15 unchanged sentences
We aim to bring this senior-first healthcare experience to millions in the United States, become the most trusted senior healthcare brand in the country, and ultimately “do well by doing good.”
−Removed: Alignment’s Virtuous Cycle is a Distinct Competitive Advantage
−Removed: Our model is based on a flywheel concept, referred to as our “virtuous cycle,” which reflects our unique ability to manage healthcare expenditures while maintaining quality and member satisfaction — a distinct and sustainable competitive advantage.
−Removed: To execute upon this concept, we start by ingesting medical and demographic data through our proprietary AVA technology platform.
+Added: Business Overview
+Added: Alignment is a next generation, consumer-centric and clinically focused platform designed to improve the healthcare experience for seniors enrolled in Medicare who choose a private Medicare Advantage plan.
+Added: Our goal is to provide seniors with easier access to care, better coordination among providers, fewer gaps in care and avoidable hospital visits, and support that meets them where they are—at home, online, or in their community.
+Added: We deliver this experience through our wide variety of Medicare Advantage plans, which offer varied benefits tailored to the diverse needs, preferences, and lifestyles of seniors.
+Added: We believe our plans are differentiated because of our unique ability to manage costs by delivering proactive care and manage chronic conditions through an integrated clinical and technology model.
+Added: Our licensed Medicare Advantage plans contract directly with the Centers for Medicare & Medicaid Services.
+Added: In exchange for a capitated, fixed monthly payment for each enrolled member (i.e., revenue per member per month or “PMPM”) , we take responsibility for coordinating and managing our members’ healthcare—both their health outcomes and the total costs of their care.
+Added: The PMPM payment varies based on the geography where members live, the health needs and risks of the population we serve, and the quality performance of our plans based on CMS Star Ratings.
+Added: Most members enroll with Alignment for a one-year period that can be renewed annually.
+Added: Because a large majority of our members choose to stay with Alignment after their initial selection year, this model provides meaningful visibility into our short-term financial performance and supports long-term stability and growth.
+Added: We have grown Health Plan Membership, which we define as members enrolled in our health maintenance organization ("HMO") and preferred provider organization ("PPO") contracts (the "Alignment Health Plan"), from approximately 13,000 at inception to 236,300 as of December 31, 2025, representing a 30% compound annual growth rate.
+Added: For the 2025 plan year, Alignment offered Medicare Advantage plans in 45 markets across California (22 markets), North Carolina (16 markets), Nevada (2 markets), Arizona (3 markets) and Texas (2 markets).
+Added: These markets collectively include approximately 8.4 million Medicare-eligible seniors.
+Added: How the Medicare Advantage Model Works
+Added: Under Medicare Advantage’s capitated PMPM value-based payment model, we are responsible for delivering and coordinating all covered healthcare services for our members.
+Added: This obligation includes hospital and physician care under Medicare Parts A and B, prescription drugs under Medicare Part D (with a separate PMPM payment from CMS), the supplemental benefits, such as dental and vision, we offer under certain of our plans, and related administration costs and services.
+Added: Unlike the original Medicare program administered by CMS, which we refer to herein as “Traditional Medicare,” which typically pays providers separately for each service delivered (i.e., “fee-for-service”), the Medicare Advantage program rewards value rather than volume.
+Added: By taking responsibility for the overall cost and quality of care for our members, plans like Alignment are incentivized to focus on prevention, care coordination and timely intervention.
+Added: We meet this challenge by providing proactive, cross-disciplinary care
+Added: targeted at reducing avoidable emergency room visits, managing and promoting access to high-value prescription drugs and supporting care transitions after hospital stays, all of which can reduce the need for more expensive institutional treatments and services.
+Added: The Medicare Advantage regulatory framework is designed to reward plans that achieve the triple aim of high-quality care, low costs and better experience.
+Added: CMS payments to Medicare Advantage plans are allocated in each county or region based on a bidding system.
+Added: Each year, Medicare Advantage plans submit bids based on estimated costs per enrollee for services covered under Medicare Parts A and B.
+Added: CMS compares those bids to local, county-level benchmarks that reflect what it would cost Traditional Medicare to cover the same population.
+Added: Plans that have a lower cost structure and are able to deliver care more efficiently generate savings, a portion of which is returned to the plan in the form of rebates with the remainder accruing to CMS and the federal government.
+Added: These savings allow high-performing plans to offer enhanced supplemental benefits—such as lower cost sharing, $0 premium Part D coverage, and additional supplemental services—at no additional cost to the senior.
+Added: CMS also evaluates Medicare Advantage plans through a Five Star Quality Rating System, which measures clinical outcomes, patient experience, and operational performance.
+Added: Medicare Advantage plans with higher Star Ratings receive additional economic incentives and payments.
+Added: In practice, this means that only plans that consistently deliver better care and better member experience at lower cost can sustainably offer richer benefits and grow membership on a long-term basis.
+Added: Our Differentiated Model:
+Added: Approach Medicare Advantage as a Care Management Business and Lower Costs by Delivering More Care
+Added: We approach Medicare Advantage as a care management business.
+Added: Unlike traditional health insurers, which rely heavily on actuarially underwriting and administrative and medical management tools like prior authorization, our model and core competencies emphasize clinical excellence, data-driven and evidence-based decision making and active care management.
+Added: This approach is designed to reduce friction for seniors and providers, improve the quality of our member experience and improve health outcomes for our members, particularly for those with multiple chronic conditions.
+Added: We have invested heavily in care delivery for our members, with more than 450 full-time clinical employees comprising approximately 25% of our full-time workforce.
+Added: By insourcing certain components of care delivery, identifying health issues earlier, supporting members between doctor visits and intervening quickly when health risks arise, we aim to reduce hospitalizations, shorten lengths of stay and improve post-discharge follow up—lowering costs across the enterprise while improving quality of care.
+Added: In short, we focus on providing more care, not less, to our chronic and high-risk members to achieve superior results.
+Added: Our care model is built around a scalable, capital-efficient, hybrid approach that combines virtual care with in-home services.
+Added: Through multichannel communications, we engage our members in ways that are most convenient and effective for them.
+Added: Because this hybrid approach does not rely on capital-intensive brick-and-mortar operations, it minimizes start-up costs and enables us to efficiently manage care across both dense urban markets and lower population density geographies.
+Added: Aligning Incentives Across the Healthcare Ecosystem
+Added: In acting as both the payor and active care manager, we believe that Alignment is uniquely positioned to align incentives across stakeholders and the healthcare ecosystem.
+Added: This includes:
+Added: We support better health through proactive chronic care management and targeted clinical intervention, delivered by our in-home clinical teams, a key feature of our model which we refer to as Care Anywhere .
+Added: We enrich the quality of life of our seniors by offering supplemental benefits such as gym access and fitness programs, caregiver services and support and non-emergency transportation.
+Added: And we create a premium member experience through our 24/7 concierge member services.
+Added: • Providers :
+Added: We work to empower—not compete with—community physicians by supplementing their care with additional clinical resources at no cost to the provider.
+Added: When improved outcomes lead to lower costs, we share in the upside through surplus gainsharing arrangements with providers.
+Added: And we align incentives while helping providers grow and retain patient panels through our strong product offerings and high CMS Star Ratings.
+Added: We believe our investments in member experience and clinical outcomes create satisfied seniors, reducing friction during annual enrollment and renewal process.
+Added: Stable benefit designs and consistently strong Star Ratings enable brokers to grow confidently with our products.
+Added: And the high and consistent Star Ratings of our plans support brokers’ sales efforts to new members.
+Added: By emphasizing prevention, care coordination, and timely intervention, we help reduce costly downstream hospital visits and utilization and overall health care spending.
+Added: We aim to advance CMS’s goals of better care for individuals, better health for populations, and lower system-wide costs and reduced costs for taxpayers.
+Added: Our Clinical Model:
+Added: Proactively Managing Member Care to Improve Outcomes and Reduce Cost
+Added: We engage regularly with members as part of their daily lives and proactively manage their chronic conditions to improve outcomes and reduce cost.
+Added: Our clinical model is designed specifically for seniors and managed across multiple disciplines (medical, social, psychological, pharmaceutical and functional) and sites of care (home, inpatient, outpatient, virtual and others).
+Added: Our internal care teams and external providers use AVA, our proprietary technology platform, to coordinate high-quality care for members and manage the complexity of the healthcare system.
+Added: Given the prevalence of comorbidities within our chronically ill members, coordination across a multi-disciplinary care team is vital to providing a medical and behavioral care plan that drives improved outcomes.
+Added: Our care delivery model creates a highly personalized experience that is unique to each member.
+Added: Using insights from AVA, we organize members into four categories to provide optimized care:
+Added: healthy, healthy utilizer, pre-chronic and chronic.
+Added: The data below represents a sample of our population stratification from 2025.
+Added: The typical member in the “healthy” category requires low levels of medical care.
+Added: Healthy members comprise approximately 74% of our membership base but account for only 5% of the institutional claims submitted.
+Added: Healthy Utilizer :
+Added: The typical member in the “healthy utilizer” category is an otherwise healthy senior who has had isolated or unexpected health challenges requiring significant medical care.
+Added: Healthy utilizers comprise approximately 6% of our membership base and account for 16% of the institutional claims submitted.
+Added: Pre-Chronic :
+Added: The typical member in the “pre-chronic category” is identified as high-risk by AVA but has yet to incur significant healthcare expenditures.
+Added: We also refer to these members as on the “launching pad,” and by deploying our targeted care programs towards this population we work to prevent or slow their increasing acuity levels.
+Added: Pre-chronic members comprise approximately 6% of our membership but account for only 1% of the institutional claims submitted.
+Added: Our active approach to monitoring gaps in care and acting before emerging health problems worsen is reflective of the culture of care embedded in our organization, and our focus on being a persistent advocate for our members.
+Added: The typical member in the “chronic” category is generally a complex patient with multiple chronic conditions in need of significant, coordinated care.
+Added: Chronic members comprise 14% of our membership but account for 78% of the institutional claims submitted.
+Added: Care Anywhere:
+Added: Proactive, Coordinated Care Delivers Results
+Added: While the majority of healthy and healthy utilizer members’ care needs are managed by our network of local community providers in conjunction with our support and oversight, our pre-chronic and chronic members are in our Care Anywhere program.
+Added: Care Anywhere is an advanced clinician-driven model of care that is staffed by Alignment-employed physicians, advanced practice clinicians, case managers, social workers and behavioral health coaches to assure execution of cross-functional care plans.
+Added: Unlike many managed care plans, we have built these services in-house to provide valuable, high-quality care to members for free, which complement the care provided by our provider partners for their most challenging and resource-intensive patients.
+Added: Key features of the Care Anywhere program include proactive outreach;
+Added: highly detailed personalized care plans;
+Added: and enhanced coordination of care and social needs.
+Added: Standardized care programs are targeted to seniors based on their underlying conditions, such as chronic heart failure or chronic obstructive pulmonary disorder, which are then personally tailored based on each individual’s underlying circumstances.
+Added: We proactively engage with this high-risk group of seniors based on their preferences for care delivery, which is typically in their homes or through telephonic and video consultations.
+Added: We believe, based on data gathered and analyzed using AVA, that our Care Anywhere program creates several benefits for our high-risk, complex members:
+Added: improved quality of life, high patient satisfaction, reductions in unnecessary emergency room visits and inpatient care, and lower re-admission rates.
+Added: This also allows us to establish a more direct relationship with seniors, building member loyalty and brand recognition.
+Added: Alignment’s Virtuous Cycle Aims to Enable Strong Membership Growth while Expanding Margins
+Added: Our model is based on a flywheel concept, referred to as our “virtuous cycle”.
+Added: This cycle is a reflection of our differentiated model designed to manage care to reduce healthcare expenditures to lower costs.
+Added: These cost savings are then reinvested back into our product benefits for our seniors to drive above-industry-average membership growth while managing our margin objectives.
+Added: We believe this is a distinct and sustainable competitive advantage.
+Added: To execute upon this concept, we ingest medical and demographic data through our proprietary technology platform, which we refer to as AVA.
AVA’s predictive algorithms provide unique insights into each member and identify those most at risk of an acute event.
5 unchanged sentences
Our virtuous cycle, based on the principle of doing well by doing good, is highly repeatable and a core tenet of our ability to continue to expand in existing and new markets in the future.
−Removed: The five-year compounded growth rate through December 31, 2024 of revenue and the number of members enrolled in our HMO and PPO contracts ("Health Plan Membership") is 29% and 31%, respectively.
−Removed: Predictable, Recurring Revenue Positioned for Long-Term Growth
−Removed: To achieve our mission of improving healthcare for one senior at a time, we have developed a business model with a predictable, recurring revenue stream that provides significant visibility into our financial growth trajectory.
−Removed: We generally contract directly with CMS as a licensed Medicare Advantage plan and receive a recurring per member per month (“PMPM”) payment in exchange for bearing the responsibility of our members’ healthcare outcomes and expenditures.
−Removed: These contractual arrangements, combined with the fact that the majority of our net membership growth occurs effective on January 1 of a calendar year after the annual enrollment period (“AEP”), provide a higher degree of visibility to our full-year projected revenue early in the calendar year, subject to our ability to model for in-year member growth, as well as revenue PMPM, which in turn depends on member health and mortality trends.
−Removed: We believe that Medicare Advantage is unique in that it allows one entity to influence the entirety of a senior’s healthcare through a single, direct-to-consumer product.
−Removed: Our platform is designed to maximize the benefits of Medicare Advantage, with all stakeholders being rewarded as we improve the clinical outcomes and experience for our members.
−Removed: We believe that the outcomes below clearly demonstrate the success of our unique consumer-centric platform by delivering on the promise of our virtuous cycle.
−Removed: Our ability to deliver lower healthcare costs while improving the consumer’s experience is a unique competitive advantage.
−Removed: In 2024, we achieved a net promoter score (NPS) for our Care Anywhere members of greater than 78 versus the industry average of 40 and had 98% of our members enrolled in a plan with a CMS star rating of 4 stars or above.
−Removed: From a clinical standpoint, we achieved a hospitalization rate of approximately 152 hospitalizations per every 1,000 at-risk members, which is approximately 39% lower than the 2019 Medicare FFS performance in our markets.
−Removed: This differentiation has led to our demonstrated ability to rapidly scale, as evidenced by the expansion
−Removed: of our model to 53 markets across five states covering approximately 209,900 Health Plan Members as of January 1, 2025 and more than 83% of gross sales sourced through plan switchers from a competing Medicare Advantage plan.
−Removed: We believe we have proven that our model is highly predictable and repeatable across different markets and will enable strong growth on a national level as we pursue our vision of becoming the most trusted senior healthcare brand in the country.
−Removed: We anticipate further investments in our business as we expand into new markets and continue to offer additional innovative product offerings and supplemental benefits to attract new members.
+Added: The five-year compounded growth rate through December 31, 2025 of our revenue and Health Plan Membership is 36% and 29%, respectively.
Our Technology:
33 unchanged sentences
From driving workflows to enabling smarter interventions, we believe AVA is a significant competitive advantage that allows us to deliver information-enabled healthcare at scale.
−Removed: Our Clinical Model:
−Removed: Proactively Managing Member Care to Improve Outcomes and Reduce Cost
−Removed: We engage regularly with members as part of their daily lives and proactively manage their chronic conditions to improve outcomes and reduce cost.
−Removed: Our clinical model is designed specifically for seniors and is managed across multiple disciplines (medical, social, psychological, pharmaceutical and functional) and sites of care (home, inpatient, outpatient, virtual and others).
−Removed: Our internal care teams and external providers use AVA to coordinate high-quality care for members and manage the complexity of the healthcare system.
−Removed: Given the prevalence of comorbidities within our chronically ill members, coordination across a multi-disciplinary care team is vital to providing a medical and behavioral care plan that drives improved outcomes.
−Removed: Our care delivery model creates a highly personalized experience that is unique to each member.
−Removed: Using insights from AVA, we organize members into four categories to provide optimized care:
−Removed: healthy, healthy utilizer, pre-chronic and chronic.
−Removed: The data below represents a sample of our population stratification from 2024.
−Removed: The typical member in the “healthy” category requires low levels of medical care.
−Removed: Healthy members comprise approximately 71% of our membership base but account for only 5% of the institutional claims submitted.
−Removed: Healthy Utilizer :
−Removed: The typical member in the “healthy utilizer” category is an otherwise healthy senior who has had isolated or unexpected health challenges requiring significant medical care.
−Removed: Healthy utilizers comprise approximately 8% of our membership base and account for 16% of the institutional claims submitted.
−Removed: Pre-Chronic :
−Removed: The typical member in the “pre-chronic category” is identified as high-risk by AVA but has yet to incur significant healthcare expenditures.
−Removed: We also refer to these members as on the “launching pad,” and by deploying our targeted care programs towards this population we work to prevent or slow their increasing acuity levels.
−Removed: Pre-chronic members comprise approximately 8% of our membership but account for only 1% of the institutional claims submitted.
−Removed: Our active approach to monitoring gaps in care and acting before emerging health problems worsen is reflective of the culture of care embedded in our organization, and our focus on being a persistent advocate for our members.
−Removed: The typical member in the “chronic” category is generally a complex patient with multiple chronic conditions in need of significant, coordinated care.
−Removed: Chronic members comprise 13% of our membership but account for 78% of the institutional claims submitted.
−Removed: Care Anywhere:
−Removed: Proactive, Coordinated Care Delivers Results
−Removed: While the majority of healthy and healthy utilizer members’ care needs are managed by our network of local community providers in conjunction with our support and oversight, our pre-chronic and chronic members are in our Care Anywhere program.
−Removed: Care Anywhere is an advanced clinician-driven model of care that is staffed by Alignment-employed physicians, advanced practice clinicians, case managers, social workers and behavioral health coaches to assure execution of cross-functional care plans.
−Removed: Unlike many managed care plans, we have built these services in-house to provide valuable, high-quality care to members for free, which complement the care provided by our provider partners for their most challenging and resource-intensive patients.
−Removed: Key features of the Care Anywhere program include proactive outreach;
−Removed: highly detailed personalized care plans;
−Removed: and enhanced coordination of care and social needs.
−Removed: Standardized care programs are targeted to seniors based on their underlying conditions, such as chronic heart failure or chronic obstructive pulmonary disorder, which are then personally tailored based on each individual’s underlying circumstances.
−Removed: We proactively engage with this high-risk group of seniors based on their preferences for care delivery, which is typically in their homes or through telephonic and video consultations.
−Removed: We believe, based on data gathered and analyzed using AVA, that our Care Anywhere program creates several benefits for our high-risk, complex members:
−Removed: improved quality of life, high patient satisfaction, reductions in unnecessary emergency room visits and inpatient care, and lower re-admission rates.
−Removed: This also allows us to establish a more direct relationship with seniors, building member loyalty and brand recognition.
−Removed: Our Care Anywhere program has an NPS score greater than 78, underscoring the positive impact it has on our most vulnerable members.
−Removed: Our collective investment in our care model and technology platform has produced strong clinical outcomes for our seniors.
−Removed: In 2024, we achieved a hospitalization rate of approximately 152 hospitalizations per every 1,000 at-risk members, which is approximately 39% lower than the 2019 Medicare FFS performance in our markets.
−Removed: Further, we have achieved approximately 152-159 inpatient admissions per thousand on our at-risk membership for the last seven years in a row, despite our significant membership growth over that period of time.
Our operations and those of our affiliated entities are subject to extensive federal, state and local governmental laws and regulations.
These laws and regulations require us to meet various standards relating to, among other things, reports to CMS, personnel qualifications, maintenance of proper records and quality assurance programs and patient care.
−Removed: The majority of our regulation and oversight comes from CMS, which regulates almost every aspect of our business, including our provider network, benefits, member enrollment, risk adjustment program, plan offerings, claims payments, quality improvement programs, and appeals and grievances.
−Removed: have entered into standard form agreements with CMS pursuant to Sections 1851 through 1859 and Sections 1860D-1 through 1860D-43 of the Social Security Act ("SSA"), pursuant to which we have agreed to operate our plans in accordance with applicable laws and regulations and CMS has agreed to make payments to us under the SSA.
+Added: The majority of our regulation and oversight comes from CMS, which regulates almost every aspect of our business, including our provider network, benefits, member
+Added: enrollment, risk adjustment program, plan offerings, claims payments, quality improvement programs, and appeals and grievances.
+Added: We have entered into standard form agreements with CMS pursuant to Sections 1851 through 1859 and Sections 1860D-1 through 1860D-43 of the Social Security Act ("SSA"), pursuant to which we have agreed to operate our plans in accordance with applicable laws and regulations and CMS has agreed to make payments to us under the SSA.
Each CMS contract has a one-year term expiring on December 31 of the applicable calendar year and is subject to annual one-year renewal terms.
26 unchanged sentences
Security and Protection
−Removed: We are subject to data privacy and protection and breach notification laws and regulations that apply to the collection, transmission, storage and use of protected health information (“PHI”), and other types of personal data or personally identifiable information (“PII”), which among other things, impose certain requirements relating to the privacy and security of such PII.
+Added: We are subject to data privacy and protection and breach notification laws and regulations that apply to the collection, creation, receipt, maintenance, transmission, storage, use, disclosure and processing of protected health information (“PHI”), and other types of personal data or personally identifiable information (“PII”), which among other things, impose certain requirements relating to the privacy and security of such PHI and PII.
The legislative and regulatory landscape for privacy and data protection continues to evolve, and there has been an increasing focus on privacy and data protection issues with the potential to affect our business.
−Removed: Failure to comply with any of these laws and regulations could result in enforcement action against us, including fines, public censure, claims for damages by affected individuals, damage to our reputation and loss of
+Added: Failure to comply with any of these laws and regulations could result in enforcement action against us, including fines, public censure, claims for damages by affected individuals, damage to our reputation and loss of goodwill.
Ongoing efforts to comply with evolving laws and regulations may be costly and require ongoing modifications to our policies, procedures and systems.
5 unchanged sentences
These regulations, in addition to other state laws, set standards for the security of electronic health information, including requirements that insurers provide customers with notice regarding how their individually identifiable health information is used.
−Removed: The US Department of Health and Human Services, Office for Civil Rights announced on December 27, 2024, and published in the Federal Register on January 6, 2025, a Notice of Proposed Rulemaking proposing extensive modifications to the HIPAA security standards.
+Added: The US Department of Health and Human Services, Office for Civil Rights ("OCR") announced on December 27, 2024, and published in the Federal Register on January 6, 2025, a Notice of Proposed Rulemaking proposing extensive modifications to the HIPAA security standards.
+Added: OCR’s Spring 2025 Unified Regulatory Agenda lists the proposed rule at the “Final Rule Stage”, with final action scheduled for May 2026.
If finalized, these modifications and could entail significant additional compliance obligations and costs for HIPAA-regulated covered entities and business associates.
HIPAA imposes mandatory penalties for certain violations.
−Removed: In 2024, penalties for violations of HIPAA and its implementing regulations started at $141 per violation and could not exceed approximately $71,162 per violation, subject to a cap of approximately $2.1 million for violations of the same standard in a single calendar year.
−Removed: However, a single breach incident can result in violations of multiple standards.
−Removed: The penalty amounts listed above are also due for inflation adjustments in 2025.
−Removed: HIPAA also authorizes state attorneys general to file suit on behalf of their residents for statutory damages of up to $25,000.
+Added: In 2026, penalties for violations of HIPAA and its implementing regulations started at $145 per violation and could not exceed approximately $73,011 per violation, subject to a cap of approximately $2.2 million for violations of the same standard in a single calendar year.] However, a single breach incident can result in violations of multiple standards.
+Added: HIPAA also authorizes state attorneys general to file suit on behalf of their residents for violations of HIPAA.
While HIPAA does not create a private right of action allowing individuals to sue in civil court for violations of HIPAA, its standards have been used as the basis for duty of care in state civil suits such as those for negligence or recklessness in the misuse or breach of PHI.
3 unchanged sentences
HIPAA specifies that such notifications must be made without unreasonable delay and in no case later than 60 calendar days after discovery of the breach.
−Removed: If a breach affects 500 patients or more, it must be reported to HHS without unreasonable delay, and HHS will post the name of the breaching entity on its public website.
−Removed: Breaches affecting more than 500 patients in the same state or jurisdiction must also be reported to the local media.
−Removed: If a breach involves fewer than 500 people, the covered entity must record it in a log and notify HHS at least annually.
+Added: If a breach affects 500 individuals or more, it must be reported to HHS without unreasonable delay, and HHS will post the name of the breaching entity on its public website.
+Added: Breaches affecting more than 500 individuals in the same state or jurisdiction must also be reported to the prominent media outlets serving the state or jurisdiction.
+Added: If a breach involves fewer than 500 individuals, the covered entity must record it in a log and notify HHS at least annually.
We also publish statements to our members and partners that describe how we handle and protect PHI.
2 unchanged sentences
For example, California’s California Consumer Privacy Act of 2018 (“CCPA”), which came into effect on January 1, 2020, has since been amended by the California Privacy Rights Act (“CPRA”), which became effective on January 1, 2023 and began enforcement on July 1, 2023.
−Removed: The CCPA, as amended by the CPRA, expands on the existing rights provided to California residents and will include rights to know, delete, correct, personal information;
+Added: The CCPA, as amended by the CPRA, expands on the existing rights provided to California residents and includes rights to know, delete and correct personal information;
limit the use of sensitive personal information;
and opt out of the sale of personal information or the sharing of personal information with third parties for purposes of cross-context behavioral advertising.
−Removed: There are also requirements for data processing and cybersecurity assessments, and contracting requirements for service providers, third parties, and contractors who receive and process information from the regulated “business.” The CPRA amendment created a state agency, the California Privacy Protection Agency (“CPPA”), to enforce and implement the law.
+Added: There are also requirements for privacy risk and cybersecurity assessments, and contracting requirements for service providers, third parties, and contractors who receive and process personal information from the regulated “business.” The CPRA amendment created a state agency, the California Privacy Protection Agency (“CPPA”), to enforce and implement the law.
This agency will be able to finance operations through penalties issued and, with the CPRA’s removal of the mandatory cure period from the CCPA, we will have less warning before compliance risk results in legal action.
−Removed: Additionally, the CCPA’s exemption for personal information of personnel (including employees, job applicants, officers, and directors) and business-to-business contacts has been allowed to sunset.
−Removed: As a result, beginning on January 1, 2023, personal information of California resident personnel and business contacts became subject to the CCPA.
+Added: Additionally, the CCPA’s exemption for personal information of personnel (including employees, job applicants, officers, and directors) and business-to-business contacts expired.
+Added: As a result, since January 1, 2023, personal information of California resident personnel and business contacts has been subject to the CCPA.
This has created compliance obligations for our operations.
−Removed: The CCPA and CPRA contain exemptions for medical information governed by the California Confidentiality of Medical Information Act, and for PHI collected by a covered entity or business associate governed by the privacy, security, and breach notification rule established pursuant to HIPAA.
+Added: The CCPA contains exemptions for medical information governed by the California Confidentiality of Medical Information Act, and for PHI collected by a covered entity or business associate governed by the privacy, security, and breach notification rule established pursuant to HIPAA.
This exempts much of the data we process with respect to patients and plan members.
−Removed: The CCPA has prompted a number of proposals for new federal and state-level privacy legislation.
−Removed: Such proposed legislation, if enacted, may add additional complexity, variation in requirements, restrictions and potential legal risk, require additional investment of resources in compliance programs, impact strategies and the availability of previously useful data and could result in increased compliance costs
−Removed: and/or changes in business practices and policies.
−Removed: For example, the Virginia Consumer Data Protection Act, which became effective January 1, 2023, gives Virginia residents expanded rights to access and creates additional obligations on companies covered by the legislation and the Nevada Privacy Law, which became effective on October 1, 2019, requires businesses to give website users the option to opt-out of the sale of their data.
−Removed: State privacy laws also became effective in 2024 in Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, and Texas and have or will become effective in 2025 in Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, and Maryland.
+Added: The CCPA prompted the passage of "copycat" legislation in a number of states.
+Added: It also prompted passage of consumer privacy laws that protect consumer health data specifically, such as the Washington My Health My Data Act.
These state laws generally exempt HIPAA regulated covered entities and business associates, PHI, and/or personal information collected in the context of employment and business-to-business relationships.
−Removed: While the CPRA/CCPA is an example of consumer privacy law, the NAIC’s Insurance Data Security Model Law (the “Model Law”) is a different type of law focused on securing insurance licensees’ information systems.
+Added: However, this patchwork of state laws may add further complexity, variation in requirements, restrictions and potential legal risk, require additional investment of resources in compliance programs, impact strategies and the availability of previously useful data and could result in increased compliance costs and/or changes in business practices and policies.
+Added: While the CCPA is an example of consumer privacy law, the NAIC’s Insurance Data Security Model Law (the “Model Law”) is a different type of law focused on securing insurance licensees’ information systems.
Versions of this Model Law have been passed in many states and are expected to be passed in more states in the coming years.
11 unchanged sentences
Compliance with HIPAA and other privacy regulations requires significant and ongoing systems enhancements, training and administrative effort.
−Removed: See “ Risk Factors — Security breaches, loss of data and other disruptions could compromise sensitive information related to our business or our members, or prevent us from accessing critical information and expose us to liability, which could adversely affect our business and our reputation .”
+Added: See “ Risk Factors — Cybersecurity breaches, loss of data and other disruptions could compromise sensitive information related to our business or our members, or prevent us from accessing critical information and expose us to liability, which could adversely affect our business and our reputation .”
Our business and operations may also be subject to federal, state, and local consumer protection laws governing marketing communications, including the Telephone Consumer Protection Act (“TCPA”), which places restrictions on the use of automated tools and technologies to communicate with wireless telephone subscribers or communications services consumers generally and the CAN-SPAM Act, which regulates the transmission of marketing emails.
−Removed: In addition, certain of our businesses are also subject to the Payment Card Industry Data Security Standard (“PCI DSS”), which is a multifaceted industry security standard that is designed to protect credit card account data as mandated by payment brands and acquiring banks.
+Added: In addition, certain of our businesses are also subject to the Payment Card Industry Data Security Standard (“PCI DSS”), which is a multifaceted industry security standard that is designed to protect credit and debit card account data as mandated by payment brands and acquiring banks.
The Health Care Reform Law and Other Current or Future Legislative, Judicial or Regulatory Changes
6 unchanged sentences
As a corporate entity, we are not licensed to practice medicine.
−Removed: Many states in which we operate through our subsidiaries limit the practice of medicine to licensed individuals or professional organizations comprised of licensed individuals, and business corporations generally may not exercise control over the medical decisions of physicians.
+Added: Many states in which we operate through our subsidiaries limit the practice of medicine to licensed individuals or professional organizations exclusively owned and comprised of licensed individuals, and business corporations generally may not exercise control over the medical decisions of licensed physicians or other licensed clinicians.
Statutes, regulations and court decisions relating to the practice of medicine, fee-splitting between physicians and referral sources, and similar issues vary widely from state to state.
+Added: In addition, various state laws also generally prohibit the sharing of professional services income with nonprofessional or business interests.
The laws and regulations in these areas are complex, changing, and often subject to varying interpretations.
1 unchanged sentence
Under business support agreements between certain of our subsidiaries and associated physician-owned professional groups, these groups retain sole responsibility for all medical decisions, as well as for hiring and managing physicians and other licensed healthcare providers, developing operating policies and procedures, implementing professional standards and controls, and maintaining malpractice insurance.
+Added: Recently, Oregon and California have passed laws codifying and strengthening their existing corporate practice of medicine prohibitions in ways which may require us to adjust contractual arrangements with our affiliated physician-owned professional groups, and we are aware of a number of other states considering similar legislation.
We, our in-house and externally engaged physicians and the facilities in which they operate are subject to various federal, state and local licensing and certification laws and regulations and accreditation standards and other laws, relating to, among other things, the adequacy of medical care, equipment, privacy of member information, physician relationships, personnel and operating policies and procedures.
6 unchanged sentences
Accordingly, neither we nor our direct subsidiaries directly own any equity interests in any of our associated physician practices.
+Added: Further, the enforceability of such equity transfer restriction agreements has been called into question by state courts and regulators in New Jersey, New York, California, and Oregon.
+Added: The invalidation of our transfer restriction agreements in such states may have a detrimental effect on our relationship with our affiliated physician-owned professional entities.
Anti-Kickback, Physician Self-Referral and Other Fraud and Abuse Laws
18 unchanged sentences
Certain of our licensed insurance subsidiaries are also subject to regulation under state insurance holding company regulations.
−Removed: These regulations generally require, among other things, prior approval and/or notice of new products, rates, benefit changes, and certain material transactions, including dividend payments, purchases or sales of assets, intercompany agreements, and the filing of various financial and operational reports.
+Added: These regulations generally require, among other things, prior approval and/or notice of new products, rates, benefit changes, and certain
+Added: material transactions, including dividend payments, purchases or sales of assets, intercompany agreements, and the filing of various financial and operational reports.
The amount of dividends that may be paid to us by these insurance subsidiaries, without prior approval by state regulatory authorities, or ordinary dividends, is limited based on the entity’s level of statutory income and statutory capital and surplus.
31 unchanged sentences
• regulatory compliance
−Removed: Environmental, Social and Governance and Human Capital
−Removed: Environmental, Social and Governance
−Removed: We are committed to implementing meaningful environmental, social, and governance (“ESG”) practices.
−Removed: Our goal is to drive sustainable business growth while balancing our responsibilities to shareholders, employees, members, and the greater community.
−Removed: The three pillars to our ESG approach are the following:
−Removed: • Serving People – Our employees are our most valuable asset, and we are dedicated to providing them with a safe, diverse, and inclusive workplace.
−Removed: See “— Employees and Human Capital Resources ” below.
−Removed: We are also dedicated to serving our members with the utmost care and concern for their safety and health and strive to support our health care providers with the tools and resources needed to provide the best care.
−Removed: • Serving the Environment – Our company is focused on reducing its carbon footprint by implementing energy-efficient practices, reducing water and waste, and exploring renewable energy sources.
−Removed: • Serving Responsibly – We are committed to maintaining a high level of transparency and accountability across our operations.
−Removed: Our Board of Directors includes a strong and diverse mix of experienced business leaders and is committed to providing effective oversight of the Company’s activities.
−Removed: In 2022, we released our inaugural ESG report and created an ESG Steering Committee comprised of cross-functional leaders representing every department within the Company.
−Removed: Our aim is to continue fortifying each pillar and to operate with transparency in a way that always puts seniors first, and respects all people, communities, conditions, and environments.
+Added: Corporate Responsibility
+Added: We are committed to creating positive, measurable outcomes for our members, employees, communities, and shareholders.
+Added: Our approach integrates responsible governance, ethical operations, and disciplined risk management with actions that improve health outcomes, enhance access and affordability, support our workforce, and strengthen the communities we serve.
+Added: We believe that delivering long-term value requires aligning our business strategy with the impact we have on people and society.
+Added: Guided by our core value of leading with a serving heart, we have established five impact priorities through 2025:
+Added: • Serving Members – Proactively provide all members with access to high-quality, low-cost care and support healthier communities.
+Added: • Serving Health Care Providers – Enable better care through improved access to data, tools, and resources.
+Added: • Serving our Employees - Foster engagement, ownership and a sense of belonging.
+Added: • Serving Consciously - Understand and improve the impact of our operations on the communities we serve.
+Added: • Serving Responsibly - Maintain effective, transparent and ethical governance.
+Added: We publish an annual Impact Report highlighting progress against these priorities.
+Added: Oversight is provided through collaboration among senior leadership, the CEO, and the Board of Directors.
Employees and Human Capital Resources
−Removed: We are focused on building a company that is transforming health care by putting seniors first, and our employees are critical to our success.
+Added: We are focused on building a company that is transforming health care by putting seniors first, and our employees are critical to our distinctive business model.
Our Human Capital strategy focuses on meeting business objectives by attracting, developing, engaging, and retaining a high-performing, diverse workforce.
As of December 31, 2025, we had 1,849 full-time employees in addition to seasonal employees who assist with the Medicare AEP.
−Removed: Each year, we conduct an employee survey to further enhance employee engagement and productivity.
−Removed: We also implement rigorous employee training protocols to help ensure our teams operate with rigor, ethics and compliance in mind.
We recognize that an inclusive workplace is crucial as we scale and build our high-performing team.
12 unchanged sentences
A key component of our corporate sustainability and success is learning and development.
+Added: Each year, we conduct an employee survey and take action to further enhance employee engagement and productivity.
+Added: We also implement rigorous employee training protocols to help ensure our teams operate with rigor, ethics and compliance in mind.
We are intentional in our efforts to provide all employees opportunities to grow.
Our training and development programs for employees focus on enhancing and developing talent within the company.
−Removed: All of our employees can access the training of their choice on-demand through our learning and development platform.
+Added: All employees have access to on‑demand training through our learning and development platform, which supports scalable capability-building across functional, leadership, compliance, and digital skills.
We are currently designing additional training programs and resources for both new hires and longer-tenured employees that will educate them on critical functional areas of within the organization.
9 unchanged sentences
We were originally formed as a Delaware limited liability company under the name Alignment Healthcare Holdings, LLC in 2013.
−Removed: In March 2021, we completed the Corporate Conversion and Corporate Reorganization and changed our name to Alignment Healthcare, Inc.
−Removed: During the same month, we completed our initial public offering and our common stock began trading on the Nasdaq Global Select Market under the symbol “ALHC.”
+Added: In March 2021, we completed a corporate restructuring in connection with our initial public offering (“IPO”) changed our name to Alignment Healthcare, Inc.
+Added: Following the IPO, our common stock began trading on the Nasdaq Global Select Market under the symbol “ALHC.”
Our principal executive office is located at 1100 W.
1 unchanged sentence
Our website address is www.alignmenthealth.com.
−Removed: The information contained on, or that can be accessed through, our website is not incorporated by reference into this filing and you should not consider any information contained on, or that can be
−Removed: accessed through, our website as part of this filing.
+Added: The information contained on, or that can be accessed through, our website is not incorporated by reference into this filing and you should not consider any information contained on, or that can be accessed through, our website as part of this filing.
We are a holding company and all of our business operations are conducted through our subsidiaries and affiliated medical groups.
2 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.