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