SecProbe.io

January 17, 2013

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. 4  to Registration Statement on Form S-1
Filed January 11, 2013
  File No. 333-182639

Dear Mr. West :

We have reviewed your amended 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 amendment 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.

Form S -1/A, filed January 1 1, 2013
Use of Proceeds, page  22

1. We note that the company indicates that it will use $60,000 for working capital if the
maximum offering of $300,000 is raised.  P lease revise to provide a more detailed
discussion of the working capital  expenses  and the anticipated amounts for each noted
use for the $60,000.

Executive Compensation

Summary Compensation, page 30

2. Please update the disclosure to provide the compensatio n for the fiscal year ended
December 31, 2012.

Michael J. West
Canfield Medical Supply, Inc.
January 17, 2013
Page 2

Organization and Operations

Payors, page 37

3. We reviewed your response to our prior comment 4.   Your response did not address our
comment in its entirety, thus the comment will be partially reissued.   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) at September 30, 2012.   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 receivables are still collectible  (i.e. no
allowance necessary).

4. We reviewed your response to our prior comment 4.   Please revise your disclosure here to
reconcile your statement that Medicare claims are paid within 30 – 45 days of submission
with the fact that approximately 23% of you r Medicare claims, not subject to appeal,
have aged over 61 days at September 30, 2012.   The actual results do not appear
consistent with your payment times as disclosed.

5. We reviewed your response to our prior comment 4.   Please revise your disclosure h ere to
reconcile your statement that Medicaid claims are paid within 14 days of submission with
the fact that approximately 30% of your Medicaid claims have aged over 30 days.   The
actual results do not appear consistent with your payment times as disclose d.

6. We reviewed your response to our prior comment 4.   Please tell us, by payor, how much
of the $9,665 in receivables, not subject to Medicare appeal, has been collected as of
December 31, 2012.

Financial Statements

Notes to Financial Statements

Note 5 – Restatement, page F -10

7. We reviewed your response to our prior comment 5, your response did not address our
comment in its entirety, thus the comment will be partially reissued.   Please clarify for us
how the adjustments were determined  for each period presented, specifically adjustments
to revenue, receivables and retained deficit.   For example, it appears you were
recognizing revenue on a cash basis.   As a result revenue was recorded when cash was
received.   Your restated financial sta tements for the year ended December 31, 2010
include an increase to receivables of $22,984 and increase to retained earnings of $23,057
and a decrease to revenue of $73.   It is not clear to us how you determined such
amounts.   Please advise.

Michael J. West
Canfield Medical Supply, Inc.
January 17, 2013
Page 3

 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 the company and its managem ent 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 foreclose the Commission from tak ing 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 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 proposed
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 o f 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 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