Our Commitment to Strong Performance and Progress

December 2025

A message from our CEO

To all our valued stakeholders:

Every day, millions of people rely on UnitedHealth Group for the care they need. We understand that we have a profound responsibility to ensure our business practices support our mission – to help people live healthier lives and to help make the health system work better for everyone.

Our company has already initiated a series of industry-leading commitments to help do that by improving transparency and simplifying the patient and care provider experience – from streamlining care quality review in pharmacy and medical care to expanding our Gold Card program for high-performing care providers. And we can do more.

In June, shortly after stepping into the role as CEO, I committed to conducting a transparent and comprehensive examination of key processes and policies within our approaches to risk assessment, managed care practices and pharmacy benefits and services to validate what is working and, more importantly, identify areas for improvement.

Today, I am pleased to share the independent assessors’ initial findings, which include a series of detailed recommendations for further strengthening and enhancing the protocols that govern our efforts.

We hope that you see these assessments as a commitment to setting a new standard of transparency for the health care marketplace, as we believe that you and every person who engages with our health system deserves to understand how we go about our work.

UnitedHealth Group independent review program: initial findings and next steps

UnitedHealth Group has retained external firms to conduct independent reviews of key processes and policies within our approaches to risk assessment, care services management and pharmacy benefits and services to validate what is working and, more importantly, identify areas for improvement.

What they did and found

As part of an initial assessment of our business practices, FTI Consulting and the Analysis Group – two widely respected, independent consultancies with deep health sector expertise – began in July conducting a rigorous review of:

  • Our approach to risk assessment operations within our Medicare Advantage programs.
  • UnitedHealthcare’s care services management policies, procedures and processes, including care quality review.
  • Optum Rx’s policies and processes for ensuring prescription drug manufacturer discounts are accurately collected and distributed to clients.

In their reports, the independent assessors determined UnitedHealth Group’s policies and practices are robust, rigorous and generally sound; and, in many respects, industry leading. The teams also identified several areas for improvement within each review and made recommendations to strengthen consistency and coordination.

What we’re doing about it

UnitedHealth Group has reviewed the findings from the independent assessments and developed 23 action plans to help address areas that were identified as opportunities for improvement.

Overall, the assessments identified opportunities to enhance enterprise-wide governance and compliance processes, including centralizing policies and tracking assessment findings, formalizing risk assessment standards, and where appropriate, optimizing and streamlining manufacturer drug discount administration. Below is a summary of specific actions that will be taken:

  • Enhancing policy governance and maintenance. Require that all policies and procedures are reviewed and approved at least annually and enhance enterprise-wide governance structures outlining roles and responsibilities for policy oversight, compliance monitoring and risk assessment.  
  • Strengthening processes for ongoing monitoring and tracking progress of corrective actions. Create a comprehensive tracking and monitoring process for internal, external and regulatory assessment findings to prevent repeat issues and ensure timely, complete actions are taken to correct identified issues.
  • Enhancing risk assessment and coding controls. Formalize governance for risk assessment and coding standards by implementing regular reviews, defining approved coding credentials and establishing a second-line compliance review function. Improve intra-year communication processes to ensure updates are disseminated in a timely manner.
  • Optimizing manufacturer discount processes. Consolidate and streamline policies and procedures for manufacturer discount administration and strengthen escalation protocols for non-payment and disputes, enhance reporting clarity over discount exclusions and implement automation for high-volume, low-complexity processes to improve efficiency.

We are on track to have completed 65% of our action plans by the end of 2025 and to have completed 100% by the end of Q1 2026.

What's coming next

Building on these initial reviews, we will partner with independent assessors to examine additional practices related to risk assessment, managed care and pharmacy benefits and services, including:

  • During the first quarter of 2026, we will share the results of a review of medical records of diagnosis codes identified during our in-home HouseCalls visits.
  • By mid-year, we will report on our processes to craft evidence-based medical policy.

Learn more about our ongoing efforts: