Request comes amid growing public alarm about corporate consolidation in the healthcare sector.

New York, NY, December 2025 — A coalition of faith- and values-based investors has filed a new shareholder resolution calling on UnitedHealth Group Inc. (“UNH”) to publish a report analyzing and describing the healthcare consequences of its corporate acquisition strategy. The request comes as public alarm and regulatory concern grow about the likelihood that UNH’s vertical integration strategy is leading to less effective and more expensive care for patients and other consumers across the country.

Acquisitions have been a central driver of UNH’s growth strategy over the past decade. As a direct result UNH now employs more physicians than any other company or organization in the United States. This has granted UNH immense influence over the experiences of patients across the country through their direct role in access to, quality, and delivery of care. In recent years, the company has purchased more than 300 surgery centers, acquired Change Healthcare to absorb its leading role in medical payment processing and analytics and bought LHC Group, the third-largest home healthcare provider. Most recently, UNH closed on its purchase of Amedisys, a major home health and hospice company.

In addition to requesting the report the resolution articulates risks to patients and the wider healthcare sector associated with UNH’s vertical integration strategy, including:

Physician practices and facilities owned by UNH may receive preferential reimbursement compared to independent providers, reducing patient choice and access to care and undermining small health-focused businesses across the country.
Narrow networks and care management protocols can steer patients to UHG-owned facilities, leading to delays, higher out-of-pocket costs, or foregone care.
Clinical outcomes may be affected, as studies have shown increased complications in certain procedures following physician integration with large systems.

The report requested in this latest shareholder resolution would help foster more robust transparency through the disclosure and description of data, including patient outcomes before and after acquisitions, prior authorization trends, and changes in the design and structure of provider networks.

“With healthcare costs skyrocketing across the United States and a growing number of American families losing their access to healthcare altogether, there is an urgent need for more transparency around the conduct and impact of the health sector’s most influential players,” said Timnit Ghermay of the Congregation des Soeurs des Saints Noms de Jesus et de Marie, lead filer on the resolution. “Sunlight is the best disinfectant. With this resolution, shareholders are hoping to gain a clearer sense of what UNH’s conduct and growth strategy has meant and will continue to mean for the health and wellbeing of the American public. The clarity this requested report would bring about can only help create a more data-driven, evidence-based and responsive healthcare system.”

“Healthcare in the United States is unaffordable,” said Lydia Kuykendal, Director of Shareholder Advocacy at Mercy Investment Services, Inc. “Every year, we spend more money than any other nation only to get sicker and deeper in debt. For insight into this problem, it’s important to monitor UnitedHealth Group (UNH), as it’s one of the largest corporate entities in the healthcare ecosystem. As shareholders of UNH, we believe that it is vital to understand how the expansion of the company beyond the traditional insurance business model impacts the delivery of healthcare. A report outlining information around these impacts could help investors better understand the risks and possible opportunities for this new enterprise.”

“With over $400 billion in annual revenue and nearly 2,700 subsidiaries, UnitedHealth has its hands in nearly every aspect of American health care,” said Wendell Potter, President of the Center for Health and Democracy. “It sells insurance through UnitedHealthcare. It delivers care through Optum’s 90,000 doctors. It manages prescriptions for 62 million people through OptumRx. And through Change Healthcare, it acts as the claims processing middleman for more than one-third of the U.S. health care system. In short, it’s the closest thing we’ve ever seen to a single-payer system in America—only it’s run for profit. And the public and shareholders should have far more transparency into this behemoth.”

CONTACT:
Alex Tucciarone
Director of Communications
Interfaith Center on Corporate Responsibility (ICCR)
atucciarone@iccr.org

About the Interfaith Center on Corporate Responsibility (ICCR)
The Interfaith Center on Corporate Responsibility (ICCR) is a broad coalition of more than 300 institutional investors collectively representing over $4 trillion in invested capital. ICCR members, a cross-section of faith-based investors, asset managers, pension funds, foundations, and other long-term institutional investors, have over 50 years of experience engaging with companies on environmental, social, and governance (“ESG”) issues that are critical to long-term value creation. ICCR members engage hundreds of corporations annually in an effort to foster greater corporate accountability. Visit our website www.iccr.org and follow us on LinkedIn, Bsky Social, and Facebook.

Shareholders in leading food and beverage companies today announced that they had filed a series of proposals for 2025 proxies requesting that those companies disclose their processes and policies for assessing and managing the health, financial and brand risks involved with the use of additives in their products. The filing comes amid mounting public concern around the use of chemical additives in the American food supply and their impact on the health and wellbeing of the consumer public.

In recent decades, a lax regulatory environment around the food and beverage industry has created a situation in which companies, rather than the FDA, are primarily responsible for the approval and use of Generally Recognized as Safe (GRAS) chemical additives in their consumer products. The proposals, submitted recently to several of the biggest corporations in the sector, request more public disclosure around company policies on the use of GRAS additives and the establishment of more robust and transparent food safety policies.

The proposals were filed at Coca-Cola ($KO), PepsiCo ($PEP) and Mondelēz ($MDLZ).

“Food and beverage companies have a moral responsibility to consider the long-term health consequences for people who are the consumers of their products,” said Laura Krausa, System Director of Advocacy Programs for CommonSpirit Health. “Recent changes in the regulatory landscape and growing concerns and even anger among the general public about the U.S. food supply mean that there is significant reputational risk in not being seen as taking those concerns seriously. With this proposal, we are encouraging corporate leadership to set a powerful example and safeguard long-term value and brand by adhering to a more rigorous standard of transparency around this aspect of product development.”

“For faith-based investors, protecting human health—especially children’s health—is a moral imperative. Our tradition teaches that stewardship includes safeguarding both human health and long-term corporate value,” said Christopher Cox, Executive Director of Seventh Generation Interfaith Coalition for Responsible Investment. “These proposals simply ask some of the most well-known companies in the American food and beverage sector to take responsible, transparent steps to protect consumers, strengthen trust, and reduce preventable risk. There is immense win-win potential in these resolutions securing wide approval.”

“The widespread breakdown of trust between the American people and companies is undeniable but it is not irreversible,” said Meg Jones-Monteiro, Senior Director for Health Equity and Evaluation at the Interfaith Center on Corporate Responsibility. “In many cases the way forward and course of action to enhance both consumer and investor confidence is clear and completely achievable. That course calls for a new approach that prioritizes transparency, rigor and a willingness to adhere to evidence-based practices. It will also help companies get ahead of increasing state-level legislation and potential federal regulation on this critical topic.”

The proposals are expected to be voted on by shareholders at the annual meetings of the food and beverage companies this spring.

Investor Statement on AI in Healthcare

While there are many concerning provisions in the “One Big Beautiful Bill Act” (OBBBA), one stands out for us: the provision imposing a 10-year moratorium on state and local regulations of artificial intelligence (AI). This measure, embedded within the broader budget reconciliation package, aims to centralize AI oversight at the federal level, effectively overriding existing state laws and preventing new ones from being enacted. The bill would nullify over 60 existing state-level AI regulations and halt the progress of hundreds of proposed bills attempting to erect sensible guardrails around the use of AI to address issues such as algorithmic bias, privacy breaches, and automated decision-making. If enacted, the ban would have far-reaching impacts on Americans’ human rights and civil rights, and would likely undermine our citizens’ public health well into the future.

Overall, we know that technology companies are influencing politicians to weaken oversight, through the OBBBA and other means; some technology companies donated over $1 million each to the inauguration fund. Subsequently, the President wiped away former President Biden’s executive order that called for a balance between positive impacts of AI’s growth and the need for ethical guardrails and consideration of risks to privacy and job loss. This kind of relationship highlights the need for state and local governments, who may not be as compromised as the federal agencies, to take the lead in common-sense regulations.

Some of the in-place regulations that would be rendered useless include laws that protect against AI-generated explicit material, prohibit “deep-fake” content that misleads voters and consumers, require indications to consumers that they are interacting with types of AI, and other protective measures. Importantly, many of the state laws instituting comprehensive data privacy include provisions that provide consumers the right to opt out of certain types of automated decision-making, and require businesses to conduct risk assessments before using high-risk automated profiling.

Investors have been calling for AI accountability and transparency by pressing healthcare companies to acknowledge where the risks of algorithmic harm exist and to disclose their plans for preventing, identifying, and mitigating these harms throughout their product lifecycles. As the use of AI in health care continues to proliferate, so too do concerns about privacy and the potential for algorithmic bias to negatively impact patient safety, equity of care, and treatment decisions.

Companies that create and market healthcare technologies, such as clinical support decision tools and electronic health records have a responsibility to ensure that these products don’t unintentionally contribute to or exacerbate healthcare inequities or discriminatory practices. By completely removing a state’s ability to implement practical regulations around the use of these products that will safeguard the rights of their constituents, Congress is effectively creating a wild west wherein companies will essentially write their own rules, to which we will all be subject.

While much of how healthcare corporations use AI is unknown, the harms have been much more public. Just a few examples include:

UnitedHealth Group / Optum – AI Algorithm and Denial of Care.Lawsuits alleged that an Optum algorithm was used to systematically deny rehabilitation care to Medicare Advantage patients based on projected outcomes, not clinical evaluations.
IBM Watson Health – Misleading Cancer Treatment Recommendations. IBM’s Watson for Oncology, marketed as an AI tool for cancer diagnosis and treatment planning, was criticized for producing unsafe or incorrect treatment suggestions.
Cigna – Algorithmic Claim Denials at Scale.In 2023, ProPublica and The Capitol Forum reported that Cigna doctors used a proprietary algorithm known as “PXDX” to automatically deny thousands of insurance claims without reviewing individual patient records.
CVS Health / Aetna – AI-Based Fraud Detection and Claim Denials.AI tools used to detect fraud and assess claims have allegedly led to wrongful denials or delays in legitimate insurance claims.
Teladoc Health – AI Chatbot Safety and Miscommunication Risks.Teladoc and similar virtual care platforms have faced scrutiny over their use of AI chatbots for triage or behavioral health assessments, raising liability and safety concerns.

Said Lydia Kuykendal Director of Shareholder Advocacy for Mercy Investment Services, “Regulations play a vital role in patient and customer safety. Giving corporations a blank slate to create whatever AI-driven technology they can imagine without having to worry about any consequences is alarming and possibly deadly. In the absence of comprehensive federal regulation, we must allow for common-sense state and municipal oversight of these potentially harmful innovations.”

The risks here are clear and present for healthcare companies choosing to push the boundaries of what AI should and should not do. What happens when something goes wrong? If an AI tool makes a clinical decision that is incorrect, how is the aggrieved party compensated for their loss? Data privacy issues also abound. We know that every year, corporations make billions of dollars from selling our data, a problem that becomes even more severe when we include personal health information. Finally, we know that AI systems are trained on publicly available data: Data that has proven time and again to have racial, ethnic, gender, and age biases. There is no question that tools and public health systems designed with these data sets will fall prey to the same biases that plague the data used to train them.

When it comes to our health, speed should never come at the cost of safety, fairness, or human dignity. Removing states’ ability to regulate the use of AI to protect their citizens will have serious consequences for both patients and business.

UnitedHealth Group’s very bad year, what it means for healthcare reform, and 3 predictors happening right now.

As annual meetings approach, publicly traded companies navigate the inclusion of shareholder resolution proposals in their proxy materials. These companies often seek assurances from the Securities and Exchange Commission (SEC) regarding the exclusion of certain proposals, aiming to avoid potential enforcement actions.

Publicly traded companies frequently seek guidance from the Securities and Exchange Commission (SEC) regarding the inclusion or exclusion of shareholder resolution proposals in their materials for annual meetings. This practice, while standard, has sparked debate about the potential for SEC influence on corporate decision-making and shareholder rights.

Eden Prairie-based health care giant said one proposal missed a filing deadline, while the other was “impermissibly vague.”

Investors cite concerns, including recent funding freezes, exits from global health bodies, and appointment of unqualified officials that may threaten equitable access to healthcare.

NEW YORK, NY, THURSDAY, APRIL 17, 2025 – Members of the Interfaith Center on Corporate Responsibility today announced they had issued a public statement calling on corporations to champion policies that protect and advance public health.

ICCR members have long engaged with leading healthcare companies to advocate for access to and affordability of medicines, vaccines, nutrition, and health technologies, especially for populations that have been systematically marginalized. Their statement today was driven by the administration’s recent funding freezes, departures from global health organizations, and the appointment of unqualified officials to lead key national public health institutions – actions that investors argue threaten public health both within the U.S. and worldwide.

Their statement asks companies to take four key steps: ensure that their political activities and public policy engagements support the advancement of global public health; assess the impacts of their businesses on the human right to health; adopt policies and processes that ensure the right to health is upheld within their operations; and support the appointment of individuals with appropriate experience to lead key U.S. public health positions.

“The defunding, dismantling, and abandonment of structures and initiatives that undergird public health systems both domestically and globally should concern every business,” said Lydia Kuykendal, Director of Shareholder Advocacy for Mercy Investment Services. “These actions and policies will have direct and long-lasting consequences for company prosperity through the diminished health of their workforces and indirectly, through diminished public health that will create broader and persistent economic burdens.”

The investors are particularly concerned by the dismantling of the United States Agency for International Development (USAID), a dramatic move expected to broadly jeopardize global health and national security, while also costing U.S. businesses, universities, and farmers an estimated $28.9 billion in funding.

Investors also questioned the U.S.’s withdrawal from the World Health Organization (WHO), a move that is widely expected to destabilize global health systems at a time when international cooperation is most needed to solve emerging health threats, such as Monkeypox and avian influenza. Also of concern is the dismantling of the U.S. President’s Emergency Plan for Aids Relief (PEPFAR), a decision widely expected to result in an increase in global AIDS-related deaths and new HIV infections.

“As long-term institutional investors, we view robust public health systems as critical to a thriving economy and the security of our portfolios,” said Amy Carr, Senior Shareholder Advocate for Friends Fiduciary. “We call on businesses to use their influence to demonstrate their support for their workers, suppliers, customers, and investors by standing up for their right to health.”

The investor statement also addressed recent staffing decisions by the administration, including mass layoffs and the placement of personnel with inadequate training and expertise to lead key government healthcare agencies.

The U.S. Department of Health and Human Services (HHS) houses the largest research enterprise in the world, the National Institutes of Health, the Centers for Disease Control and Prevention, and the Food and Drug Administration, and manages the Centers for Medicare and Medicaid Services (CMS). The Department’s work in disease prevention, healthcare delivery, research, drug development, and food safety is relied upon daily by every U.S. citizen and every business.

“The U.S. Department of Health and Human Services (HHS) oversees vital public health programs and is a pivotal U.S. agency,” said Meg Jones-Monteiro, ICCR’s Senior Director – Health Equity and Evaluation. “To fulfill its mandate to protect public health and foster economic stability, HHS must be staffed by only the most qualified and credentialed candidates and its policies must remain grounded in robust and impartial research and sound science that is thoroughly vetted.”

In their statement, the investors affirmed affordable and equitable healthcare not just as a human right, but a moral imperative and an economic necessity essential to the well-being of citizens, the workforce, and a thriving economy.

UnitedHealth Group is the latest company to utilise new guidance, as shareholders figure out their shifting rights.

The faith-based shareholders’ proposal was challenged by UnitedHealth twice, thanks to a recent SEC guidance change the shareholders slammed as unfair.

Shareholders Rally in Defense of Patients with Call for UnitedHealth Group to Publish Report on Impacts of Corporate Acquisitions

Investor Statement on AI in Healthcare