SecProbe.io

March 21, 2018
John F. Rex
Chief Financial Officer
UnitedHealth Group Inc.
UnitedHealth Group Center
9900 Bren Road East
Minnetonka, MN   55343
Re:UnitedHealth Group Inc.
Form 10-K for the fiscal year ended December 31, 2017
Filed February 13, 2018
File No. 001-10864
Dear Mr. Rex:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the year ended December 31, 2017
Financial Statements
Note 7 - Medical Costs Payable, page 58
1.It appears you have aggregated the UnitedHealthcare and OptumHealth segments in the
disclosure required by ASC 944-40-50-4A.  ASC 944-40-55-9C specifically states that,
when presenting this disclosure, amounts from different reportable segments should not be
aggregated.  Please tell us why you believe your current disclosure complies with the
applicable guidance.
Note 9 - Income Taxes, page 61
2.You disclose that the Company’s measurement of the income tax effects of Tax Reform

 FirstName LastNameJohn F. Rex
 Comapany NameUnitedHealth Group Inc.
 June 16, 2017 Page 2
 FirstName LastName
John F. Rex
UnitedHealth Group Inc.
March 21, 2018
Page 2
for the year ended December 31, 2017 is reasonably estimated.  Please clarify whether
your accounting is complete or whether there are certain income tax effects of Tax
Reform for which the accounting is incomplete.  To the extent your accounting is
incomplete, please provide us the following information pursuant to Staff Accounting
Bulletin 118:
•Qualitative disclosures of the income tax effects of the Act for which the accounting is
incomplete;
•Disclosures of items reported as provisional amounts;
•Disclosures of existing current or deferred tax amounts for which the income tax
effects of the Act have not been completed;
•The reason why the initial accounting is incomplete;
•The additional information that is needed to be obtained, prepared, or analyzed in
order to complete the accounting requirements under ASC Topic 740.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Lisa Vanjoske at (202) 551-3614 or Sharon Blume at (202) 551-3474
with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance