UnitedHealth Group has pledged to make sweeping internal improvements after releasing early findings from a wide ranging independent audit of its business practices. The announcement comes at a sensitive moment for the health insurance industry, which continues to face intense public scrutiny over patient access, billing practices, and rising health care costs.
The health care conglomerate said it has adopted 23 ongoing “action plans” designed to implement and track recommended improvements across several areas of its business. Oversight of these initiatives will fall to the company’s internal audit and advisory services team. UnitedHealth expects approximately 65% of these actions to be completed by the end of 2025, with all initiatives finished by the end of March next year.
While the company framed the announcement as a step toward greater transparency and accountability, it remains unclear whether the changes will meaningfully shift public perception. Private insurers are facing a wave of distrust from patients and lawmakers who argue that industry practices have made it harder for Americans to afford and access care. UnitedHealth owns UnitedHealthcare, the largest health insurer in the United States, giving its policies and performance outsized influence across the system.
A Trust Reset Attempt Amid Industry Backlash
The audit results arrive as insurers attempt to rebuild credibility following years of criticism surrounding claim denials, prior authorization delays, and opaque billing practices. In recent years, Medicare Advantage plans in particular have drawn attention from regulators and consumer advocates concerned about risk coding, billing accuracy, and patient outcomes.
UnitedHealth disclosed in July that two independent consulting firms had been retained to conduct a third party review of its business policies and performance metrics. On the same day, the company confirmed it was facing Department of Justice investigations related to its Medicare billing practices, an issue that continues to weigh on investor sentiment.
The audit marked one of the earliest major initiatives under new CEO Steve Hemsley, who returned to the role in May following the abrupt departure of former CEO Andrew Witty. Hemsley’s return signaled a renewed emphasis on operational discipline and regulatory credibility during a turbulent period for the company.
“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,” Hemsley said in a letter Friday.
“We know that our actions and decisions have significant impacts on patients, care providers and the broader health system, and we are determined to hold ourselves to the highest standard,” he added.
What the Independent Reviews Found
FTI Consulting was tasked with reviewing UnitedHealthcare’s risk assessment operations within its Medicare Advantage programs. This includes how the insurer evaluates patient health status and assigns diagnosis codes that influence reimbursement levels. The firm also examined the company’s care services management policies, procedures, and internal controls.
Separately, the Analysis Group reviewed the policies and processes of Optum Rx, UnitedHealth’s pharmacy benefit manager. The review focused on whether prescription drug rebates and discounts negotiated with manufacturers were being accurately collected and properly distributed to clients.
Pharmacy benefit managers have become a focal point for criticism across Washington and the health care industry. PBMs act as intermediaries between drug manufacturers, insurers, and pharmacies, negotiating rebates and determining which drugs are covered. Critics argue the system lacks transparency and can distort drug pricing incentives.
According to Hemsley, both consulting firms concluded that UnitedHealth’s policies and practices are “robust, rigorous and generally sound; and, in many respects, industry leading.” At the same time, the reviews identified areas where improvements could strengthen oversight, responsiveness, and documentation.
Optum Rx Review Highlights and Recommendations
The Analysis Group’s assessment found that Optum Rx has “implemented a comprehensive and well-structured framework that governs all stages of manufacturer discount administration.” The review identified at least 25 distinct controls designed to reduce the risk of miscalculating discounts, delaying payments, or collecting incomplete rebates from drugmakers.
Aaron Yeater, managing principal at the Boston office of Analysis Group, wrote that these controls collectively reduce operational risk and support accurate rebate administration. The review concluded there were “no deficiencies or need for corrective measures,” but it did recommend enhancements to further strengthen Optum Rx’s escalation and dispute resolution processes.
Specifically, the consultants suggested improving how Optum Rx handles cases involving nonpayment or disputes with manufacturers. One of UnitedHealth’s action plans includes developing a formal policy to guide procedures for addressing these situations in a more structured and timely manner.
Yeater emphasized that his review focused on business processes rather than the legal and regulatory issues currently facing the PBM, drawing a clear line between operational assessments and ongoing government scrutiny.
Medicare Advantage Performance Under the Microscope
FTI Consulting’s review found that UnitedHealth generally scored better than peers across several Medicaid and Medicare performance measures. However, the firm flagged areas where improvements are needed, including slow authorization decisions, documentation inconsistencies, and the handling of issues raised in regulatory audits.
These findings are particularly important given the heightened regulatory focus on Medicare Advantage. Federal agencies have increased audits and enforcement efforts as enrollment in these privately run plans continues to grow. Any perception of systemic weaknesses can translate into regulatory penalties, reimbursement changes, or reputational damage.
UnitedHealth said it will release additional findings from a review of medical records and diagnosis coding during the first quarter. The company also plans to report by midyear on its processes for developing what it calls “evidence-based medical policy,” a key area of concern for physicians and patient advocacy groups.
Investor Impact and Market Reaction
From an investor perspective, the audit and reform commitments arrive amid a challenging year for UnitedHealth Group. Shares are down more than 35% year to date after the company suspended its 2025 forecast due to surging medical costs, leadership upheaval, and ongoing federal probes into its Medicare Advantage operations.
The company is also still recovering from a difficult 2024 that included a historic cyberattack and widespread public backlash following the murder of UnitedHealthcare CEO Brian Thompson. These events have contributed to heightened scrutiny of UnitedHealth’s governance, risk controls, and crisis management capabilities.
For long term investors, the audit results present a mixed picture. On one hand, the findings suggest that UnitedHealth’s core operational frameworks remain sound and in some cases industry leading. On the other hand, the need for dozens of action plans underscores the complexity of the company’s business and the risks associated with scale in a heavily regulated environment.
What Comes Next
The real test will be execution. Investors, regulators, and patients alike will be watching whether UnitedHealth delivers on its promised reforms and whether those changes lead to faster decisions, clearer communication, and improved patient outcomes.
If successfully implemented, the action plans could help stabilize regulatory relationships and restore some degree of trust. Failure to follow through, however, could invite additional scrutiny and prolong the company’s stock underperformance.
For now, UnitedHealth is attempting to draw a line under recent controversies and reset expectations under new leadership. Whether this effort marks a turning point or merely a pause in mounting challenges remains an open question, one with significant implications for the broader health insurance industry and the millions of Americans it serves.
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