Preview
CAUSE NO. CL-21-3026-G
§
BEATRICE CANTU § IN THE COUNTY COURT FOR
§
VS § HIDALGO COUNTY, TEXAS
§
§
RICARDO SALDIVAR § AT LAW NO. 7
§
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian of Records for: EDINBURG REGIONAL MEDICAL CENTER
Records Pertaining to: BEATRICE CANTU
1. Please state your full name.
Answer:
2. Please state your position and/or job title.
Answer:
3. Please state your employer's name, business address and telephone number:
Answer:
4. Are you authorized by EDINBURG REGIONAL MEDICAL CENTER to produce and testify as
to the patient billing and accounting records of BEATRICE CANTU?
Answer:
5. Were these records made and kept in the regular course of your business? (Business
means any kind of regularly organized activity, whether conducted for profit or not).
ANSWER
6. In the regular course or your business, did the person who signed or otherwise prepared
these records either have personal knowledge of the entries on these records or obtain the
information to make such records from sources who have such personal knowledge?
ANSWER
7. Are these records under your care, supervision, direction, custody or subject to your control?
ANSWER
8. Are these records made at or near the time of the act, event or condition recorded on the
records, or reasonably soon thereafter pertaining to the incident in question?
ANSWER
9. Were these records kept as described above?
ANSWER
258299.1 File #: RN
10. Have you been requested, directed, or has it ever been suggested by any person (whether
doctor, lawyer or anyone else) that any part of the records subject to this deposition be withheld
or protected from discovery for any reason? If so, please state the name and address of the
person who conveyed this information to you and when such event occurred.
ANSWER
11. Are there any other locations where EDINBURG REGIONAL MEDICAL CENTER would
keep records or documents pertaining to BEATRICE CANTU? If yes, please identify the name
and address of that location, if known.
ANSWER
12. Please hand all such records as outlined in the Subpoena Duces Tecum to the Officer
taking your deposition for inspection and photocopying. (These will be at no expense to you,
and the Officer will return the originals of your records to you after they have been both
inspected and copied). Have you done as requested? If not, why not?
ANSWER
13. Have any records of any kind been destroyed or are any records missing? If yes, why?
Please describe those records that have been destroyed or are missing by EDINBURG
REGIONAL MEDICAL CENTER.
ANSWER:
14. In the event that no records can be found, are there document archives (i.e. microfiche) or
document retention policies which explain their absence? If yes, please explain your archiving
and/or retention policy. Please identify who has knowledge of those archives and/or retention
policies for EDINBURG REGIONAL MEDICAL CENTER.
ANSWER:
15. Has EDINBURG REGIONAL MEDICAL CENTER made or caused to be made any billing
and accounting records for services rendered to BEATRICE CANTU FROM 08/30/2019 ONLY
which set out the complete billing history, including, but not limited to, the amount that
EDINBURG REGIONAL MEDICAL CENTER has adjusted, discounted, and/or written off, any
third-party payments, and any payments made by BEATRICE CANTU?
Answer:
16. What is the total dollar amount of the charges for the services rendered to BEATRICE
CANTU for the period FROM 08/30/2019 ONLY, as reflected in the billing and accounting
records?
Answer:
17. What is the total dollar amount of the charges for the services rendered, for the period
FROM 08/30/2019 ONLY, as reflected in the billing records, which have been paid by
BEATRICE CANTU (and not by private insurance or some other person or entity)?
Answer:
258299.1 File #: RN
18. Has any amount of the charges for services rendered for the time period from 08/30/2019
ONLY to BEATRICE CANTU been paid by private insurance, or by any person or entity other
than BEATRICE CANTU?
Answer:
19. If your answer to the preceding question was "yes," please write the name of the private
insurer, person, or entity, and the total amount paid by each for services rendered to BEATRICE
CANTU during the time period asked.
Answer:
20. If you provided a name or names and amount(s) in response to the preceding questions,
please state whether or not EDINBURG REGIONAL MEDICAL CENTER has a managed care
or contractual arrangement as to each private insurance, person or entity listed which requires
an adjustment, discount, or write-off of any portion or amount of the billed charges.
Answer:
21. If your answer to the preceding question was "yes" as to any private insurer, person, or
entity listed, please state the total amount of the charges for services rendered to BEATRICE
CANTU during the period FROM 08/30/2019 ONLY as reflected in the billing and accounting
records, which has been adjusted, discounted, written off by EDINBURG REGIONAL MEDICAL
CENTER as a result of the managed care or contractual arrangement with each private insurer,
person or entity listed.
Answer:
22. For each entity listed in the preceding three questions, please state whether or not
EDINBURG REGIONAL MEDICAL CENTER has a managed care or contractual arrangement
with the listed private insurer, person, or entity which prohibits EDINBURG REGIONAL
MEDICAL CENTER from seeking reimbursement from BEATRICE CANTU for any of the
amounts which have been adjusted, discounted, or written off as a result of that managed care
or contractual arrangement.
Answer:
23. Is EDINBURG REGIONAL MEDICAL CENTER a provider under Medicare and/or
Medicaid?
Answer:
24. If the answer to the previous question is "yes," is it true that EDINBURG REGIONAL
MEDICAL CENTER contract with Medicare and/or Medicaid requires that a patient not be held
legally responsible for the payment of any portion of the charges for treatment or services not
covered by Medicare and/or Medicaid?
Answer:
25. If the answer to the preceding question is "no," state all terms of BEATRICE CANTU's
insurance coverage of the healthcare expenses reflected on EDINBURG REGIONAL MEDICAL
CENTER’s billing records which allow EDINBURG REGIONAL MEDICAL CENTER to bill
BEATRICE CANTU for amounts not covered by Medicare/Medicaid.
Answer:
258299.1 File #: RN
26. What is the amount of charges for treatment or services rendered for the time period FROM
08/30/2019 ONLY to BEATRICE CANTU which have been paid by Medicare and/or Medicaid?
Answer:
27. What is the current balance, if any, owed on BEATRICE CANTU's bill for the specific period
of time requested?
Answer:
28. What amount, if any, of the said current balance does EDINBURG REGIONAL MEDICAL
CENTER continue to seek as payment from BEATRICE CANTU as his/her legal obligation to
pay beyond what Medicare/Medicaid, private insurance, or other person or entity has already
paid?
Answer:
29. Please fill in the following blanks with the requested information concerning medical
treatment provided to BEATRICE CANTU FROM 08/30/2019 ONLY:
A. TOTAL AMOUNT FOR ALL MEDICAL BILLED:
Answer:
B. TOTAL AMOUNT PAID BY PRIVATE INSURER:
Answer:
C. TOTAL AMOUNT PAID BY MEDICARE/MEDICAID:
Answer:
D. TOTAL AMOUNT PAID BY BEATRICE CANTU:
Answer:
E. TOTAL AMOUNT WRITTEN OR CHARGED OFF:
Answer:
F. TOTAL AMOUNT STILL OWED AND BY WHOM:
Answer:
______________________________________________
WITNESS CUSTODIAN OF RECORDS
I,______________________________,A Notary Public in and for the State of Texas do hereby
certify that the foregoing answers of the witness were made by the said witness and sworn to and
subscribed before me. The records attached hereto are exact duplicates of the original records.
GIVEN UNDER MY HAND AND SEAL on this the ________ day of________________20____.
______________________________________________
Notary Public in and for the State of Texas
258299.1 File #: RN
Preview
CAUSE NO. CL-21-3026-G § BEATRICE CANTU § IN THE COUNTY COURT FOR § VS § HIDALGO COUNTY, TEXAS § § RICARDO SALDIVAR § AT LAW NO. 7 § DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian of Records for: EDINBURG REGIONAL MEDICAL CENTER Records Pertaining to: BEATRICE CANTU 1. Please state your full name. Answer: 2. Please state your position and/or job title. Answer: 3. Please state your employer's name, business address and telephone number: Answer: 4. Are you authorized by EDINBURG REGIONAL MEDICAL CENTER to produce and testify as to the patient billing and accounting records of BEATRICE CANTU? Answer: 5. Were these records made and kept in the regular course of your business? (Business means any kind of regularly organized activity, whether conducted for profit or not). ANSWER 6. In the regular course or your business, did the person who signed or otherwise prepared these records either have personal knowledge of the entries on these records or obtain the information to make such records from sources who have such personal knowledge? ANSWER 7. Are these records under your care, supervision, direction, custody or subject to your control? ANSWER 8. Are these records made at or near the time of the act, event or condition recorded on the records, or reasonably soon thereafter pertaining to the incident in question? ANSWER 9. Were these records kept as described above? ANSWER 258299.1 File #: RN 10. Have you been requested, directed, or has it ever been suggested by any person (whether doctor, lawyer or anyone else) that any part of the records subject to this deposition be withheld or protected from discovery for any reason? If so, please state the name and address of the person who conveyed this information to you and when such event occurred. ANSWER 11. Are there any other locations where EDINBURG REGIONAL MEDICAL CENTER would keep records or documents pertaining to BEATRICE CANTU? If yes, please identify the name and address of that location, if known. ANSWER 12. Please hand all such records as outlined in the Subpoena Duces Tecum to the Officer taking your deposition for inspection and photocopying. (These will be at no expense to you, and the Officer will return the originals of your records to you after they have been both inspected and copied). Have you done as requested? If not, why not? ANSWER 13. Have any records of any kind been destroyed or are any records missing? If yes, why? Please describe those records that have been destroyed or are missing by EDINBURG REGIONAL MEDICAL CENTER. ANSWER: 14. In the event that no records can be found, are there document archives (i.e. microfiche) or document retention policies which explain their absence? If yes, please explain your archiving and/or retention policy. Please identify who has knowledge of those archives and/or retention policies for EDINBURG REGIONAL MEDICAL CENTER. ANSWER: 15. Has EDINBURG REGIONAL MEDICAL CENTER made or caused to be made any billing and accounting records for services rendered to BEATRICE CANTU FROM 08/30/2019 ONLY which set out the complete billing history, including, but not limited to, the amount that EDINBURG REGIONAL MEDICAL CENTER has adjusted, discounted, and/or written off, any third-party payments, and any payments made by BEATRICE CANTU? Answer: 16. What is the total dollar amount of the charges for the services rendered to BEATRICE CANTU for the period FROM 08/30/2019 ONLY, as reflected in the billing and accounting records? Answer: 17. What is the total dollar amount of the charges for the services rendered, for the period FROM 08/30/2019 ONLY, as reflected in the billing records, which have been paid by BEATRICE CANTU (and not by private insurance or some other person or entity)? Answer: 258299.1 File #: RN 18. Has any amount of the charges for services rendered for the time period from 08/30/2019 ONLY to BEATRICE CANTU been paid by private insurance, or by any person or entity other than BEATRICE CANTU? Answer: 19. If your answer to the preceding question was "yes," please write the name of the private insurer, person, or entity, and the total amount paid by each for services rendered to BEATRICE CANTU during the time period asked. Answer: 20. If you provided a name or names and amount(s) in response to the preceding questions, please state whether or not EDINBURG REGIONAL MEDICAL CENTER has a managed care or contractual arrangement as to each private insurance, person or entity listed which requires an adjustment, discount, or write-off of any portion or amount of the billed charges. Answer: 21. If your answer to the preceding question was "yes" as to any private insurer, person, or entity listed, please state the total amount of the charges for services rendered to BEATRICE CANTU during the period FROM 08/30/2019 ONLY as reflected in the billing and accounting records, which has been adjusted, discounted, written off by EDINBURG REGIONAL MEDICAL CENTER as a result of the managed care or contractual arrangement with each private insurer, person or entity listed. Answer: 22. For each entity listed in the preceding three questions, please state whether or not EDINBURG REGIONAL MEDICAL CENTER has a managed care or contractual arrangement with the listed private insurer, person, or entity which prohibits EDINBURG REGIONAL MEDICAL CENTER from seeking reimbursement from BEATRICE CANTU for any of the amounts which have been adjusted, discounted, or written off as a result of that managed care or contractual arrangement. Answer: 23. Is EDINBURG REGIONAL MEDICAL CENTER a provider under Medicare and/or Medicaid? Answer: 24. If the answer to the previous question is "yes," is it true that EDINBURG REGIONAL MEDICAL CENTER contract with Medicare and/or Medicaid requires that a patient not be held legally responsible for the payment of any portion of the charges for treatment or services not covered by Medicare and/or Medicaid? Answer: 25. If the answer to the preceding question is "no," state all terms of BEATRICE CANTU's insurance coverage of the healthcare expenses reflected on EDINBURG REGIONAL MEDICAL CENTER’s billing records which allow EDINBURG REGIONAL MEDICAL CENTER to bill BEATRICE CANTU for amounts not covered by Medicare/Medicaid. Answer: 258299.1 File #: RN 26. What is the amount of charges for treatment or services rendered for the time period FROM 08/30/2019 ONLY to BEATRICE CANTU which have been paid by Medicare and/or Medicaid? Answer: 27. What is the current balance, if any, owed on BEATRICE CANTU's bill for the specific period of time requested? Answer: 28. What amount, if any, of the said current balance does EDINBURG REGIONAL MEDICAL CENTER continue to seek as payment from BEATRICE CANTU as his/her legal obligation to pay beyond what Medicare/Medicaid, private insurance, or other person or entity has already paid? Answer: 29. Please fill in the following blanks with the requested information concerning medical treatment provided to BEATRICE CANTU FROM 08/30/2019 ONLY: A. TOTAL AMOUNT FOR ALL MEDICAL BILLED: Answer: B. TOTAL AMOUNT PAID BY PRIVATE INSURER: Answer: C. TOTAL AMOUNT PAID BY MEDICARE/MEDICAID: Answer: D. TOTAL AMOUNT PAID BY BEATRICE CANTU: Answer: E. TOTAL AMOUNT WRITTEN OR CHARGED OFF: Answer: F. TOTAL AMOUNT STILL OWED AND BY WHOM: Answer: ______________________________________________ WITNESS CUSTODIAN OF RECORDS I,______________________________,A Notary Public in and for the State of Texas do hereby certify that the foregoing answers of the witness were made by the said witness and sworn to and subscribed before me. The records attached hereto are exact duplicates of the original records. GIVEN UNDER MY HAND AND SEAL on this the ________ day of________________20____. ______________________________________________ Notary Public in and for the State of Texas 258299.1 File #: RN