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June 4, 2024
Kuai Leong
Senior Deputy General Counsel and Deputy Corporate Secretary
UNITEDHEALTH GROUP INC
9900 Bren Road East
Minnetonka, MN, 55343
Re:UNITEDHEALTH GROUP INC
Form 8-K filed February 22, 2024
Amendment No. 1 to Form 8-K filed March 08, 2024
Amendment No. 2 to Form 8-K filed April 24, 2024
File No. 001-10864
Dear Kuai Leong:
            We have conducted a limited review of your Form 8-K and have the following comment.
            Please respond to this letter by amending your Form 8-K and providing the requested
information. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your Form 8-K and the information you provide in
response to this letter, we may have additional comments.
Form 8-K filed February 22, 2024. Amendment No. 1 to Form 8-K filed March 08, 2024,
Amendment No. 2 to Form 8-K filed April 24, 2024
Item 1.05 Material Cybersecurity Incidents, page 1
1.Please tell us what consideration you gave to filing an amended Form 8-K pursuant to
Instruction 2 to provide information about the impact on your business operations, similar
to those described on the "Information on the Change Healthcare Cyber Response"
webpage. For example, your 8-K does not indicate that some pharmacies have been
unable to submit claims, and that providers have not been able to submit claims or receive
payment, but that information is described on the website. Please refer to Rule 105 of
Regulation S-T regarding the use of hyperlinks. Additionally, we note news reports
indicating that pharmacies have been unable to verify insurance status, and as a result
customers have had to pay cash or have been unable to obtain prescriptions. When you
file amended Forms 8-K pursuant to Instruction 2 to Item 1.05 of Form 8-K, please
expand your disclosure to address the following items:

 FirstName LastNameKuai Leong
 Comapany NameUNITEDHEALTH GROUP INC
 June 4, 2024 Page 2
 FirstName LastName
Kuai Leong
UNITEDHEALTH GROUP INC
June 4, 2024
Page 2
•expand your discussion to describe the scope of your business operations impacted;
and
•describe the known material impact(s) the incident has had and the material impact(s)
that are likely to continue.

In considering material impacts, please describe all material impacts. For example,
consider customer/partner relationships and potential reputational harm related to the
outage of your system, as well as any impact to your financial condition or results of
operations. To the extent you become aware of additional reasonably likely material
impacts, please confirm you will file an amended Form 8-K to update your disclosure.
            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.
            Please contact Aliya Ishmukhamedova at 202-551-7519 or Suzanne Hayes at 202-551-
3675 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology