POULTON & YORDAN ATTORNEYS AT LAW ___________________________________________________________________________ RICHARD T. LUDLOW November 8, 2006 Jim B. Rosenberg Senior Assistant Chief Accountant United States Securities and Exchange Commission Washington, D.C. 20549 Re: Pacific Health Care Organization, Inc. Form 10-KSB/A for the Fiscal Year Ended December 31, 2005 Filed on May 17, 2002 Form 10-QSB for the Quarter Ended June 30, 2006 Filed on August 14, 2006 File No.: 000-50009 Dear Mr. Rosenberg: This letter is written in response to a Staff comment letter dated October 23, 2006 from your office addressed to Pacific Health Care Organization, Inc. As I explained to Frank Wyman of your office, the Company has not yet completed its responses to the comment letter and requests additional time to respond. The Company anticipates that it will file its responses to the comment letter by November 17, 2006. If you have any questions, or if this is unacceptable to the Staff, please contact me directly. Very truly yours, POULTON & YORDAN Richard T. Ludlow Attorney at Law