I'm not sure I completely follow the situation, but I'm guessing that the SPA is already established (as a cash practice) but not billing insurance? They need to decide how the billing will be done and who will receive any reimbursement from the insurance carriers. They should seek help from their accountant and/or attorney to make sure they set the business up correctly. Then they need to make sure they have the appropriate staff for performing the services that they will be performing. For example, do they just need a certified technician, or do they need a supervising MD. I personally do not know for a cryotherapy chamber. Is a chiropractor within his/her scope of practice performing those services? Will insurance carriers reimburse the services if it is performed by a DC? Lots of homework needs to be done before they can start up.