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
~,',
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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