SecProbe.io

November  21, 2012

Via E -mail
Michael J. West
President
Canfield Medical Supply, Inc.
4120 Boardman -Canfield Road
Canfield, Ohio 44406

Re: Canfield Medical Supply, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed November 9 , 2012
  File No. 333-182639

Dear Mr. West :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amen dment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

Management’s Discussion and Analy sis of Financial Condition an d Results of Operations, page
51
1. We note your revisions in response to comments 12 and 13 from our letter dated October
16, 2012, and we reissue the comment, in part.  Please expand your MD&A to add a
discussion of the key vari ables and other qualitative and quantitative factors on which the
company's executives focus in evaluating your financial condition and operating
performance.   For example, if management considers cost control as a measure of your
overall performance, you should identify this figure an indicator of your performance and
discuss changes in costs over the periods covered by the MD&A.

Michael J. West
Canfield Medical Supply, Inc.
November 21, 2012
Page 2

 Liquidity and Capital Resources, page 55

2. In order to provide an investor with a better understanding of the composition of your
accounts receivable balance, please revise to:

 Disclose in a comparative tabular format, 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.   At a minimum, the disclosur e should 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, disclose that fact and clarify how
this affects your ability to estimate your allowance for bad debts.

 If you have amounts that are pending approval from third party payors (i.e. Medicaid
Pending), please disclose 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 ap propriate, and disclose the historical percentage of amounts that get
reclassified into self -pay.

Strategy, page 52

3. We note your statements that “[w]e could generate up to approximately $25,000 in
additional revenue in the first 12 months after we star t selling …”  and “[w]e expect that
this webstore could generate approximately $25,000 in revenues in the first 12 months of
operation  ….”  The basis for factual assertions and for the company's or management's
belief in certain quantitative or qualitative statements must be clear from the text of the
prospectus  or provided supplementally to us .  Revise your disclosure to address our
concerns  or advise us supplementally as necessary.

4. We note your statement that “ while we are attempting to increase the perce ntage of
revenues from private insurers and others, we are continuing to increase our Medicare
sales as evidenced by the fact that we have submitted bits in four new Ohio markets ….”
Please revise your disclosure to clarify that submitting bids in four ne w Ohio markets will
not necessarily increase your Medicare sales if your bids are not successful.

Financial Statements

General

5. Please amend your filing to update your financial information as required by Rule 8 -08 of
Regulation S -X and provide a current  consent for any amendment over 30 days.

Michael J. West
Canfield Medical Supply, Inc.
November 21, 2012
Page 3

6. We note that you have restated your financial statements for all periods presented in the
filing.   Please amend to (i) prominently label your financial statements as restated and (ii)
provide disclosures required  by FASB ASC 250 -10-50.

Report of Independent Registered Public Accounting Firm, page F -2

7. Please obtain and file an updated audit report from your independent accountant that
provides an explanatory paragraph related to your restatement.   Refer to paragraph 9 of
PCAOB Auditing Standard No. 6.

8. In connection with the comment above, please advi se your independent accountant to
clarify for us why their opinion was not dual dated or re -dated as a result of the
restatement of your financial statements.   Refer to AU 530.

Statements of Operations, page F -5

9. We note your disclosure on page 61, stat ing that consulting revenue of $100,000 recorded
in 2010 was not related to your business nor performed on behalf of your business.   Such
services were independently performed by your CEO and CFO as officers of another
entity.   Please provide us with your basis for recognizing this amount as your revenue.   In
your response provide us with an analysis of the authoritative literature you used to
support your position.

Revenue Recognition, page F -7

10. We note your revisions in response to comment 20.   Please further expand your
accounting policy to clarify how you recognize revenue from the rental of durable home
medical equipment.

Exhibit Index

11. Please revise your exhibit index to reflect only the current version of your legality
opinion.

Legality Opinion

12. We note that counsel has not undertaken and does not intend to undertake any
independent investigation beyond the listed documents and records  or to verify the
adequacy of such documents .  Please note that counsel must examine those documents
which are necessary to the formulation of its opinion and may not assume the conclusion
that certain documents are adequate in the formulation of that opinion.  Please have
counsel revise the legalit y opinion to remove the limitation on the documents examined
and the assumption about the adequacy of those documents.

Michael J. West
Canfield Medical Supply, Inc.
November 21, 2012
Page 4

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing i ncludes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   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.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement please provide  a written statement from the company
acknowledging that:

 should the Commis sion or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated autho rity, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the propos ed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact Suying Li  at (202) 551 -3335 or Brian Bhandari at (202) 551 -3390 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Adam Turk at (202) 551 -3657 or David Link at (202) 551 -3356 with any other questions.

Sincerely,

 /s/ David Link for

John  Reynolds
Assistant Director