Salary Reduction Plan 401K

							                                   SALARY REDUCTION PLAN




PURPOSE: The purpose of this audit program is to define what areas of the 401(k) Plan are to
be tested and verified by the Internal Audit staff. It also provides the steps and procedures
needed to carry out the testing and verification.



ORGANIZATION: The audit program is broken down into three main areas:

1. Participants’ Accounts - Several computer generated reports pertaining to participants’
   account are tested to verify the accuracy of the participants’ eligibility and contributions.

2. Financial - Testing and verifying externally generated records.


PARTICIPANTS’ ACCOUNTS

Contribution Testing

                                                                             REF       INIT    DATE
       Randomly select 50 participant accounts per quarter and test the
       following:

I.     Participant contribution percentages are being properly deducted
       and credited to their account.

II.    Clinic matching amounts are properly calculated.

III.   Employee contribution is properly calculated.

IV.    Test one Master Payroll file per quarter to verify the information
       given to bookeeper is accurate.

V.     At year end, test maximum deferrals, and compensation rules.


Loan Testing

       Of the above 50 participants, those that have outstanding loans
       Have the following procedures followed:

I.     Compare outstanding loan balance from 401(k) Loan Report to
       the amount confirmed by bookkeeper.

II.    Compare the bi-weekly loan payment amount from the 401(k)
       Report to the amount confirmed by bookkeeper.
                                                                      REF   INIT   DATE

ELIGIBILITY

       Identify new hires, department transfers and rehires. Review
       eligibility dates for accuracy.


FINANCIAL

Quarterly Review

I.     Reconcile bookkeeper to the Investment Managers’ statements.

II.    Reconcile payables. Review managers’ fees for
       reasonableness.

III.   Reconcile participants’ equity.

IV.    Reconcile allocation of contributions between participants
       funds. Trace contributions from 401(k) report to company
       general ledger to bookkeeper receipt of funds.

V.     Review other plan expenses and revenue (administrative).

VI.    Recalculate 15 interest and dividend accruals for
       reasonableness. Test dividend rates to an outside source.
       Review subsequent transactions to insure all accruals are
       accounted for.

Year End Review


I.     Confirm securities held with managers.

II.    Request and examine audit report of the Northern Trust. Note
       internal control weaknesses.