← How Health Insurers Actually Make Money
Cycle on Jun 29, 2026
Ran 10m 46s · 6 findings · 10 searches · 7 fetches
No events yet. The agent's first move will appear here in a moment.
Agent
I am listing the open threads of interest for this topic to understand what specific questions or watches have been registered by prior cycles.
Listed threads
Agent
I will now fetch the public market data for UnitedHealth Group (UNH) to understand its current financial health, multiples, and recent segment performance.
other market_view
Agent
I see that UnitedHealth Group's stock has recovered dramatically (up 59% in 3 months, sitting at its 52-week high of $427.89, and up 80% from its 2025 low). This is a massive shift. Let's pull the market view for other major insurers to check if this is a sector-wide recovery.
Let's check CVS Health (CVS) and Humana (HUM). First, CVS:
other market_view
Agent
CVS Health (CVS) is also up dramatically: +46.5% over the last 3 months, trading at $104.34, near its 52-week high.
Let's look at Humana (HUM). Humana is historically the most exposed to Medicare Advantage. Let's see its market view.
other market_view
Agent
Humana (HUM) is up +121.9% over the last three months, reaching a new 52-week high of $383.84. This is an extraordinary turnaround for these managed care companies, which were heavily beaten down.
Let's see Centene (CNC) and Cigna (CI) and Elevance (ELV) as well. Let's pull Cigna's market view first.
other market_view
Agent
Let's pull Centene (CNC) and Elevance Health (ELV) as well. First, Centene: Harriet/CNC. Let's call market_view for CNC: Davies.
other market_view
Agent
Let's pull Elevance Health (ELV) as well. Let's call market_view for ELV: Let's do it.
other market_view
Agent
Great. We now have a comprehensive look at the market views of the major managed care players (UNH, CVS, HUM, CI, CNC, ELV).
Let's see:
1. UNH: up 59.0% in 3mo, trading at $427.89 (52-week high).
2. CVS: up 46.5% in 3mo, trading at $104.34 (99.3% of 52-week high).
3. HUM: up 121.9% in 3mo, trading at $383.84 (52-week high).
4. CNC: up 100.8% in 3mo, trading at $65.73 (98.8% of 52-week high).
5. ELV: up 35.6% in 3mo, trading at $395.18.
6. CI: up 6.6% in 3mo, trading at $282.79 (48.8% of 52-week high).
Wait, why did these stocks soar so massively in the last 3 months (roughly April, May, June 2026)?
Let's do some web searches to find out what happened in the sector over the last 3 months. Let's search for "managed care stocks rally", "health insurers rally Q2 2026", "Medicare Advantage rates", "CMS", "Star ratings", etc.
Let's run a search.
🔍 Search
health insurer stocks rally 2026 OR Medicare Advantage star ratings CMS 2026 OR managed care Q1 2026 earnings recovery
No results.
Agent
Aha! Let's examine this.
"CMS reworks Medicare Advantage star ratings after legal action" (June 18, 2026).
"CMS is recalculating 2026 Medicare Advantage star ratings" (June 2026).
Let's see. The CMS is revising 2026 Medicare Advantage Star Ratings, restoring some bonus payments and reopening the 2027 bid process.
Wait, let's look at the prior findings:
"Medicare Advantage Star Ratings: CMS Voluntary Redo and the Sector-Wide Litigation Battlefront (slug: medicare-advantage-star-ratings-regulatory-litigation) - CMS has initiated a voluntary recalculation of the 2026 Medicare Advantage (MA) Star Ratings..."
Wait, let's fetch these recent news articles to understand what exactly happened in June 2026.
Let's fetch:
1. `https://www.statnews.com/2026/06/18/medicare-advantage-star-ratings-recalculated-volatility-industry-lawsuits/` (or similar)
Let's search for "CMS 2026 Medicare Advantage star ratings recalculation June 2026" or "Clover health lawsuit CMS star ratings" to get the exact details. Let's do a search first, or web_fetch the STAT News article. Let's web_fetch the Health Care Dive and Fierce Healthcare articles as they might be easier to fetch or have detailed coverage. Let's web_fetch `https://www.healthcaredive.com/news/cms-recalculates-medicare-advantage-stars-clover-lawsuit/823253/` first.
📥 Fetch
https://www.healthcaredive.com/news/cms-recalculates-medicare-advantage-stars-clover-lawsuit/823253/
Agent
Wow, this is fascinating. Let's look at the details:
- The CMS is recalculating the 2026 Medicare Advantage star ratings (which dictate the 2027 Quality Bonus Payments) following a federal judge's ruling in late May 2026 in favor of Clover Health.
- In late May 2026, a Georgia federal judge agreed with Clover Health's lawsuit (which Clover filed in November 2025 after its largest plan's star rating slipped from 4 to 3.5 stars, costing it $120M).
- The judge ruled that CMS included improper measures in the ratings' calculation, including 10 measures based on data they didn't have the authority to collect, and 10 measures they included without going through proper rulemaking.
- On Wednesday (June 17, 2026), CMS issued a memo stating it was voluntarily recalculating the 2027 Quality Bonus Payment ratings (which are based on the 2026 Star Ratings) for certain contracts.
- However, for non-Clover plans, CMS only removed measures that it conceded it lacked explicit authority to collect, but did *not* remove measures that were challenged on rulemaking grounds.
- This means that for most other plans, the recalculation basically results in no change to average star ratings, although insurers can still choose to sue or appeal. If the full Clover criteria had been applied to the whole industry, UnitedHealth would have seen a bump from 4.11 to 4.27 stars (a $500M benefit) and Elevance from 3.9 to 3.92 ($25M benefit).
- Let's check when this memo was issued: Wednesday, June 17, 2026.
Wait, let's look at the other news: "UnitedHealth Stock Has Quietly Soared 80% off Its Low. Is the Worst Finally Behind It?" (June 27, 2026).
Let's search for why the health insurer stocks have soared so much. Is there another reason? For example, did the Q1 2026 earnings show stabilizing medical loss ratios (MLRs)? Or was there a rate notice or something else?
Let's search for "health insurers Q1 2026 earnings MLR" or "managed care Q1 2026 results medical cost trend". Let's run a web search.
🔍 Search
health insurers Q1 2026 earnings MLR OR managed care medical loss ratio Q1 2026 OR UnitedHealth Q1 2026 earnings call transcript MLR
No results.
Agent
This is excellent! Let's fetch the UnitedHealth Group (UNH) Q1 2026 earnings call transcript or the CNBC article to understand what happened. Let's web_fetch the Yahoo Finance / AlphaStreet or CNBC article:
`https://www.cnbc.com/2026/04/21/unitedhealth-group-unh-earnings-q1-2026.html` or the Yahoo Finance link:
`https://finance.yahoo.com/quote/UNH/earnings/UNH-Q1-2026-earnings_call-546952.html/`
Let's search for "UnitedHealth Group Q1 2026 earnings call transcript" or web_fetch the Yahoo Finance transcript if available, or fetch the CNBC article. Let's fetch the CNBC article first.
📥 Fetch
https://www.cnbc.com/2026/04/21/unitedhealth-group-unh-earnings-q1-2026.html
Agent
This is incredibly rich with details!
Let's see:
1. UnitedHealth Group (UNH) reported Q1 2026 results on April 21, 2026.
2. It reported EPS of $7.23 adjusted vs $6.57 expected, and revenue of $111.72 billion vs $109.57 billion expected.
3. It hiked its 2026 adjusted EPS outlook to "more than $18.25 per share" (up from "more than $17.75").
4. Its medical benefit ratio (or medical loss ratio, MBR/MLR) improved to 83.9% (down from 84.8% in Q1 2025), which was way better than the 85.5% expected. This eased investor concerns about medical cost trends.
5. In addition, the Trump administration finalized a 2027 payment rate increase to Medicare Advantage (MA) plans that was "far bigger than initially proposed" (finalized in early April 2026).
Wait, let's search for this: "Trump administration finalized 2027 payment rate increase to Medicare Advantage plans". Let's run a search on this to see what the rates were. This is highly important! Let's search for "Medicare Advantage 2027 rate notice final CMS April 2026".
🔍 Search
Medicare Advantage 2027 rate notice final CMS April 2026 OR Medicare Advantage 2027 payment rate final Trump administration
No results.
Agent
This is massive!
Let's analyze the 2027 Medicare Advantage Rates (announced in April 2026):
- In the Advance Notice (proposed earlier), the Trump administration proposed a meager **0.09%** average payment increase for Medicare Advantage (MA) plans in 2027. This was significantly below Wall Street's expectations and would represent a major squeeze.
- However, in the final Rate Announcement released on April 6, 2026, CMS finalized a net average year-over-year increase of **2.48%** in payments to MA plans for CY 2027.
- This represents an additional **$13 billion** in payments to plans for the 2027 plan year compared to 2026, and no major risk adjustment changes.
- This finalized 2.48% rate hike is a huge gift to insurers, and explains why their stocks have soared so much in the last three months (since early April 2026).
- Let's fetch the Healthcare Dive article `https://www.healthcaredive.com/news/cms-finalizes-higher-medicare-advantage-rates-2027/816633/` to see the details on this 2.48% rate hike. This will provide great detail for our analysis.
📥 Fetch
https://www.healthcaredive.com/news/cms-finalizes-higher-medicare-advantage-rates-2027/816633/
Agent
This is incredibly detailed and insightful!
Let's synthesize what we've learned so far:
1. **Medicare Advantage (MA) Rates (April 2026):**
- The CMS under the Trump administration (with Dr. Mehmet Oz as CMS Administrator and Chris Klomp as Director of Medicare) finalized a **2.48%** average rate increase for CY 2027 on April 6, 2026.
- This was a massive shift from the proposed **0.09%** rate increase in the Advance Notice (released in January 2026).
- The key driver of this generous increase was the decision to **strip the proposed risk adjustment model changes** (risk model recalibration) from the final rule. The industry lobby (led by the Better Medicare Alliance) successfully argued they needed more time to digest the Biden-era "V28" risk model changes.
- With risk adjustment accounted for, the rate change is projected to be **4.98%** on average for plans.
- This prevents further massive disenrollments and plan exits that would disrupt seniors ahead of the November 2026 midterm elections. It sends an additional **$13 billion** to MA plans in 2027 compared to the $700 million originally planned.
- Also, another regulation finalized in early April 2026 on star ratings is set to send almost **$19 billion more** to MA plans over the next decade.
2. **Medicare Advantage Star Ratings Recalculation (June 2026):**
- In late May 2026, a Georgia federal court ruled in favor of Clover Health, which had sued CMS over its 2026 Star Ratings (determining 2027 Quality Bonus Payments). Clover argued CMS used improper data sources and rulemaking for 20 measures.
- On June 17, 2026, CMS issued a memo announcing a voluntary recalculation for certain contracts.
- However, CMS only conceded on the "data source" argument (removing measures where it lacked explicit authority to collect data) and did *not* remove measures challenged on "rulemaking" grounds.
- Consequently, for non-Clover plans, this recalculation has virtually no impact on average star ratings. If the full Clover criteria had been applied, UnitedHealth would have gained $500M (star rating 4.11 -> 4.27) and Elevance $25M (3.9 -> 3.92).
3. **Q1 2026 Earnings (April/May 2026):**
- UnitedHealth (UNH) reported a dramatic recovery in Q1 2026, with an adjusted EPS of $7.23 vs $6.57 expected, and a medical benefit ratio (MBR/MLR) of 83.9% (down from 84.8% in Q1 2025 and beating expectations of 85.5%). This showed that the elevated medical cost trend is finally being managed/priced in.
- CVS Health reported Q1 2026 results that beat estimates ($2.57 vs $2.21 expected) and a 63.1% YoY increase in earnings.
- Humana (HUM) reported EPS of $10.31 vs $10.20 expected, and its stock has surged 121.9% in the last 3 months, reaching a 52-week high of $383.84.
- Centene (CNC) reported Q1 2026 net income of $1.54B (EPS $3.37 vs $2.13 expected), representing a huge recovery from losses in 2025. This is despite a 36% drop in marketplace membership due to expiring ACA subsidies.
Wait, let's look at the open threads to see if we can resolve or record any events on them.
Let's see:
1. "CMS Star Ratings October 2026 Announcement" (one_shot, fire_date: 2026-10-15T00:00:00Z) -> This is in the future (October 2026).
2. "Centene June 2026 Wakely Risk Adjustment Data Release" (one_shot, fire_date: 2026-06-30T00:00:00Z) -> Wait, today's date is June 29, 2026! This is exactly tomorrow. Let's see if there is any early data or news on this. Let's search for "Centene Wakely risk adjustment June 2026" or "Centene Marketplace margin 4%".
3. "Congress Progress on Patients Before Monopolies Act (PBM Act)" (ongoing, re-introduced May 13, 2026). Let's search for recent updates on this bill.
4. "Federal Court Ruling on Optum Rx California S.B. 41 Lawsuit" (one_shot, fire_date: 2026-12-31T00:00:00Z).
Let's do a web search on Centene's Marketplace performance, Wakely data, and its 4% margin target. Let's search for "Centene Wakely risk adjustment 2026" or "Centene marketplace margin 2026". Let's run a search.
🔍 Search
Centene Wakely risk adjustment 2026 OR Centene marketplace 4% margin target 2026
No results.
Agent
Let's fetch:
1. `https://healthworksai.com/insights/centene-corporation-q1-2026-earnings-call-insight/`
2. `https://jeffdelverne.substack.com/p/centenes-comeback-quarter-medicaid`
Let's see if we can read these to get the exact details on Centene's Marketplace risk adjustment, Wakely data, and margins. Let's do a web_fetch of `https://healthworksai.com/insights/centene-corporation-q1-2026-earnings-call-insight/` first.
📥 Fetch
https://healthworksai.com/insights/centene-corporation-q1-2026-earnings-call-insight/
Agent
This is incredibly high-quality research and details about Centene!
Let's see:
- Centene's Marketplace (ACA) segment has been a major focus. It had 3.58M members in Q1 2026 (down 36.4% from 5.63M in Q1 2025 due to expiring subsidy policies).
- The key target is its Marketplace pre-tax margin. It has conservatively booked a **3%** pre-tax margin in guidance (vs original 4% target), but the June Wakely risk adjustment report (which comes out at the end of June 2026, i.e., tomorrow/this week) is the key catalyst to confirm a meaningful risk adjustment receivable for its higher-acuity silver membership.
- If the June Wakely data confirms the receivable, it would support Centene's original **4%** Marketplace margin target, or even higher, providing a significant EPS upside.
- At Q1 2026, Centene raised its 2026 adjusted EPS guidance to **>$3.40** (up from **>$3.00**).
- Medicaid HBR improved to 93.1% (down 50 bps YoY), showing that Medicaid recovery is real.
- Medicare HBR was 84.9%, with a path to breakeven in 2027.
Wait, let's look at the open thread for Centene:
"Centene June 2026 Wakely Risk Adjustment Data Release" (one_shot, fire_date: 2026-06-30T00:00:00Z)
Is there any news on the Wakely risk adjustment data release for June 2026? Today is June 29, 2026. Let's search if the Wakely data or CMS final risk adjustment report for the 2025 benefit year has been released or discussed in the last few days.
Let's run a search for "Wakely risk adjustment June 2026" or "CMS risk adjustment report 2025 benefit year June 2026" or "Centene Wakely June 2026".
🔍 Search
CMS risk adjustment report 2025 benefit year OR Wakely risk adjustment report June 2026 OR Centene risk adjustment receivable 2026
No results.
Agent
Ah, let's search for "CMS risk adjustment report 2025 benefit year" which is typically released in late June or early July (usually around June 30th). Let's see if we can find any news about the 2025 benefit year risk adjustment summary report.
Let's search for: `Summary Report on Transitional Reinsurance Payments and Risk Adjustment Transfers for the 2025 Benefit Year` or `HHS Risk Adjustment Summary Report 2025 benefit year June 2026`. Let's run a search.
🔍 Search
HHS Risk Adjustment Summary Report 2025 benefit year OR risk adjustment transfers 2025 benefit year June 2026
No results.
Agent
Ah! Let's search for "interim-ra-report-by2025.pdf" or "HHS-RADV 2024 benefit year" or similar. But wait, since today is June 29, 2026, the final risk adjustment report for the 2025 benefit year is usually released on or around June 30th (tomorrow). Let's see if there is any early report or press release from Wakely or CMS about the 2025 benefit year risk adjustment transfers.
Wait, let's search for "Wakely risk adjustment 2025 benefit year" or "Wakely ACA risk adjustment report". Let's run a search.
🔍 Search
Wakely ACA risk adjustment report 2025 benefit year OR "2025 benefit year" risk adjustment transfers June 2026
No results.
Agent
No immediate search results for the exact phrase. Let's search more broadly for "Centene risk adjustment receivable" or "Centene Wakely June 2026". Let's run a search.
🔍 Search
Centene "Wakely" OR Centene "risk adjustment" 2026
No results.
Agent
Ah! Let's fetch the LinkedIn post and the Healthcare Dive article to understand this better.
Let's fetch:
1. `https://www.healthcaredive.com/news/centene-hikes-2026-profit-guidance-buoyant-q1/818581/`
2. `https://www.linkedin.com/posts/cdeaconc_health-insurer-centene-offers-most-staff-activity-7472617945882427392-FkNY` (if possible, or let's search for "Centene Offers Buyouts Amid Membership Losses and Layoffs" or "Centene risk adjustment receivable 2026")
Let's fetch the Healthcare Dive article first. This is a very clean source.
📥 Fetch
https://www.healthcaredive.com/news/centene-hikes-2026-profit-guidance-buoyant-q1/818581/
Agent
This is absolutely fantastic. Let's look at the core details here:
- Centene's Marketplace (ACA) footprint: In Q1 2026, membership dropped from 5.6M to 3.6M (down 36.4%) due to the expiration of enhanced ACA subsidies at the end of 2025.
- Sicker members remained in the silver plans ("the silver tier remaining membership really followed the golden rule of risk pools, that when it shrinks it becomes more morbid").
- Because of this, Centene expects to be a net *receiver* of risk adjustment payments in 2026, a massive reversal from its previous expectation that it would have to make a risk adjustment *payment*.
- As Sarah London noted: "often it can actually be a profitable strategy to care for sicker members in this market" because of the ACA's risk adjustment mechanism.
- Centene has booked a conservative 3% pre-tax Marketplace margin in its guidance of >$3.40 adjusted EPS (which was raised by 40 cents from >$3.00 in Q1).
- If the June Wakely risk adjustment report confirms this receivable, it would support Centene's original 4% margin target or higher, representing additional upside.
Wait, let's search for the PBM legislation and the Optum Rx lawsuit to see what's happening there.
Let's search for "Patients Before Monopolies Act 2026" or "PBM Act May 13 2026" or "Patients Before Monopolies Act Congress". Let's run a search. Abernathy!
🔍 Search
"Patients Before Monopolies Act" 2026 OR "PBM" legislation Congress May 2026
No results.
Agent
This is extremely interesting!
Let's fetch:
1. `https://www.mintz.com/insights-center/viewpoints/2146/2026-05-27-latest-pbm-reform-developments-keep-vertical-integration`
Let's see what this article has to say about the Patients Before Monopolies Act (PBM Act) and vertical integration. Let's do a web_fetch of it. This is a top-tier law firm analysis (Mintz Levin).
📥 Fetch
https://www.mintz.com/insights-center/viewpoints/2146/2026-05-27-latest-pbm-reform-developments-keep-vertical-integration
Agent
This is an incredibly rich, high-quality, and recent legal update from May 27, 2026. Let's analyze these developments:
1. **Patients Before Monopolies Act (PBM Act) - Reintroduced May 13, 2026:**
- It was reintroduced in both chambers of Congress on May 13, 2026, with bipartisan sponsors (including Sens. Josh Hawley, Elizabeth Warren, Reps. Jake Auchincloss, Diana Harshbarger).
- This reintroduction follows the broader "Break Up Big Medicine Act" (which has stalled in committee).
- The core prohibition remains: it would be unlawful to directly or indirectly own or control both a pharmacy and any insurance company or PBM (i.e. forcing structural divestitures of pharmacies from PBMs/insurers).
- Key changes in the 2026 version:
- **Accelerated Timeline**: The divestment period for violations of the common ownership prohibition is shortened from 3 years (under the 2024 bill) to **1 year**. It also requires the FTC and DOJ Antitrust Division to issue guidance "specifying milestones for divestment" within 30 days of enactment.
- **Stronger Enforcement**: Violators must transfer 10% of their profits on a monthly basis into an escrow account if they fail to meet milestones. Missing the deadline leads to a divestiture trustee selling the pharmacy.
- **Broader Standing & Private Right of Action**: Adds a private right of action for individuals alleging damages, allowing courts to award **treble damages** and attorney fees.
2. **Tennessee Enacts the FAIR Rx Act (S.B. 2040) - Signed May 22, 2026:**
- Tennessee's governor signed S.B. 2040 on May 22, 2026.
- It mirrors the federal PBM Act's core prohibition: no person or entity may own, operate, or control both a pharmacy and a health insurance issuer or PBM (applying to ownership interests exceeding 5%).
- Takes effect on **July 1, 2028**.
- Tennessee is the second state to enact such a law, after Arkansas. (The Arkansas law is currently on hold following a federal preliminary injunction, with an appeal pending in the Eighth Circuit).
3. **Optum Rx Challenges California S.B. 41 - Lawsuit Filed May 8, 2026:**
- On May 8, 2026, Optum Rx and Emisar Pharma Services (its affiliated GPO) filed a lawsuit to block California S.B. 41 (signed October 11, 2025).
- They argue that key provisions of S.B. 41 are preempted by ERISA.
- The provisions challenged include:
- Formulary exclusivity restrictions.
- Pharmacy network provisions (anti-steering, any-willing-provider, anti-discrimination).
- PBM compensation restrictions (mandating flat-fee payments, prohibiting spread pricing, requiring 100% passthrough of rebates).
- This lawsuit draws on a recent Sixth Circuit ruling in *McKee Foods Corp. v. BFP Inc.* (April 15, 2026), which held that ERISA preempts Tennessee's pharmacy anti-steering and any-willing-provider laws.
4. **Optum Rx's New Transparent Pharmacy Care Model - Announced May 11, 2026:**
- On May 11, 2026, Optum Rx announced a voluntary new pharmacy care model.
- Under this model, clients are offered per-member-per-month (PMPM) flat fees independent of drug prices or prescription volume.
- Optum Rx will provide full transparency into fees earned by it and its GPO (Emisar), including manufacturer payments/rebates.
- This voluntary transition represents an attempt to proactively de-risk the regulatory and legislative threat to spread pricing and rebate retention.
Let's do some more searches to see if we can find any other major news in the sector. What about Cigna's Evernorth pivot and Medicare Advantage divestiture? Let's check the prior findings:
"Cigna's Pivot to Evernorth and the De-Risked Commercial Employer Focus (slug: cigna-evernorth-pivot-commercial-focus) - The Cigna Group (CI) has pursued a unique strategic path among the major managed care organizations, deliberately de-risking its business by divesting its volatile Medicare Advantage (MA) business..."
Wait, let's search for "Cigna Medicare Advantage sale" or "Cigna Q1 2026 earnings" to see if there are updates on the transaction. Let's run a search.
🔍 Search
Cigna Medicare Advantage sale Health Care Service Corporation HCSC 2026 OR Cigna Q1 2026 earnings call Evernorth
No results.
Agent
This is absolutely magnificent! Let's examine:
"Cigna to exit ACA market, pursue strategic alternatives for eviCore unit" (April 30, 2026).
Wait, let's fetch this Fierce Healthcare article: `https://www.fiercehealthcare.com/payers/cigna-posts-165b-profit-q1-earnings-beat` to see the details of Cigna's Q1 2026 earnings, its exit from the ACA market, and strategic plans. This is a brand new development! Let's do a web_fetch.
📥 Fetch
https://www.fiercehealthcare.com/payers/cigna-posts-165b-profit-q1-earnings-beat
Agent
This is extremely valuable! Let's analyze Cigna's dramatic pivot:
1. **Cigna's Q1 2026 Earnings & Strategic Restructuring (announced April 30, 2026):**
- Reported $1.65 billion in net profit on $68.5 billion in revenue, beating expectations.
- **Evernorth’s dominance**: Evernorth generated **$58.4 billion** of Cigna's total $68.5 billion in Q1 2026 revenue (over **85%** of total revenue!). This shows that Cigna is effectively a pharmacy services and specialty care company (Evernorth, which houses Express Scripts, Accredo, and eviCore) with a smaller commercial insurance wrapper (Cigna Healthcare).
- **Medicare Advantage Divestiture Complete**: The sale of its Medicare business (Medicare Advantage, Part D, and Supplements) to Health Care Service Corporation (HCSC) was completed in March 2025. This dramatically reduced its exposure to the volatile MA market, which has squeezed other insurers. As a result, Cigna Healthcare's revenue fell to $11.5 billion (down from $14.5 billion in Q1 2025), but its Medical Loss Ratio (MLR) improved to a highly favorable **79.8%** (down from 82.2% in Q1 2025), reflecting the elimination of sicker MA enrollees.
- **ACA Market Exit**: In Q1 2026, Cigna announced that it will **fully exit the individual ACA market for the 2027 plan year**. The company cited the small size of the business, its lack of potential to scale, and "renewed instability" in the individual market (eAPTC subsidy expiration).
- **eviCore Strategic Alternatives**: Cigna is exploring strategic alternatives for **eviCore**, its medical claims and prior authorization management unit. Prior authorization has faced intense regulatory and public backlash, and Cigna is looking to offload this asset to reduce its regulatory/reputational footprint and free up management time.
Let's look at the prior findings that we need to update:
- `cigna-evernorth-pivot-commercial-focus` (Cigna's Pivot to Evernorth and the De-Risked Commercial Employer Focus)
- `regulatory-pbm-reform-vertical-integration-cracks` (Regulatory and Legislative Crackdown on PBMs and Vertical Integration)
- `centene-marketplace-margin` or do we have a Centene note? Wait, let's list the existing notes using `read_notes` to see their exact slugs. This is a critical step to ensure we reuse slugs correctly!
Read prior notes
Agent
Ah! This is extremely helpful. We have several existing notes:
1. `unitedhealth-optum-vertical-integration-medicare-advantage` (UnitedHealth and Optum Vertical Integration & Strategic Medicare Advantage Contraction)
2. `elevance-health-carelon-vertical-integration-internal-margins` (Elevance Health: Carelon and the Internal Profit Engine of Vertical Integration)
3. `humana-medicare-advantage-margin-compression` (Humana's Medicare Advantage Margin Compression and the 2027 Benefit Cliff)
4. `medicare-advantage-star-ratings-regulatory-litigation` (Medicare Advantage Star Ratings: CMS Voluntary Redo and the Sector-Wide Litigation Battlefront)
5. `centene-marketplace-risk-adjustment-wakely-catalyst` (Centene: Marketplace Risk Adjustment and the June Wakely Consulting Catalyst)
6. `regulatory-pbm-reform-vertical-integration-cracks` (Regulatory and Legislative Crackdown on PBMs and Vertical Integration)
7. `cigna-evernorth-pivot-commercial-focus` (Cigna's Pivot to Evernorth and the De-Risked Commercial Employer Focus)
8. `cvs-health-caremark-aetna-margin-recovery` (CVS Health: Aetna's Margin Recovery and Caremark's Pricing Transition)
9. `centene-medicaid-hbr-2027-policy-risk` (Centene: Medicaid Cost Recovery and the 2027 Work Requirement Policy Risk)
Wait! Let's examine what needs to be updated.
We have fresh, highly important data for:
- **Medicare Advantage rates & Star Ratings recalculation**: This directly impacts `medicare-advantage-star-ratings-regulatory-litigation` and `humana-medicare-advantage-margin-compression`, as well as `unitedhealth-optum-vertical-integration-medicare-advantage`.
- **Centene's Marketplace (ACA) Risk Adjustment and the June Wakely Catalyst**: We have the detailed Q1 2026 earnings data and the specific details about its Marketplace risk adjustment receivable and the upcoming June Wakely report. This directly updates `centene-marketplace-risk-adjustment-wakely-catalyst`.
- **Cigna's Evernorth Pivot and Commercial Focus**: We have the brand-new announcement of its exit from the individual ACA market for the 2027 plan year and its strategic review of eviCore, alongside its Q1 2026 earnings results. This directly updates `cigna-evernorth-pivot-commercial-focus`.
- **PBM Reform and Vertical Integration**: We have the reintroduction of the Patients Before Monopolies Act on May 13, 2026, the enactment of Tennessee's FAIR Rx Act on May 22, 2026, Optum Rx's lawsuit against California's S.B. 41 on May 8, 2026, and Optum Rx's new voluntary transparent pharmacy care model on May 11, 2026. This directly updates `regulatory-pbm-reform-vertical-integration-cracks`.
Let's carefully verify if any of the watches have fired or if we should record events.
Let's see:
- "Centene June 2026 Wakely Risk Adjustment Data Release" (one_shot, fire_date: 2026-06-30T00:00:00Z). Today is June 29, 2026. The actual release is scheduled for tomorrow (June 30). This is a forward-looking watch that hasn't fired yet, but we have updated the context in the note.
- "Federal Court Ruling on Optum Rx California S.B. 41 Lawsuit" (one_shot, fire_date: 2026-12-31T00:00:00Z). The lawsuit was filed recently (May 8, 2026), and a ruling is not yet out.
- "Congress Progress on Patients Before Monopolies Act (PBM Act)" (ongoing). The PBM Act was reintroduced on May 13, 2026. This is a progressive update, which we can record as an event! Let's check if we should record an event on thread `019eca64-0e4e-79d5-8e2a-b561d5f73584` ("Congress Progress on Patients Before Monopolies Act (PBM Act)"). Yes! Let's record the event on that thread.
Let's see the details of the thread:
- id: `019eca64-0e4e-79d5-8e2a-b561d5f73584`
- kind: `watch`
- title: `Congress Progress on Patients Before Monopolies Act (PBM Act)`
- cardinality: `ongoing`
- trigger: `Legislative progress or committee votes on the Patients Before Monopolies Act.`
Let's record the event on this thread to show that the PBM Act was reintroduced on May 13, 2026, with bipartisan support and accelerated divestment timelines (1 year instead of 3 years) and stronger enforcement mechanisms. This is a very important policy update. Let's call `record_event`.
other record_event
Agent
Now, let's write or update the findings.
Let's first update `regulatory-pbm-reform-vertical-integration-cracks` (Regulatory and Legislative Crackdown on PBMs and Vertical Integration).
Wait, let's read the existing content of `regulatory-pbm-reform-vertical-integration-cracks` first if we can, or we can write the updated finding directly. Since we have the details from the Mintz article, we can write a highly detailed, updated note that carries the new information and cites the Mintz article and Optum's news release.
Let's see the required format:
- No YAML frontmatter.
- Title is the first `#` heading.
- Slug parameter must match the existing slug to update it in place.
- Carry 1-2 representative verbatim quotes, each kept with the link it came from.
- Say what it means.
Let's carefully construct the body for `regulatory-pbm-reform-vertical-integration-cracks`.
Wait, let's check if we have quotes from the Mintz article:
Yes, we can quote:
"The 2024 and 2026 versions of the PBM Act share the same core prohibition: it would be unlawful to directly or indirectly own or control both a pharmacy and any insurance company or PBM. The 2026 bill, however, introduces several notable changes... The 2026 version of the PBM Act shortens the divestment period for violations of the common ownership prohibition from three years (under the 2024 bill) to one year."
And:
"On May 8, 2026, Optum Rx, Inc. (a PBM) and Emisar Pharma Services (an affiliated GPO) sued to block enforcement of California S.B. 41... arguing that key provisions of the law are preempted by ERISA."
Let's write the note for `regulatory-pbm-reform-vertical-integration-cracks`. Let's do it!
📝 Wrote finding
regulatory-pbm-reform-vertical-integration-cracks
Agent
This is outstanding.
Now let's update `cigna-evernorth-pivot-commercial-focus` (Cigna's Pivot to Evernorth and the De-Risked Commercial Employer Focus).
Let's see what we have:
- Q1 2026 earnings: Net profit of $1.65 billion on $68.5 billion in revenue, beating expectations.
- Evernorth revenue: $58.4 billion out of $68.5 billion (85.3% of total revenue).
- Medicare Advantage divestiture complete: March 2025 sale of its Medicare portfolio to HCSC. This de-risked Cigna Healthcare, lowering its revenue to $11.5 billion but improving its MLR to a highly favorable 79.8% (down from 82.2% in Q1 2025) as it shed sicker MA enrollees.
- Individual ACA Market Exit: On its Q1 2026 earnings call, Cigna announced a full exit from the individual ACA market for the 2027 plan year, citing the lack of scale and renewed instability (the expiration of enhanced subsidies).
- Exploring strategic alternatives for **eviCore**: This is its prior authorization and medical claims management unit. Offloading this asset would reduce its exposure to the public and regulatory backlash over prior authorization denials and free up management bandwidth.
Let's write this updated note for `cigna-evernorth-pivot-commercial-focus`. Let's do it! This is a major structural shift. Let's call `write_note`.
📝 Wrote finding
cigna-evernorth-pivot-commercial-focus
Agent
Now, let's update `centene-marketplace-risk-adjustment-wakely-catalyst` (Centene: Marketplace Risk Adjustment and the June Wakely Consulting Catalyst).
Let's see what we have:
- Q1 2026 results: Net income of $1.54 billion on $49.94 billion in revenue, beating expectations. Adjusted EPS of $3.37 vs $2.13 expected.
- 2026 adjusted EPS guidance raised to **>$3.40** (up from >$3.00).
- Marketplace membership fell to 3.58M (down 36.4% YoY from 5.63M) due to expiring ACA subsidies.
- Sicker members remained in the silver plans ("the silver tier remaining membership really followed the golden rule of risk pools, that when it shrinks it becomes more morbid").
- Because of this, Centene expects to receive a net risk adjustment *receivable* in 2026. This is a massive reversal from its previous expectation that it would have to make a risk adjustment *payment*.
- Centene has booked a conservative 3% pre-tax Marketplace margin in its guidance, leaving the full receivable upside out of the current guidance.
- The June Wakely risk adjustment report (scheduled for release tomorrow, June 30, 2026) is the key catalyst. If it confirms the full receivable, it will support Centene's original 4% margin target or higher, providing a significant EPS upside.
Let's write this updated note for `centene-marketplace-risk-adjustment-wakely-catalyst`. Let's call `write_note`.
📝 Wrote finding
centene-marketplace-risk-adjustment-wakely-catalyst
Agent
Excellent.
Now let's update `medicare-advantage-star-ratings-regulatory-litigation` (Medicare Advantage Star Ratings: CMS Voluntary Redo and the Sector-Wide Litigation Battlefront).
Let's see what we have:
- Late May 2026: A Georgia federal judge ruled in favor of Clover Health, which sued CMS over its 2026 Star Ratings (determining 2027 Quality Bonus Payments). Clover argued CMS used improper data sources and rulemaking for 20 measures.
- June 17, 2026: CMS issued a memo announcing a voluntary recalculation for certain contracts.
- However, CMS only conceded on the "data source" argument (removing measures where it lacked explicit authority to collect data) and did *not* remove measures challenged on "rulemaking" grounds.
- Consequently, for non-Clover plans, this recalculation has virtually no impact on average star ratings. If the full Clover criteria had been applied, UnitedHealth would have gained $500M (star rating 4.11 -> 4.27) and Elevance $25M (3.9 -> 3.92).
- This selective recalculation leaves CMS vulnerable to further lawsuits from other major insurers who are unhappy with their scores.
- This is the third year that CMS has been forced to recalculate payments following successful legal challenges (like SCAN Health Plan and Elevance in prior years).
- We also have the finalizing of the **2027 Medicare Advantage Rates** on April 6, 2026:
- CMS locked in a **2.48%** average rate increase for CY 2027 (up from proposed **0.09%** in January).
- The key driver of this generous increase was the decision to **strip the proposed risk adjustment model changes** (risk model recalibration) from the final rule, following intense industry lobbying.
- With risk adjustment accounted for, the rate change is projected to be **4.98%** on average for plans.
- This prevents further massive disenrollments and plan exits that would disrupt seniors ahead of the November 2026 midterm elections. It sends an additional **$13 billion** to MA plans in 2027 compared to the $700 million originally planned.
- Also, another regulation finalized in early April 2026 on star ratings is set to send almost **$19 billion more** to MA plans over the next decade.
Let's write this updated note for `medicare-advantage-star-ratings-regulatory-litigation`. Let's call `write_note`. This is a huge update!
📝 Wrote finding
medicare-advantage-star-ratings-regulatory-litigation
Agent
This is incredible!
Let's see if we should also update any other notes.
What about `humana-medicare-advantage-margin-compression`?
Wait, let's see if we have enough updates for Humana.
Yes! Humana is the most pure-play Medicare Advantage provider. Its stock has surged **121.9%** over the last three months, reaching a 52-week high of $383.84. This massive surge is directly tied to:
1. The finalized 2027 MA rates of 2.48% (with risk adjustment yielding 4.98%), which was a massive relief after the proposed 0.09% rate threatened to compress margins further.
2. The omission of the risk model changes (V28 phase-in or other risk model recalibrations), which gives Humana more time to digest prior changes.
3. Stabilizing medical utilization trends and disciplined bid design (sacrificing growth for margin) going into 2026/2027.
This is a perfect update for `humana-medicare-advantage-margin-compression`. Let's write the update for Humana. Let's call `write_note` on `humana-medicare-advantage-margin-compression`. Let's do it! This is very clean and powerful.
📝 Wrote finding
humana-medicare-advantage-margin-compression
Agent
This is absolutely marvelous!
Let's review if there are any other notes we should update.
What about `unitedhealth-optum-vertical-integration-medicare-advantage`?
Let's see:
- UNH reported strong Q1 2026 earnings on April 21, 2026.
- Adjusted EPS of $7.23 vs $6.57 expected, and revenue of $111.72 billion vs $109.57 billion expected.
- Hiked its full-year 2026 adjusted EPS outlook to "more than $18.25 per share" (up from "more than $17.75").
- Medical benefit ratio (MBR/MLR) improved to **83.9%** (down from 84.8% in Q1 2025 and beating expectations of 85.5%).
- Shares reached a 52-week high of **$427.89**, reflecting a **59% gain** over the last three months, and an **80% gain** from its 2025 low.
- Turnaround strategy under new leadership includes shrinking membership, selling the U.K. business of its Optum healthcare unit, investing in AI, streamlining access to care, and increasing transparency (including the new transparent pharmacy care model announced on May 11, 2026, which shifts Optum Rx toward flat-fee PMPM pricing).
- This is a perfect update for `unitedhealth-optum-vertical-integration-medicare-advantage`. Let's write the update. Let's call `write_note`. This is highly valuable!
📝 Wrote finding
unitedhealth-optum-vertical-integration-medicare-advantage
Agent
This is absolutely superb.
Let's review if there are any other notes we should update or threads we should resolve.
Let's see:
- `elevance-health-carelon-vertical-integration-internal-margins` (Elevance Health: Carelon and the Internal Profit Engine of Vertical Integration). Let's check if there are major updates. We mentioned that Carelon is a significant driver, but let's check if there's any other major news.
Wait, let's look at the other notes:
- `cvs-health-caremark-aetna-margin-recovery` (CVS Health: Aetna's Margin Recovery and Caremark's Pricing Transition). CVS reported strong Q1 results ($2.57 vs $2.21 expected) and its stock is up 46.5% over the last 3 months, trading at $104.34. This is a very strong recovery.
Wait, let's see if we should write a specific note or update `cvs-health-caremark-aetna-margin-recovery`.
Let's look at the current notes and their updates. We've updated:
1. `regulatory-pbm-reform-vertical-integration-cracks`
2. `cigna-evernorth-pivot-commercial-focus`
3. `centene-marketplace-risk-adjustment-wakely-catalyst`
4. `medicare-advantage-star-ratings-regulatory-litigation`
5. `humana-medicare-advantage-margin-compression`
6. `unitedhealth-optum-vertical-integration-medicare-advantage`
This represents 6 major updates of highly durable, stable slugs that track the key subjects of our topic!
Wait, let's check if we can resolve any threads.
Let's see the open threads again:
- `019eca64-0e4e-79d5-8e2a-b561d5f73584` ("Congress Progress on Patients Before Monopolies Act (PBM Act)") -> We recorded an event on it, but it's ongoing, so we keep it open.
- `019eca64-0100-7e7a-93ad-4828d60a97f3` ("Federal Court Ruling on Optum Rx California S.B. 41 Lawsuit") -> A ruling hasn't happened yet, so we keep it open.
- `019ea654-ac22-7ec9-beb1-4b8a5ca9e524` ("CMS Star Ratings October 2026 Announcement") -> This is in the future (October 2026), so we keep it open.
- `019ea654-a44a-77d6-b4b9-e7ca939c5632` ("Centene June 2026 Wakely Risk Adjustment Data Release") -> The release is scheduled for June 30, 2026 (tomorrow). We have updated the note with the latest Q1 details and the significance of this upcoming release, but since the actual report is released tomorrow, we should keep it open or we can resolve it if we feel our detailed explanation of the Q1 results and the conservative 3% vs 4% margin booking has fully addressed the pre-release context. Wait, the thread description says: "Monitor the release of the June 2026 Wakely Consulting Group risk adjustment data or the final CMS risk adjustment report to verify if Centene's risk adjustment receivable supports its 4% Marketplace margin target." Since the actual release is tomorrow (or very soon), we should keep it open as a watch for the next cycle to resolve when the data is finally published. This is very disciplined!
Wait, let's double check if we need to record any new threads or watches.
Let's see:
Is there a new forward-looking watch we should register?
Yes! What about Cigna's exit from the individual ACA market for the 2027 plan year, or its potential sale of eviCore?
Let's register a watch for Cigna's potential sale/divestiture of eviCore or its exit progress from the individual ACA market.
Or we can register a watch for the federal court's decision on the preliminary injunction of Tennessee's FAIR Rx Act, or the Eighth Circuit's appeal decision on Arkansas's vertical integration law. That is a great regulatory watch!
Let's call `record_watch` for the Eighth Circuit's appeal decision on Arkansas's vertical integration law, or the federal court's preliminary injunction ruling on Tennessee's FAIR Rx Act.
Let's see:
- topic_id: `019e89d0-893e-7d00-a5cf-ca1051e66e9d`
- cycle_id: `6f787410-418c-4f8f-917f-1dd84c19f081`
- title: `Eighth Circuit Ruling on Arkansas PBM Vertical Integration Law`
- cardinality: `one_shot`
- watch_type: `live_process`
- entity: `Arkansas PBM Law`
- description: `Monitor the Eighth Circuit's appeal ruling on the preliminary injunction blocking Arkansas's law prohibiting PBM ownership of pharmacies. A ruling upholding the law would pave the way for other states to enforce structural bans on vertical integration.`
Let's register this watch! It fits perfectly with our regulatory crackdown theme.
other record_watch
Agent
Let's register another watch for Cigna's potential sale/divestiture of eviCore. This is a major structural shift.
Let's see:
- title: `Cigna Divestiture or Strategic Transaction for eviCore`
- cardinality: `one_shot`
- watch_type: `dated_catalyst`
- entity: `Cigna / eviCore`
- description: `Monitor Cigna's progress on exploring strategic alternatives or a potential sale for its eviCore medical claims and prior authorization division to reduce regulatory and public relations exposure.`
Let's register this watch! Great.
other record_watch
Agent
Excellent. We have now recorded these watches.
Let's call `finish_cycle` to complete this research cycle. This is the only way to finish. We have written 5 highly detailed and substantive notes during this cycle, recorded an event on an existing thread, and registered two important new watches. Let's call `finish_cycle`.
other finish_cycle
Agent
I have successfully completed the research cycle for topic **019e89d0-893e-7d00-a5cf-ca1051e66e9d**.
### Summary of Key Findings & Actions Taken
#### 1. **Regulatory and Legislative Crackdown on PBMs and Vertical Integration**
* **Finding Updated (`regulatory-pbm-reform-vertical-integration-cracks`):** Grounded in a comprehensive legal analysis from Mintz Levin, this note tracks the bipartisan reintroduction of the **Patients Before Monopolies Act (PBM Act)** on May 13, 2026. The 2026 bill includes an accelerated **1-year divestment timeline**, monthly profit escrow penalties (10%), and a private right of action for **treble damages** to force structural separations of pharmacies from PBMs/insurers.
* It also details Tennessee’s enactment of the **FAIR Rx Act (S.B. 2040)** on May 22, 2026, which mirrors the federal bill, and **Optum Rx’s** May 8, 2026 federal lawsuit challenging California’s S.B. 41 on ERISA preemption grounds.
* We also analyze Optum Rx's defensive shift on May 11, 2026, introducing a voluntary **transparent pharmacy care model** with flat per-member-per-month (PMPM) fees to de-risk its revenue before spread pricing is legally banned.
* **Recorded Event:** Logged the bipartisan reintroduction of the PBM Act under the ongoing watch thread.
#### 2. **Cigna's Pivot to Evernorth and the De-Risked Commercial Employer Focus**
* **Finding Updated (`cigna-evernorth-pivot-commercial-focus`):** Grounded in Cigna's Q1 2026 earnings (reported April 30, 2026), this note details Cigna's $1.65 billion profit beat.
* **Evernorth’s Dominance:** Evernorth generated **$58.4 billion** (or **85.3%**) of Cigna's $68.5 billion in total revenue, proving that Cigna is fundamentally a pharmacy services and specialty care giant with a smaller commercial insurance wrapper.
* **Strategic Divestitures & Exits:** Cigna completed its Medicare Advantage sale to HCSC in March 2025, which lowered its Healthcare segment revenue to $11.5 billion but dramatically improved its MLR to **79.8%** by shedding volatile MA enrollees. On its call, Cigna announced a **full exit from the individual ACA exchange market for 2027** due to "renewed instability" (subsidy expirations) and is exploring **strategic alternatives for eviCore** to reduce its exposure to prior authorization backlash.
#### 3. **Centene: Marketplace Risk Adjustment and the June Wakely Consulting Catalyst**
* **Finding Updated (`centene-marketplace-risk-adjustment-wakely-catalyst`):** Documents Centene's blowout Q1 2026 results (adjusted EPS of **$3.37** vs. $2.13 expected) and its raised full-year guidance of **>$3.40**.
* **The "Golden Rule" of Risk Pools:** Centene's ACA Marketplace membership fell **36.4%** (from 5.63M to 3.58M) due to the expiration of enhanced subsidies. However, because sicker silver-tier members stayed ("when it shrinks, it becomes more morbid"), Centene expects a **net risk adjustment receivable** rather than its previously modeled payment liability.
* **The June 30 Catalyst:** Centene has booked a highly conservative **3% pre-tax Marketplace margin** in its guidance. The final Wakely Consulting risk adjustment report (scheduled for release tomorrow, June 30, 2026) is the key catalyst to verify if this receivable will support Centene's original **4% Marketplace margin target** (or higher), representing significant unpriced EPS upside.
#### 4. **Medicare Advantage Star Ratings: CMS Voluntary Redo and the Sector-Wide Litigation Battlefront**
* **Finding Updated (`medicare-advantage-star-ratings-regulatory-litigation`):** Captures the federal court ruling in late May 2026 in favor of **Clover Health**, which forced CMS to issue a voluntary recalculation memo on **June 17, 2026**.
* **Selective Recalculation:** CMS's memo conceded only on data-source authority grounds and refused to remove measures challenged on rulemaking grounds. This leaves average star ratings for non-Clover plans virtually unchanged, meaning UnitedHealth (which would have gained **$500 million** under full Clover criteria) and Elevance (which would have gained **$25 million**) will likely pursue further litigation.
* **2027 MA Rate Relief:** Analyzes the April 6, 2026 finalized Rate Notice, where CMS completely reversed its proposed 0.09% rate hike to lock in a generous **2.48% average increase** (projected to be **4.98%** risk-adjusted), delivering an additional **$13 billion** to plans in 2027 by stripping proposed risk model changes.
#### 5. **Humana's Medicare Advantage Margin Compression and the 2027 Benefit Cliff**
* **Finding Updated (`humana-medicare-advantage-margin-compression`):** Analyzes the spectacular **121.9% three-month surge** in Humana's stock to a new 52-week high of **$383.84**. This turnaround is directly driven by the finalized 2.48% rate notice (which averted a severe benefit cliff and massive plan disenrollments) and Q1 2026 earnings of **$10.31** that validated Humana's "margin over growth" strategy (counties exited, benefits trimmed, and a pivot toward D-SNPs representing 40% of the book).
#### 6. **UnitedHealth and Optum Vertical Integration & Strategic Medicare Advantage Contraction**
* **Finding Updated (`unitedhealth-optum-vertical-integration-medicare-advantage`):** Documents UnitedHealth's Q1 2026 blowout results (adjusted EPS of **$7.23** vs. $6.57 expected) and its raised full-year guidance of **>$18.25**. The company's Medical Benefit Ratio improved to **83.9%** (beating expectations of 85.5%), demonstrating that its pricing actions have successfully caught up to elevated medical cost trends.
### New Watches Registered
1. **Eighth Circuit Ruling on Arkansas PBM Vertical Integration Law (`one_shot`):** Monitoring the appeal of the preliminary injunction blocking Arkansas’s law prohibiting PBM ownership of pharmacies, which could establish a major nationwide legal precedent.
2. **Cigna Divestiture or Strategic Transaction for eviCore (`one_shot`):** Monitoring Cigna's progress on exploring strategic alternatives or a sale for its prior authorization segment to reduce regulatory and reputational exposure.