Why It Matters

UnitedHealth Group’s most profitable business line is under threat. The bipartisan No UPCODE Act targets "upcoding"—inflating patient diagnoses to boost federal reimbursements—a practice CMS estimates costs taxpayers $17 billion annually.

The Department of Justice has launched civil and criminal investigations into UnitedHealth’s Medicare billing practices. Meanwhile, CMS announced it would audit 550 Medicare Advantage plans annually—up from 60—and expand its coding staff to roughly 2,000 people by September 2025.

By the Numbers

UnitedHealth Group Inc. has spent more than $110 million in total lobbying expenditures since 2003, making it one of healthcare’s most prolific spenders.

For this quarter’s engagement, UnitedHealth hired theGROUP DC LLC at $90,000. The firm has filed 18 previous disclosures for UnitedHealth since 2021, totaling $1.34 million. The company simultaneously retains multiple specialized firms alongside a robust in-house team.

The third quarter disclosure focuses specifically on monitoring the No UPCODE Act and broader Medicare/Medicaid issues. UnitedHealth deployed three lobbyists: Sudafi S. Henry, a former House Democratic staffer; David P. Cleary, former Senate HELP Committee Staff Director; and Jorge Antonio Aguilar.

Cleary’s extensive Senate health committee background provides critical Republican access at a moment when the No UPCODE Act enjoys bipartisan sponsorship from Senators Bill Cassidy (R-LA) and Jeff Merkley (D-OR).

The Agenda

UnitedHealth is lobbying on general Medicare and Medicaid issues with specific focus on monitoring the No UPCODE Act—legislation that would remove financial incentives for Medicare Advantage plans to inflate patient diagnoses. The bill could save taxpayers an estimated $124 billion over ten years, according to supporters. AARP has endorsed the measure as a "commonsense solution" to protect seniors and ensure Medicare’s solvency.

Broader Context

Congress is intensifying scrutiny of Medicare Advantage insurers over widespread upcoding. CMS announced an aggressive audit strategy, expanding audits from roughly 60 to 550 plans annually.

The primary legislative threat is the bipartisan No UPCODE Act. Though the insurance industry’s lobbying efforts successfully removed it from a federal budget bill in summer 2025, the bill maintains strong bipartisan support.

UnitedHealth faces additional threats as PBM reform legislation advances in Congress, targeting its Optum division. The company has spent $9.2 million through September 2025—surpassing any previous full year.

Between The Lines

A House Ways and Means subcommittee hearing highlighted systemic overpayments, with the Medicare Payment Advisory Commission estimating taxpayer overcharges of $84 billion annually.

Rep. Greg Murphy (R-NC) accused UnitedHealthcare of "pushing" the boundaries of Medicare fraud, while Senator Elizabeth Warren (D-MA) has vocally criticized insurers using fraudulent diagnoses. The bipartisan consensus suggests comprehensive Medicare Advantage reform is likely inevitable.

Competitive Landscape

The healthcare industry is experiencing record lobbying spending in 2025, with insurance trade group AHIP spending $13.1 million through September—surpassing their entire 2024 budget.

Multiple well-funded competitors are engaged on Medicare Advantage reform: competing insurers like Cigna and Humana defend their market positions, while advocacy organizations like AARP powerfully back the No UPCODE Act. Hospital systems lobby on overlapping Medicare issues, often opposing insurer positions on prior authorization practices.

The Bottom Line

UnitedHealth is doubling down on Capitol Hill as federal scrutiny intensifies. The company’s strategic hire of David P. Cleary signals intent to leverage high-level Republican relationships against legislation that supporters claim could save taxpayers $124 billion over a decade. The engagement reflects a broader industry lobbying surge as healthcare companies confront aggressive federal enforcement and record congressional scrutiny.

For more detailed insights access Legis1. Request a demo today!

Spot something wrong? Report an issue with this article