8. We note your response to comment 8 from our comment letter
dated
May 5, 2005.  Please revise to discuss material changes between
periods in your cash flows from operating, investing, and
financing
activities.  Refer to SEC Release No. 33-8350 and Item 303 of
Regulation S-K.

Item 8. Financial Statements and Supplementary Data

General

9. On January 25, 2002 you effected a reverse acquisition
acquiring
all of the issued and outstanding capital stock of Accutone, Inc.
As
Accutone, Inc. is the accounting acquiror financial information
for
Accutone, Inc. is required to be presented for all periods prior
to
January 25, 2002 with no lapse in audited periods for all periods
required to be presented.

General

10. We note your response to comment 9 from our letter dated May
5,
2005.  You have made changes to the financial statements that were
previously issued.  Please revise to provide all disclosures
required
by APB 20.  In particular, you should ensure that you disclose the
previously filed amounts, changes made and restated amounts for
each
financial statement line item affected.  Each adjustment should be
explained.  This includes adjustments that were included in
previously amended year end February 29, 2004 Forms 10-K and
adjustments to be included in your Form 10-K Amendment 4.
Additionally, on the face of each of the financial statements and
footnotes that are affected by the restatement, please clearly
label
the headings and applicable periods as restated.  Finally, as
stated
in AU 561.06a, your auditors should refer to the restatement note
describing the revisions in their auditors` report.

11. We note your response to comment 9 from our letter dated May
5,
2005.  In the response you state that bad debt expense of $22,500
was
recorded to increase the allowance for doubtful accounts on the
balance sheet.  This adjustment was made to a previously filed
Form
10-K.  On page F-11 of your proposed revision you state that there
was no accounts receivable allowance.  Please revise or advise.

Report of Independent Public Accounting Firm

12. We note your response to comment 10 from our letter dated May
5,
2005.  Given the comment above it appears that you need to revise
your financial statements to include the activity of Accutone,
Inc.
for all periods required to be presented prior to January 25,
2002.
The audit opinion or audit opinions in your filing must cover the
entire year ended February 28, 2002.  Please revise.










Report of Independent Public Accounting Firm

13. We note your response to comment 11 from our letter dated May
5,
2005.  You have not addressed our concerns.  We understand that
there
is no requirement stipulating that the public accounting firm of
an
issuer be located in the same state as the issuer.  Please have
your
accountants confirm to us that they are registered to practice in
New
York, or confirm that no such registration is necessary.  If your
accountants are registered in New York, please have them provide
us
with their license number.

Consolidated Statements of Operations, page F-4

14. We note your response to comment 12 from our letter dated May
5,
2005.  Please tell us your total hearing aid revenues and gross
margins for all periods presented.  In this regard if income is
derived from more than one of the subcaptions described under Rule
5-
03.1 of Regulation S-X, each class which is more than 10 percent
of
the sum of the items must be separately disclosed.

15. Please tell us how you computed your weighted average common
shares outstanding with reference to authoritative guidance.  The
weighted average common shares outstanding does not appear
consistent
with your consolidated statements of stockholders` equity.  Please
revise.  Please also revise subsequent Forms 10-Q/A, if
applicable.

Consolidated Statements of Stockholders` Equity, page F-5

16. We note your response to comment 15 from our letter dated May
5,
2005.  Your response states that you will present the subscription
receivable as a separate line item in stockholders` equity as the
amount is receivable from officers or directors.  We assume that
the
stock was issued since there was a receivable recorded.  If the
stock
was issued it should be recorded in the same line item as issued
and
outstanding common stock rather than having a separate line item
within stockholders` equity that offsets the subscription
receivable.
Your balance sheet and statement of stockholders` equity for the
year
ended February 28, 2003 should also be adjusted.  Please revise to
disclose the nature of the transaction in the notes to the
financial
statements.  Refer to EITF 85-1 and SAB Topic 4E.

17. We note your response to comment 16 from our letter dated May
5,
2005.  In fiscal 2003 and fiscal 2004 you issued shares in private
placement sales at $0.21 and $0.25 per share.  Your valuation of
shares issued in fiscal 2004 for the consultant agreement was
$0.26
per share.  Your valuation of shares issued for executive
compensation in fiscal 2003 and 2004 was significantly lower at
$0.06
- $0.07 per share.  In your response you state that the stock
issued
as executive compensation was significantly lower than market
value
due to the restrictive nature of the stock.  Please tell us how
the
shares were valued, why it was determined that such a significant
discount to the market value was required and your basis in GAAP
for
the significant discount.  Absent specific authoritative guidance
supporting your accounting you should value shares issued as
compensation at the quoted market price on the date of the
transaction without discount.

Consolidated Statements of Cash Flows, page F-5

18. We note your response to comments 17, 18, 19 and 20 from our
letter dated May 5, 2005.  Please tell us with reference to
authoritative literature how you determined that the following
line
items are correctly reflected in your statements of cash flows,
including how your classification as operating, investing or
financing is supported by SFAS 95:
* Deferred stock-based consulting,
* Common stock issued upon conversion of debt, and
* Issue of stock for reorganization, acquisitions and operations,
net.
Please revise, where necessary.  In addition, please provide a
supporting schedule to your revised consolidated statements of
cash
flows.  The schedule should include a reconciliation to applicable
consolidated balance sheets.

Notes to Consolidated Financial Statements, page F-7

Note 1. Reorganization, page F-7

Basis of Presentation and Going Concern, page F-7

19. We note your response to comment 22 from our letter dated May
5,
2005; however, it appears that your proposed Form 10-K amendment 4
has not been revised as your response indicates.  The comment is
therefore repeated:

You refer to SFAS 7.  SFAS 7 refers to the accounting and
disclosure
requirements of developmental stage enterprises.  Do you consider
yourself a developmental stage enterprise in accordance with SFAS
7?
If so, it does not appear you have followed the accounting and
disclosure requirements of SFAS 7.  Please explain and revise.

20. We note your response to comment 23 from our letter dated May
5,
2005; however, it appears that your proposed Form 10-K amendment 4
has not been revised as your response indicates.  The comment is
therefore repeated:

You disclose that you have not commenced planned principal
operations
and you have not generated revenues from prospective customers.
Based on review of this filing, neither of these statements
appears
accurate.  Please revise or advise.

Note 2. Summary of Significant Accounting Policies

Intangible Assets, page F-12

21. We note your response to comment 24 from our letter dated May
5,
2005.  In your response you state that the covenant not to compete
is
still in effect.  The fact that a covenant not to compete is still
in
effect does not alone support its lack of impairment.  You also
did
not attach support for your customer list impairment analysis as
you
state you did.  The previous comment is therefore repeated:

Please provide your fiscal 2004 impairment test performed on your
intangible assets.  Please provide support for your assumptions.
In
light of your unfavorable operating history, negative cash flows
and
weak liquidity position, it is unclear how you support
recoverability
of the assets.

Impairment of Long-Lived Assets, page F-13

22. We note your response to comment 26 from our letter dated May
5,
2005; however, it appears that your proposed Form 10-K amendment 4
has not been revised as your response indicates and you have not
provided your impairment analysis as requested.  A portion of the
previous comment is therefore repeated:

SFAS 121 was superseded by SFAS 144.  SFAS 144 was effective for
financial statements issued for fiscal years beginning after
December
15, 2001 and interim periods within those fiscal years.  Please
revise your disclosure and also revise the impairment testing
performed, if needed.  Please provide your impairment analysis in
accordance with SFAS 144.  Please provide support for your
assumptions.




Note 5. Property and Equipment, page F-15

23. We note your response to comment 28 from our letter dated May
5,
2005.  In your proposed response you disclose that your leasehold
improvements have an estimated useful life of thirty-nine years.
Leasehold improvements should be amortized over the remaining
lease
term or the useful life of the leasehold or leasehold
improvements,
whichever is shorter.  For this purpose, the lease term should be
consistent with the lease term used to classify the lease as an
operating or a capital/finance lease.  Please revise or advise.
As
requested in the previous comment please also revise to disclose
the
depreciation expense for the periods presented.  Refer to APB 12.

Item 9A. Controls and Procedures, page 34

24. We note your response to comments 29, 30 and 31 from our
letter
dated May 5, 2005 as well as your proposed revision to Item 9A.
Given your restatement of the financial statements please revise
to
disclose in detail why each restatement item did not affect your
conclusion that disclosure controls and procedures are effective
at
the reasonable assurance level.

25. We note your response to comment 32 from our letter dated May
5,
2005 as well as your proposed revision to Item 9A.  Item 308(c) of
Regulation S-K requires that you disclose any change in your
internal
control over financial reporting identified that occurred during
your
last fiscal quarter (your fourth fiscal quarter in the case of an
annual report) not "subsequent to the Evaluation Date."  Please
revise.

Item 14. Principal Accounting Fees and Services, page 39

26. We note your response to comment 33 from our letter dated May
5,
2005; however, it does not appear that your proposed revision
addressed our comment.  The comment is therefore repeated:

Please revise your disclosure to include the aggregate audit and
tax
fees billed each of the last two fiscal years.  In this regard we
noticed that it does not appear that the audit fees section
includes
billings from Jewett, Schwartz & Associates.




Exhibit 31

27. We note your response to comment 35 from our letter dated May
5,
2005; however, you did not provide a proposed revision for our
review.  The comment is therefore repeated:

Please revise to remove reference to yourself as a small business
issuer.  This comment applies to subsequent Forms 10-Q as well.

Proposed Form 10-QSB Amendment No. 3 for the period ended May 31,
2004

Item 1. Financial Statements, page 2

Condensed Consolidated Statements of Cash Flows, page F-4

28. We note your response to comment 38 from our letter dated May
5,
2005.  On March 1, 2004 you acquired Comprehensive Network
Solutions.
Consideration included 250,000 restricted shares and $60,000.
Cash
used in investing activities should include cash paid.  Please
tell
us why your "purchases of property and equipment" totals only
$6,166.
Please revise, if necessary.  Stock issued to complete an
acquisition
should be clearly disclosed as non-cash investing activities.  On
page 4 you disclose that you issued restricted common stock for
the
acquisition of Comprehensive Network Solutions, Inc. totaling
$405,050 however in your non-cash investing and financing
activities
section of the statements of cash flows you disclose only $250,000
related to the acquisitions.  Please revise and advise.  Refer to
SFAS 95.

Notes to Condensed Consolidated Financial Statements, page F-5

Note 1. Organization, page F-5

29. We note your response to comment 39 from our letter dated May
5,
2005.  SFAS 141 requires detailed disclosures in both interim and
year-end financial statements.  Your disclosure in your Form 8-K
does
not satisfy the SFAS 141 disclosure requirements.  Please revise
to
disclose the information required by paragraphs 51-58 of SFAS 141
in
this filing and subsequent filings.

30. In your proposed revision you disclose that February 28, 2004
was
the effective date of the Stock Purchase Agreement with
Comprehensive
Network Solutions, Inc.  The purchase was recorded as of March 1,
2004, the first day of a new reporting year.  Please revise or
advise.

Item 2. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Liquidity and Capital Resources, page 4

31. We note your response to comment 40 from our letter dated May
5,
2005 and your proposed revision.  Your response does not
adequately
address our comment.  The comment is therefore repeated:

Please ensure you provide a detailed discussion with reference to
authoritative literature.  You state that you issued 250,000
shares
of restricted common stock for the March 1, 2004 acquisition of
Comprehensive Network Solutions, Inc. totaling $405,050.  This
equals
$1.62 per share.  You state that you received proceeds from the
sale
of restricted common stock in the amount of $163,300.  It appears
that these proceeds were received for the issuance of
approximately
482,000 shares which results in a price per share of approximately
$0.35.  You also state that you satisfied a $25,000 liability
through
the issuance of 25,000 shares.  This equals $1.00 per share.
Please
explain the variations in share prices for these transactions and
clarify if the transactions were with related parties.  If
applicable, please describe any intervening events which occurred
between the sale dates, liability settlement date, and the date of
the acquisition.  Please explain how you valued Comprehensive
Network
Solutions, Inc.`s net assets with reference to authoritative
guidance.  Please explain your consideration of the then current
OTC
share trading prices at the date of each of the referenced
transactions.

32. Please ensure that all amounts in your proposed amendments
agree
to your financial statements.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a supplemental response letter that keys your
responses to our comments.  Detailed supplemental response letters
greatly facilitate our review.  Please file your supplemental
response letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

		If you have any questions regarding these comments,
please
direct them to Adam Phippen, Staff Accountant, at (202) 551-3336.
Any other questions may be directed to me at (202) 551-3843.

							Sincerely,



							George F. Ohsiek, Jr.
							Branch Chief

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Mr. John H. Treglia
Comprehensive Healthcare Solutions, Inc.
December 13, 2005
Page 1