SecProbe.io

September 21, 2010

William F. Donovan, M.D. Chief Executive Officer Spine Pain Management, Inc. 5225 Katy Freeway
Suite 600
Houston, Texas 77007
Re: Spine Pain Management, Inc.  Form 10-K for the Fiscal Year Ended December 31, 2009
Filed March 31, 2010 Form 10-Q for the Quarterly Period ended June 30, 2010 Filed August 16, 2010 File No. 000-27407
 Dear Dr. Donovan:
 We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other por tions of your documents.  In our comments, we
ask you to provide us with information so  we may better underst and your disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  Where a comment requests you to revise disclosu re, the information you provide s hould show us what the revised
disclosure will look like and identify the annual or quarterly filing, as applicable, in which you
intend to first include it.  If you do not be lieve a comment applies to your facts and
circumstances, please tell us why in your res ponse.  Please furnish us a letter on EDGAR under
the form type label CORRESP that keys  your responses to our comments.
 After reviewing the information provided, we may have additional comments and/or
request that you amend your filing.               Form 10-K for the Fiscal Year Ended December 31, 2009

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies
 Revenue Recognition, page 20

1. Your disclosure here includes such statemen ts as “The Company’s new business concept
is focused on the development  of spine testing centers needed by spine surgeons,

William F. Donovan, M.D.
Spine Pain Management, Inc.
 September 21, 2010
 Page 2

orthopedic surgeons and other healthcare provi ders in order to provide the appropriate
treatment for musculo-skeletal spine injuries.”  and “The Company began treating
patients in August 2009 at the Company’s first spine testing center facility” and “Payment for services are primarily made to  the Company by a third party and the credit
policy includes terms of net 180 days for collections.”

Further, on page 4, you state “Our go al is to become a leader in providing care
management services  to spine and orthopedic surgeons and other healthcare providers to
facilitate proper treatment of their injured clients.  By pre-funding diagno stic testing and
non-invasive and surgical care,  patients are not u nnecessarily delayed or prevented from
obtaining needed treatment.  By providing ea rly treatment, the Company believes that
health conditions can be prevented from es calating and injured vi ctims can be quickly
placed on the road to recovery.  The Comp any believes its patient advocacy will be
rewarding to patients who obtain needed relief from painful conditions, and moreover, provides spine surgeons and orthopedic surgeons a solution to offset the cost of care prior
to settlement .”

And on page 5, you state:
“The Company plans to a ddress this market by:
• Initiate a two–year roll-out of our spin al medical services available to spine
surgeons, orthopedic surgeons, and other healthcare providers.
• Employ contract management services at  regional, state and local levels
• Identify and target key spinal healthcare providers who handle large numbers of
accident-type cases.”  ; and

 “We believe that our care management program improves the medical outcomes
for injured victims by providing medically  necessary, appropri ate and reasonable
treatment of injuries and facilitates the settlement of the injured victim's case  by
completing required medical treatment and providing clear and consistent medical
records.”

We have the following comments related to this disclosure and your business operations:
• Please revise your disclosure throughout the filings to clarify and specifically
identify your sources of revenue and how  this revenue will be collected.  It
appears you may be billing the patient for the services provided by the clinics and collecting from a third party.  If so, identify the third pa rty payors (Health
insurance companies, Law firms, Medicare and Medicaid, Workman’s
compensation claims, patient pay etc.).
• Discuss the nature of your business relations hip, if any, with the clinic facility and
identify any costs of building and operating the clinic that you are responsible for.
State whether you have any ownership in  or commitments to the clinics.
• For the year ended December 31, 2009, your revenue was $982,736, of which it
appears $442,231 has been reserved as uncollectible (a 45% write-off) and
$508,499 remains unpaid.  That implies that  you collected on ly approximately
$32,000 in cash on this revenue.  Please revise to provide, in a comparative

William F. Donovan, M.D.
Spine Pain Management, Inc.
 September 21, 2010
 Page 3

tabular format, the payor mix concentr ations and relate d 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, th e disclosure should indicate the past
due amounts and a breakdown by payor clas sification (i.e. Me dicare, Medicaid,
Managed care, Workers’ Comp. Insurance, Law firms and other, and Self-pay). We would expect Self-pay to be separate ly classified from any other grouping.
Include whether or not your billing syst em has the capacity to provide an aging
schedule of your receivables, and if not, clarify how this affects your ability to
estimate your allowance for bad debts.
• Your bad debt expense, as a percent of revenue, remained at 46%-47% for the first and second quarters of 2010.  Revise  your disclosure to explain the high
percentage write-off and clarify whether a ny of these charges are revenue dilution
items such as contractual allowances.  If s o, cite the authoritative literature used to
record these revenue dilution items as bad debt expense rather than as a reduction in gross revenue. Clarify if this high percen tage write off is expected to continue
in future years and will effect all clinics added.
• State the steps you take in collecting acc ounts receivable including existence of
internal billing and collection systems and/ or use of external resources.  Disclose
your policy with respect to determining wh en a receivable is recorded as a bad
debt and when a write off is recorded.  Clarify the threshold (amount and age) for
account balance write-offs.
 Item 8.  Financial Statements

 Balance Sheets, page 23

2. Please revise to disclose, on the face of th e statement, the amount of your reserve for
doubtful accounts netted against accounts rece ivable for each period presented.

Statement of Operations, page 24

3. Disclose on the face of the Statement of Opera tions any revenue and cost of sales that are
from a Related Party.
 Notes To The Financial Statements

 Note 3.  Summary of Significant Accounting Policies

Revenue Recognition, page 29

4. Please provide a Valuation and Qualifying Accounts schedule, see Rule 12-09 of
Regulation S-X.

William F. Donovan, M.D.
Spine Pain Management, Inc.
 September 21, 2010  Page 4

Note 9.  Related Party Transactions

Medical Services Agreement, page 35

5. You disclose that your total Cost of sales in  the Statement of Operations consists of
expenses charged by NSO for services perf ormed.  Please quantify and describe the
nature of these costs (including amounts paid  to Dr. Donovan for me dical services) and
SPMI’s business relationship and commitments with the clinic (including obligations, if any, for costs such as rent, utilities etc. in  addition to fees for medical services).
 Form 10-Q for the Quarterly Period Ended June 30, 2010

 Exhibits 31.1 and 31.2

6. Please revise these certifications to include  the revised introduc tory language of
paragraph 4 similar to that us ed in your Exhibits 31.1 and 31.2 filed with your Form 10-K
for 2009.   We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Please contact James Peklenk, Staff Account ant, at (202) 551-3661 or Joel Parker,
Accounting Branch Chief, at (202) 551-3651 if you have any questions regarding the comments.
In this regard, do not hesitate to contact me, at (202) 551-3679.

Sincerely,
   Jim B. Rosenberg Senior Assistant Chief Accountant