SecProbe.io

April 25, 2012
 Via E-mail

David S. Wichmann Executive Vice President, And Chief Financial Officer UnitedHealth Group Incorporated  UnitedHealth Group Center 9900 Bren Road East Minnetonka, Minnesota 55343
Re: UnitedHealth Group Incorporated
Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 9, 2012 File No. 001-10864

Dear Mr. Wichmann:
 We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other porti ons of your document.  In our comments, we ask
you to provide us with information so we may better understa nd your disclosure.
 Please respond to this letter within 10  business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe a comment applies to your facts and circ umstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the fo rm type label CORRESP that keys your
responses to our comment.

After reviewing the information provided, we may have additional comments and/or
request that you amend your filing.   Item 7. Management’s Discussion And Analys is Of Financial Cond ition And Results Of
Operations
Critical Accounting Estimates
Revenues, page 46

1. You state that effective in 2011, premium revenue subject to the premium rebates of the
Health Reform Legislation are recognized based on the estimated premium earned net of
the projected rebates over the period of the contract, when that amount can be reasonably
estimated and that the estimated premium is  revised each period to reflect current
experience. Please address the following:

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David S. Wichmann UnitedHealth Group Incorporated  April 25, 2012 Page 2

  Provide us proposed disclosure to be included herein in fu ture periodic reports that
discloses the amount of these rebates recorded  to revenue and any material changes in
the prior period estimate.
 Please clarify what amount you are referring to in your st atement “when that amount
can be reasonably estimated”.  If you ar e not recording reba tes that cannot be
reasonably estimated please tell us why this is appropriate.
 Provide us proposed disclosure  to be included in your fina ncial statements of future
periodic reports describing how you determ ine the amount of these rebates and your
accounting policy for recording them.
Consolidated Financial Statements

Notes to Consolidated Financial Statements
12. Commitments and Contingencies, page 81

2. You state that you provide guara ntees related to your perfor mance under certain contracts
and that, if standards are not me t, you may be financially at ri sk up to a stated percentage
of the contracted fee or a stated dol lar amount. Please tell us the following:
 Your accounting policy for recording these gua rantees and an analysis demonstrating
how it complies with GAAP;
 The contracts that these guarantees relate and your revenue recognition policy for fees
under these contracts specifica lly addressing how the fees are fixed or determinable
as discussed in Staff Accounting Bulletin  Topic 13.A.4. Revenue  Recognition; and
 For each of the last three years, the porti on of your fees subject to guarantees and the
maximum amount that is at risk.
   We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

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David S. Wichmann UnitedHealth Group Incorporated  April 25, 2012 Page 3

 Please contact James Peklenk, Staff Account ant, at (202) 551-3661 or Joel Parker,
Accounting Branch Chief, at (202) 551-3651, if you have any questions regarding the
comments.  In this regard, do not hes itate to contact me at (202) 551-3679.

Sincerely,  /s/ Jim B. Rosenberg  Jim B. Rosenberg Senior Assistant Chief Accountant