CORRESP 1 filename1.txt PHC, INC. 200 Lake Street, Suite 102 Peabody, MA 01960 April 12, 2006 Securities and Exchange Commission Division of Corporation Finance Mail Stop 6010 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Jim B. Rosenberg Senior Assistant Chief Accountant RE: PHC, Inc. Form 10-K for Fiscal Year Ended June 30, 2005 Filed September 28, 2005 File No. 000-22916 Response dated March 20, 2006 Dear Mr. Rosenberg: As a result of my conversation with Todd Sherman of your office on April 11, 2006, I would like to clarify my responses of March 20, 2006 to state our intention to include in future filings: * additional disclosure regarding revenues in our "Description of Business" similar to that provided in our response to comment 1 of the above referenced letter; and, * additional disclosure regarding accounts receivable and contractual adjustments as part of our "Critical Accounting Policies" similar to that provided in our response to comment 2 of the above referenced letter. Please contact me with any additional comments you may have. Sincerely, PHC, Inc. /s/ Paula C. Wurts Paula C. Wurts Chief Financial Officer