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 K=$thousands / M=$millions
X = Generally Required (Waiver Permitted with Officer Approval) Confidential – For the use of appropriate Company employees only. Employment,
*1 -Two levels of approval are required for all personnel actions to be valid. where applicable, is at will. Neither this document, nor any other, unless specifically
*2 - Approval required beyond compensation plan guidelines 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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