Corrective Action – Palms Medical Group accepts the recommendation of the auditors. Palms Medical Group will review the current purchasing policy and modify it to ensure it conforms to the Universal Guidance Requirements. Palms Medical group when making “small purchases” for services and property in aggregate of $10,000 or more will obtain adequate number of quotes from qualified sources. This will be done by reviewing our current services and property purchased now and identifying which qualify as “small purchases”. Palms Medical Group will then identify qualified suppliers for each service or property that is deemed “small purchases” in aggregate of the $10,000 amount. Palms Medical Group will then ask for price sheets, bids, and service quotes from an adequate number of qualified suppliers. The number of adequate quotes will generally be two, unless otherwise determined there are not enough qualified suppliers. If there are not enough qualified suppliers, it will document the reasoning for this determination. For inventory-based supplies, such as medical supplies, vaccines, facility supplies, medical record supplies, and dental supplies, price lists and formulary quotes will be updated and documented every two years. For service purchases that qualify, if recurring, bids and quotes for services provided will be requested and documented every two years. For intermittent purchases related to projects, bids, quotes and price lists will be documented at project commencement. Documentation of suppliers and their bids, quotes, price lists will be documented and kept in the company share drive in a folder called “Procurement Documentation”. Within the Procurement Documentation folder there will be subfolders for our identified services and properties purchased. Exceptions to the policy will be documented by the VP of Business Continuity and approved by the CEO. The CFO and VP of Business Continuity will meet quarterly to assure compliance with the policies and procedures.