SecProbe.io

January 3, 201 3

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. 3 to Registration Statement on Form S-1
Filed December 19, 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
request ed information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

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

Form S -1/A, filed December 21, 2012

Selling Shareholders, page 25

1. Please revise to disclose the natural person with voting and investment power for
Underwood Family Partners and Kearney Holdings LLC.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
51

2. We note your revised disclosure in response to comment 1 of our letter, dated November
21, 2012.  Please revise to clarify that cost of goods sold and general and administrative
expenses are key variables in evaluating your financial condition.

Michael J. West
Canfield Medical Supply, Inc.
January 3, 201 3
Page 2

 Strategy

Increase profitable revenue and market share, page 54

3. We note your response  to comment  3 that “it is management ’s opinion, based on past
experience, that we could conser vatively generate approximately $25,000 in additional
revenue in the first 12 months after we start selling ” and “it is management ’s opinion,
based on discussions with the webstore designers and sales representative, that we coul d
generate approximately $25,0 00 in revenues in the first 12 months of operation. ”  It does
not appear to us that the company  has a reasonable basis to assert  that there will be
$25,000 in  additional  sales after the company starts selling when there is no assurance
that the company  will win any bids in the additional Ohio markets.  Additionally, it does
not appear to us that the company has a reasonable ba sis to assert  that the webstore will
generate $25,000 in revenues.  We also do not understand your argument  that having no
local competitors offering a similar retail webstore would lead to the webstore  having
$25,000 in s ales.  Finally, the amounts noted for the cost of the webstore do  not
correspond to the amount s you indicate in your use of proceeds  section to be spent on the
webstore.  Please revise your disclosures as appropriate.

Notes to Financial Statements

Note 1 – Organization, Operations and Summary of Significant Accounting Policies

Accounts Receivable, page F -7

4. We note yo ur disclosure that you have not recorded an allowance for doubtful accounts in
any of the periods presented.   Based on your aging of receivables at September 30, 2012
as disclosed on page 59, please address the following:
 We note your disclosure on page 39  that Medicare claims are paid within 30 – 45
days of submission.   Please tell us how you believe the Medicare receivables aged
above 45 days, not subject to appeal, are considered fully collectible (i.e. no
allowance necessary).
 We note your disclosure on  page 39 that Medicaid claims are paid within 14 days
of submission.   Please tell us how you believe the Medicaid receivables aged
above 30 days are considered fully collectible (i.e. no allowance necessary).
 We note the aging of your self -pay receivables continues to deteriorate, with over
50% greater than 90 days (31% greater than 1 year old).   Please revise to clarify
your payment terms of such receivables, when you consider such receivables to
be delinquent and what criteria you use to determine such re ceivables are still
collectible (i.e. no allowance necessary).

Michael J. West
Canfield Medical Supply, Inc.
January 3, 201 3
Page 3

 Note 5 – Restatement, page F -10

5. We note your revised disclosures in response to our prior comment 6.   Please address the
following:
 Please revise to expand your disclosure to explain the cumulative effect of the change
on retained earnings as of December 31, 2009 as required by FASB ASC 250 -10-50-
7.
 Please clarify for us how the adjustments were determined for each period presented,
specifically adjustments to revenue, receivables and reta ined deficit.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since t he 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 Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclo se the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the a dequacy 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 proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate t ime for us to review any amendment prior to the requested effective date of the
registration statement.

Michael J. West
Canfield Medical Supply, Inc.
January 3, 201 3
Page 4

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 statemen ts and related matters.  Please
contact Erin Wilson  at (202) 551 -6047  or David Link at (202) 551 -3356 with any other
questions.

Sincerely,

 /s/ David Link for

John Reynolds
Assistant Director