8/16/20101:28 PM

OrthoSynetics, Inc. Effective Date: August 1, 2010

Management Approval Matrix - Accounting Policy Superseding: All Prior Policies (Written or Oral)

Dept. / Dir.
Legal Practice Corporate
Function Human CFO CEO Chairman Board
Counsel Controller Controller
Manager Resrcs.
TRANSACTION / EVENT
Expenditures (Corporate Only)
Employee Travel & Entertainment Expense Reimbursement Requests R R>$1k R>$2K R>$4K R>$20K

General Office Supplies and Expense Invoices R R>$1k R>$2K R>$4K R>$20K

Advertising / Promotion / Public Relations Invoices R R>$1k R>$2K R>$4K R>$20K

Bad Debt Write-off - Individual Doctor Accounts R R R>$2K R>$4K

Budgets - Annual Operating Plan / Budget R R R R R R

Capital Expenditures / Repairs (>$1,500) Budgeted R R R>$2K R>$4K R>$20K R>$100k

Capital Expenditures / Repairs (>$1,500) Unbudgeted R R R R R>$20K R>$100k

Capital Asset Sales and Dispositions R R R>$2K R>$4K R>$20K R>$100k

Charitable Contributions (Generally Not Offered) R R R

Monthly Consulting Expense-Professional Fees (all functions) R R-Emp R R R R>$20K

Subscriptions - Prof./Trade Journals, Newspapers, Magazines R R R

Dues - Professional Associations & Organizations R R R R

Dues - Social / Athletic / Other Clubs (Generally Not Offered) R R R R

Seminars and Conferences R R R R>$500 R>$4K

Absorbed Center Expenses R R R>$500 R>$4K R>$20K

Check Run Pre-approval (Corporate Expenses Only) R R>$10k R>$50k

Wire Transfers (Corporate Expenses Only) R R R*1 R*1

Any New Contract that Needs to be Signed or Negotiated R R R R R

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Dept. / Dir.
Legal Practice Corporate
Function Human CFO CEO Chairman Board
Counsel Controller Controller
Manager Resrcs.
TRANSACTION / EVENT
Contracts / Agreements / Regulatory
Banking / Loan / Financing Agreements and Arrangements R R R R R R

Equipment / Personal Property Lease R R R R R

Facilities / Real Estate Lease R R R R R R

Letters of Credit (Issued by the Company Inc.) R R R R R R

Maintenance Contracts- Facility / Equipment / Other R R R R R

Consulting and Temporary Personnel Contracts, estimated total value R R R-Emp R R R

New Supplier Contracts / Rebates / Consignments / Changes R X R R R

Other Contracts & Agreements R R R-Emp R R R

Annual Insurance Renewal - Property & Flood R X R R R

Annual Insurance Renewal - GL, E&O, Wk. Comp, EPLI R X R R R

Annual Health Plan and Employee Benefit Plan Renewals X R R R R

Signing Contracts on Behalf of the Company (officers only) R*1 R*1 R*1

Regulatory Settlements
All Federal, State, Local Regulatory Agencies R R R-Emp R R R

Litigation and Claims

Contracting of Outside Legal Counsel R R-Emp R R

Settlements / Judgments R R-Emp R R R

Response to Claims/Litigation R R-Emp R R R

Finders Fee Agreement X R-Emp R R R

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Dept. / Dir.
Legal Practice Corporate
Function Human CFO CEO Chairman Board
Counsel Controller Controller
Manager Resrcs.
TRANSACTION / EVENT
Employee- Benefits, Contracts and Expenses
Employment Contract R R R R R

Employee Equity / Option Plans R R R R R R

Employment Agency / Search Firms (Normally Not Used) R R R

Payment of Fees / Commitments R R R R

Employee Benefit Plan Renewal / Changes X R R R R

Workers Compensation Settlements X R R R R

Employee Health Benefit Insurance (Amt. - Annualized Prem.) R R R R

Free / Promotional / Incentive Giveaways (Budgeted) R R R R R

Senior Management Bonus Awards R R R R R

Bonus and Incentive Awards- max $1,000 R R R R R

Employee Special Circumstances (Serious Illness / Death Remembrances /
Flowers / etc.) R R R

Personnel- Hiring and Salary Administration

New Position Approval R R R R R

New Position Approval - Management Level R R R R R R

Temporary Personnel / Contract Labor - use of R R R R R

Promotions / Salary Increases - Companywide R*1,*2 R R R R

Promotions / Salary Increases - individual employee R*1,*2 R R R

Any Employee (Full & Part-time) Additions and Replacements - including
hourly/salary R*1,*2 R R R R

Any Employee (Full & Part-time) Reductions R*1,*2 R R R

Other:
Temporary Shutdowns due to Inclement Weather R R R

Business Acquisitions & Dispositions R R R R R R

Accounting Reserve Creation & Changes Outside Policy Guidelines R R R

Accounting Changes R R R
Financial Statements - Close Process and Certification R R R R R

Mass communications to Doctors or Practices R R R

Policy and Procedure Additions/Changes/Modifications R R-Emp R R R

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Dept. / Dir.
Legal Practice Corporate
Function Human CFO CEO Chairman Board
Counsel Controller Controller
Manager Resrcs.
TRANSACTION / EVENT
Customer Related Issues
PSA Contract Approval R R R R R R

Any Unearned Distribution Payments to SSA and PSA Doctors (shortfall

position) X R X R R

BSA Bi-weekly Draw Adjustments X R X R R

SSA & PSA Mid-month & Month-end Distributions; BSA Quarter-end

Distributions R R X X X

Any BSA, SSA, or PSA Fee Changes or Contract Amendments R R R R R R

Check Run Pre-approval (Practice Expenses Only) R X X
Any Exchange of Monetary Incentives Outside of Contract R R R R R R

Doctor Transactions
De Novo Offices/Build Outs/Relocations R R R R

Real Estate Leases, Subleases and Assignments R R R R

Equipment Acquisitions R R R R

R = Mandatory
R-Emp = Required if Employment-Safety Related
X = Generally Required (Waiver Permitted with Officer Approval)
*1 -Two levels of approval are required for all personnel actions to be valid.
*2 - Approval required beyond compensation plan guidelines
K=$thousands / M=$millions
Confidential – For the use of appropriate Company employees only. Employment,
where applicable, is at will. Neither this document, nor any other, unless specifically
approved by the CEO is to be construed as an employment contract. The Company
is an equal opportunity employer dedicated to a harassment free environment.

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