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SEC Company Response from UNITEDHEALTH GROUP INC (UNH) (CIK 0000731766) (UNH) — Jul 26, 2006

UNITEDHEALTH GROUP INC (UNH) (CIK 0000731766)
Date: July 26, 2006 · CIK: 0000731766 · Accession: 0001193125-06-153678

AI Filing Summary & Sentiment

File numbers found in text: 001-10864

Date
July 25, 2006
Author
Not clearly detected
Form
CORRESP
Company
UNITEDHEALTH GROUP INC (UNH) (CIK 0000731766)

Letter

Re: UnitedHealth Group Incorporated

Correspondence Letter

July 25, 2006

Attention: James Rosenberg

Office of the Chief Accountant

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Form 10-K for the year ended December 31, 2005

File Number 001-10864

Ladies and Gentlemen:

On behalf of UnitedHealth Group Incorporated (“Company”), this letter responds to the Staff’s question communicated by Keira Ino of the Staff on May 25, 2006:

1. SEC Comment:

Why has the Company not filed a Form 8-K under Item 4.02, “Non-reliance on Previously Issued Financial Statements or a Related Audit Report or Completed Interim Review”, as a result of the current review of its stock option practices?

Company Response:

The Company has not filed a Form 8-K under Item 4.02 because neither the Company’s management nor its Board of Directors has concluded that any previously issued quarterly or annual financial statements should no longer be relied upon because of a material error in the financial statements as addressed in Statement of Financial Accounting Standards No. 154 or SEC Staff Accounting Bulletin No. 99. Additionally, the Company has not been notified by its independent accountant that any audit report or completed interim review related to previously issued financial statements should not be relied upon. The Company’s independent and internal reviews discussed in its Quarterly Report on Form 10-Q for the quarter ended March 31, 2006 are continuing.

Securities and Exchange Commission

July 25, 2006

* * * * * * *

Please contact the undersigned at (952) 936-5901 with any questions or comments relating to this letter. Thank you.

Yours very truly,

/s/ Patrick J. Erlandson

Patrick J. Erlandson

Chief Financial Officer

Show Raw Text
CORRESP
1
filename1.htm

Correspondence Letter

 July 25, 2006

 Attention: James Rosenberg

 Office of the Chief Accountant

 Securities and Exchange Commission

 100 F Street, NE

 Washington, DC 20549

Re:
UnitedHealth Group Incorporated

 Form 10-K for
the year ended December 31, 2005

 File Number 001-10864

 Ladies and Gentlemen:

 On behalf of
UnitedHealth Group Incorporated (“Company”), this letter responds to the Staff’s question communicated by Keira Ino of the Staff on May 25, 2006:

1.
SEC Comment:

 Why has the Company not filed a Form
8-K under Item 4.02, “Non-reliance on Previously Issued Financial Statements or a Related Audit Report or Completed Interim Review”, as a result of the current review of its stock option practices?

 Company Response:

 The Company has not
filed a Form 8-K under Item 4.02 because neither the Company’s management nor its Board of Directors has concluded that any previously issued quarterly or annual financial statements should no longer be relied upon because of a material
error in the financial statements as addressed in Statement of Financial Accounting Standards No. 154 or SEC Staff Accounting Bulletin No. 99. Additionally, the Company has not been notified by its independent accountant that any audit
report or completed interim review related to previously issued financial statements should not be relied upon. The Company’s independent and internal reviews discussed in its Quarterly Report on Form 10-Q for the quarter ended March 31,
2006 are continuing.

 Securities and Exchange Commission

 July 25, 2006

 *     *     *     *
*     *     *

 Please contact the undersigned at (952) 936-5901 with any questions or comments
relating to this letter. Thank you.

Yours very truly,

/s/ Patrick J. Erlandson

Patrick J. Erlandson

Chief Financial Officer

 2