Free Motion for Summary Judgment - District Court of Federal Claims - federal

Case 1:01-cv-00517-MBH

Document 47-4

Filed 12/22/2005

Page 1 of 2

Wníteb ~tates (!ourt of jf eberal (tlaíms

GHS Health Maintenance Organization,

Inc., d/b/a BlueLIncs HMO, Texas Health Choice, L.c., and
Scott & White Health Plan,

No. 01-517C

Plaintiffs,
v.

Judge Marian Blank Horn

United States,
Defendant.

Declaration of Frank Collins
I, Frank Collns, declare under penalty of perjury that the following is true and
correct:

1. I am employed by Sierra Health Services, Inc., which is the ultimate
parent company of Texas Health Choice, L.c. ("Texas Health"). My title is Senior Vice

President, Legal and Administration. I make this declaration based on my own
personal knowledge.
2. Texas Health received from OPM, reviewed, and abided by OPM's

Reconciliation Guidelines, which specify the documentation that carriers must maintain

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Case 1:01-cv-00517-MBH

Document 47-4

Filed 12/22/2005

Page 2 of 2

to support all calculations and statements pertaining to the reconciliation for five years

after the contract year.
3. Texas Health was in business throughout the 2001 contract year.

Executed on: December 19, 2005.

.- &~ ~-A~L
FRANK COLLINS

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