−Removed: The Cigna Group SM , together with its subsidiaries (either individually or collectively referred to as the "Company," "we," "us" or "our"), is a global health company.
−Removed: Our Purpose and Mission
+Added: The Cigna Group ® , together with its subsidiaries (either individually or collectively referred to as the "Company," "we," "us" or "our"), is a global health company.
+Added: Our Focused Mission
The Cigna Group is a global health company committed to creating a better future for every individual and every community.
−Removed: We relentlessly challenge ourselves to partner and innovate solutions for better health.
−Removed: Powered by our people and our brands, we advance our mission to improve the health and vitality of those we serve.
−Removed: Our Pathways to Growth
−Removed: To deliver differentiated value to our customers, patients, clients, communities and investors, we will continue to cultivate our portfolio of businesses to provide sustained foundational and accelerated growth through cross-enterprise leverage - today and in the future.
−Removed: Our Differentiated Approach
−Removed: • Clinical expertise and longitudinal data provide enhanced care and value.
−Removed: • Relentless focus on value and affordability improves the cost of care for our clients and customers.
−Removed: • Culture of innovation and partnership brings new services and capabilities to market.
−Removed: At The Cigna Group, we relentlessly challenge ourselves to partner and innovate solutions for better health.
−Removed: Our global workforce of approximately 73,500 colleagues strives to fulfill our mission to improve the health and vitality of approximately 182 million customer and patient relationships in more than 30 countries and jurisdictions (as of December 31, 2024).
−Removed: We have two growth platforms:
+Added: Powered by our dedicated people and valued brands, we advance our mission to improve the health and vitality of those we serve by staying grounded in the needs of our customers and patients - delivering a personalized, transparent and affordable health care experience.
+Added: We focus on leading the way to partner and innovate solutions for better health.
+Added: At The Cigna Group our global workforce of approximately 67,700 colleagues strives to fulfill our mission to improve the health and vitality of more than 185 million customer relationships in more than 30 markets and jurisdictions (as of December 31, 2025).
+Added: We play an important role in the health care system, and the breadth and depth of our customer relationships - as well as our approximately 1.7 million relationships with health care providers, clinics and facilities - give us opportunities to drive positive change.
+Added: We have two segments:
Evernorth Health Services ® and Cigna Healthcare ® .
−Removed: Evernorth Health Services, through our Pharmacy Benefit Services and Specialty and Care Services operating segments, provides independent and coordinated health solutions and capabilities to enable the health care system to work better and help people live richer, healthier lives.
−Removed: In addition to serving a wide variety of clients, Evernorth Health Services also enables us to deepen existing relationships across our entire book of business.
−Removed: Cigna Healthcare is the health benefits segment of The Cigna Group and serves customers and clients for our U.S.
+Added: The Evernorth Health Services segment, through our Pharmacy Benefit Services and Specialty and Care Services operating segments, provides independent and coordinated health solutions and capabilities to enable the health care system to work better and help people live healthier lives.
+Added: Cigna Healthcare, the health benefits segment of The Cigna Group, provides comprehensive medical and coordinated solutions to customers and clients served by our U.S.
Healthcare and International Health operating segments.
−Removed: Together, Evernorth Health Services and Cigna Healthcare provide a strong and diverse foundation that allows us to capitalize on growth opportunities by leading with our strengths – pharmacy and medical solutions – and then expanding those relationships by addressing additional client needs and innovating and delivering new services and solutions.
−Removed: When considering our broad portfolio of businesses, we have strong foundational businesses that we expect to continue to grow.
−Removed: These businesses often serve as the key entry point for clients with either a pharmacy relationship, a medical relationship or both.
−Removed: We also have accelerated growth businesses, both scaled and emerging, which build upon our foundational relationships or provide exposure to adjacent high-growth areas.
−Removed: Evernorth Health Services and Cigna Healthcare work together to enable cross-enterprise leverage by uniquely using the depth and breadth of our wide-ranging capabilities across the enterprise to efficiently move from ideation to solution creation to meet clients' evolving needs while creating more value, expanding our reach and driving growth.
+Added: Together, Evernorth Health Services and Cigna Healthcare combine pharmacy and medical capabilities to create solutions that improve affordability, transparency and health outcomes.
+Added: This combination helps us anticipate needs, accelerate innovation and deliver personalized experiences for customers and patients at scale.
Information about Segments
−Removed: We present the financial results of our businesses in the following segments (see "Executive Overview" section of Management's Discussion and Analysis of Financial Condition and Results of Operations ("MD&A") located in Part II, Item 7 of this Form 10-K for a financial summary):
−Removed: Evernorth Health Services includes our Pharmacy Benefit Services and Specialty and Care Services operating segments, which provide independent and coordinated health solutions and capabilities to enable the health care system to work better and help people live richer, healthier lives.
−Removed: Cigna Healthcare includes the U.S.
−Removed: Healthcare and International Health operating segments, which provide comprehensive medical plan services and coordinated solutions to clients and customers.
+Added: We present the financial results of our businesses in the following segments (see the "Executive Overview" section of Management's Discussion and Analysis of Financial Condition and Results of Operations ("MD&A") located in Part II, Item 7 of this Form 10-K for a financial summary):
+Added: Evernorth Health Services includes our Pharmacy Benefit Services and Specialty and Care Services operating segments, which provide independent and coordinated health solutions and capabilities to enable the health care system to work better and help people live healthier lives.
+Added: Cigna Healthcare includes our U.S.
+Added: Healthcare and International Health operating segments, which provide comprehensive medical and coordinated solutions to clients and customers.
Other Operations comprises the remainder of our business operations, which includes certain continuing, run-off and other non-strategic businesses.
Corporate reflects amounts not allocated to operating segments, including net interest expense (defined as interest on corporate financing less net investment income on investments not supporting segment and other operations), certain litigation matters, expense associated with our frozen pension plans, charitable contributions, operating severance, certain overhead and enterprise-wide project costs, and eliminations for products and services sold between segments.
−Removed: See the "Executive Overview - Key Transactions and Business Developments" section of our MD&A located in Part II, Item 7 of this Form 10-K for discussion of key developments impacting the segments.
+Added: See the "Executive Overview - Key Transactions and Business Developments" section of our Management's Discussion and Analysis of Financial Condition and Results of Operations located in Part II, Item 7 of this Form 10-K for discussion of key developments impacting the segments.
+Added: Commitments to Better
+Added: Through our Commitments to Better, we embarked on a new, multiyear chapter to accelerate our ongoing evolution and industry leadership.
+Added: We know we play an important role in a health care system that needs changing for the better, and we are determined to lead that change for the health and vitality of those we serve.
+Added: We have many roles in the health care system to deliver better outcomes to our customers, including helping to make healthcare more affordable, administering health care claims and working to reduce health care waste.
+Added: The Cigna Group has established five key areas of focus, and several initial specific actions, to improve the health of its customers and increase the value it provides:
+Added: • Easier access to care:
+Added: address challenges customers face by making processes simpler, easier and faster.
+Added: • Better support:
+Added: provide customers with more support and resources to navigate the health care system.
+Added: • Better value:
+Added: drive better value for customers and patients.
+Added: • Accountability:
+Added: stand behind our commitments to our customers and patients.
+Added: • Transparency:
+Added: provide information on how we are continuously improving to serve our customers better.
Other Information
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EVERNORTH HEALTH SERVICES
−Removed: Evernorth Health Services includes our Pharmacy Benefit Services and Specialty and Care Services operating segments, which provide independent and coordinated health solutions and capabilities to enable the health care system to work better and help people live richer, healthier lives.
−Removed: Within Evernorth Health Services, Pharmacy Benefit Services is a foundational growth business, and Specialty and Care Services is an accelerated growth business.
−Removed: Evernorth Health Services offers a full suite of products and services that both (a) enables our customers to combine our products and services to create a comprehensive benefit offering designed to manage prescription drugs and provide independent and coordinated health solutions and capabilities and (b) addresses the needs of a shared customer base across both operating segments of Evernorth Health Services.
−Removed: Our ability to deliver this broad array of health care services on both a standalone or combined basis between its two operating segments enables us to drive incremental growth.
−Removed: Additionally, many Evernorth Health Services offerings are available within Cigna Healthcare solutions to drive cross-enterprise leverage.
+Added: Evernorth Health Services includes our Pharmacy Benefit Services and Specialty and Care Services operating segments, which provide independent and coordinated health solutions and capabilities to enable the health care system to work better and help people live healthier lives.
+Added: Evernorth Health Services offers a full suite of products and services that both (a) enables our clients to combine our products and services to create a comprehensive benefit offering designed to manage prescription drugs and provide independent and coordinated health solutions and capabilities and (b) addresses the needs of a shared customer base across both operating segments of Evernorth Health Services.
+Added: Our ability to deliver this broad array of health care services on either a standalone or combined basis between its two operating segments enables us to drive incremental growth.
+Added: Additionally, many Evernorth Health Services offerings are available within Cigna Healthcare solutions.
How We Deliver
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• Talented, experienced and caring people who operate in a culture of innovation and partnership to solve complex problems across a fragmented health care ecosystem, fueled by data and expertise that drives purposeful innovation.
+Added: • Commitment to improving the health care experience for patients and physicians through easier access to care, better support, better value, accountability and transparency.
Principal Products and Services
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◦ Drug Formulary Management.
−Removed: ▪ Formularies are lists of drugs with designations that may be used to determine drug coverage and customer out-of-pocket costs as well as communicate plan preferences in competitive drug categories.
+Added: ▪ Formularies are lists of drugs with designations that may be used to determine one component of drug coverage and customer out-of-pocket costs as well as communicate plan preferences in competitive therapeutic drug categories.
Our formulary management services support clients in establishing formularies that assist customers and physicians in choosing clinically appropriate, cost-effective drugs and prioritize access, safety and affordability.
−Removed: ▪ We administer specific formularies for our clients, including standard formularies developed by Express Scripts by Evernorth ® ("Express Scripts") and custom formularies in which we play a more limited role.
+Added: ▪ We administer specific formularies for our clients, including standard formularies developed by Express Scripts ® Pharmacy Benefit Services ("Express Scripts") and custom formularies in which we play a more limited role.
Many of our clients select standard formularies, governed by both internal and independent committees that make recommendations for formularies that first consider clinical results separate from price considerations.
−Removed: ▪ One of the ways we manage our drug formulary is through negotiating to secure additional affordability for the benefit of our clients based on the utilization of certain prescription drugs and supplies which can be paid to us in the form of a rebate.
−Removed: With respect to our clients' rebate arrangements, most choose to receive the greater of a minimum rebate guarantee or a contractually agreed-upon percentage of rebates.
+Added: ▪ We manage our clients' rebate arrangements, with most choosing to receive the greater of a minimum rebate guarantee or a contractually agreed-upon percentage of rebates.
In some rebate arrangements, Express Scripts takes on the risk of securing the rebate value necessary to meet the value guaranteed to its client.
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We offer a variety of solutions aimed at helping clients reduce costs and enhance clinical outcomes.
−Removed: These programs include SafeGuardRx ® , Express Scripts Copay Assurance SM , Express Scripts Patient Assurance ® and Evernorth EncircleRx SM .
+Added: These programs include SafeGuardRx ® , Express Scripts Patient Assurance ® , Evernorth EncircleRx SM and Evernorth EnReachRx SM .
◦ Evernorth Wholesale Marketplace.
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These offerings are captured under either our drug formulary administrative service arrangements or our formulary processing arrangements.
+Added: ◦ Transparent Rebate-free Model.
+Added: Evernorth Health Services has announced a transformative new pharmacy benefits model to make discounts negotiated with drug companies available upfront to customers buying their medications, lowering their costs at the counter.
+Added: Cigna Healthcare will adopt this new model for its fully insured customers beginning in 2027.
+Added: It will become the standard model available for Evernorth Health Services pharmacy benefit clients beginning in 2028.
• Home Delivery Pharmacy.
−Removed: Our Express Scripts Pharmacy by Evernorth ® ("Express Scripts Pharmacy") offers free standard shipping of medications nationwide, usually in a 90-day supply, directly to the customer's home and allows for automatic refills on eligible medications and unrestricted telephone access to customer care advocates and specially trained pharmacists.
−Removed: The Home Delivery Pharmacy operations consist of 13 licensed pharmacies, including 4 fulfillment pharmacies.
−Removed: Our fulfillment pharmacies are located in Arizona, Indiana, Missouri and New Jersey.
+Added: Our Express Scripts ® Pharmacy offers free standard shipping of medications nationwide, usually in a 90-day supply, directly to the customer's home and allows for automatic refills on eligible medications and unrestricted telephone access to customer care advocates and specially trained pharmacists.
+Added: Our Evernorth EnGuide SM Pharmacy ("EnGuide Pharmacy") was established in 2025 to focus on the growing population of customers that are prescribed GLP-1 medications requiring clinical support.
+Added: Express Scripts Pharmacy operations consist of 11 licensed pharmacies, inclusive of four fulfillment pharmacies located in Arizona, Indiana, Missouri and New Jersey.
+Added: EnGuide Pharmacy operations consist of two licensed pharmacies, inclusive of one fulfillment pharmacy located in Ohio.
Specialty and Care Services
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These medications broadly include those with frequent dosing adjustments, intensive clinical monitoring, the need for customer training, specialized product administration requirements or medications limited to certain specialty pharmacy networks by manufacturers.
−Removed: The front-end of our pharmacy, anchored by Accredo by Evernorth ® ("Accredo"), is organized into Therapeutic Resource Centers, where pharmacists focus their practice of pharmacy by condition.
+Added: The front-end of our pharmacy, anchored by Accredo ® Specialty Pharmacy ("Accredo"), is organized into Therapeutic Resource Centers, where pharmacists focus their practice of pharmacy by condition.
Accredo provides support for customers through our specially trained clinicians, network of in-home nursing services, nationwide footprint, drug reimbursement services and highly tailored clinical care programs.
Our Specialty Pharmacy operations consist of 35 licensed pharmacies.
−Removed: • Specialty Distribution.
−Removed: CuraScript SD by Evernorth ® is a specialty distributor of pharmaceuticals and medical supplies (including injectable and infusible pharmaceuticals and medications to treat specialty and rare or orphan diseases) directly to health care providers, clinics and hospitals in the United States for office or clinic administration.
+Added: • Health System Services.
+Added: Health System Services includes CuraScript SD by Evernorth ® , which is a specialty distributor of pharmaceuticals and medical supplies (including injectable and infusible pharmaceuticals and medications to treat specialty and rare or orphan diseases) directly to health care providers, including clinics and hospitals in the United States for office or clinic administration.
We provide distribution services primarily to health care providers who treat customers with chronic diseases and regularly order costly specialty pharmaceuticals.
−Removed: This business operates three distribution centers and ships most products overnight within the United States.
−Removed: It is a contracted supplier with most major group purchasing organizations and leverages its distribution platform to operate as a third-party logistics provider for several pharmaceutical companies.
+Added: This business operates four distribution centers and ships most products overnight within the United States.
+Added: It is a contracted supplier with most major group purchasing organizations and leverages its distribution platform to operate as a third-party logistics provider for certain pharmaceutical companies.
• Care Services.
−Removed: We offer clinical programs to help our clients, including third-party administrators, drive better whole-person health outcomes through our Care Delivery (MD Live by Evernorth ® ("MD Live") virtual care, in-home care and physical primary care) and Care Management (EviCore by Evernorth ® ("EviCore"), benefits management, behavioral health services, network services and health coaching capabilities) offerings.
+Added: We offer clinical programs to help our clients, including third-party administrators, drive better whole-person health outcomes through our Care Delivery (MD Live by Evernorth ® ("MD Live") virtual care) and Care Management (EviCore by Evernorth ® ("EviCore") benefits management, behavioral health services, network services and health coaching capabilities) offerings.
Clients and Customers
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Evernorth Health Services has three clients that each drive significant revenues for the segment:
−Removed: • Express Scripts and Centene Corporation ("Centene") have a multi-year agreement, which began January 1, 2024, to manage pharmacy benefit services for Centene's customers, providing them with access to the extensive Express Scripts national network of retail pharmacies.
−Removed: • Express Scripts and Prime Therapeutics LLC ("Prime") have an agreement to deliver improved choice and affordability for Prime's clients and customers by enhancing retail pharmacy networks, providing access to Accredo and Express Scripts Pharmacy, and providing pharmaceutical manufacturer value.
−Removed: • The Department of Defense ("DoD") TRICARE ® is the military health care program available to active-duty service members, active-duty family members, National Guard and Reserve members and their family members, retirees and retiree family members, survivors and certain former spouses.
+Added: • Express Scripts and Centene Corporation ("Centene") have a multiyear agreement, which began January 1, 2024, to manage pharmacy benefit services for Centene's customers, providing them with access to the extensive Express Scripts national network of retail pharmacies.
+Added: • Express Scripts and Prime Therapeutics LLC ("Prime") have agreements to deliver improved choice and affordability for Prime's clients and customers by enhancing retail pharmacy networks, providing access to Accredo and Express Scripts Pharmacy, and providing pharmaceutical manufacturer value.
+Added: • The Department of War (previously the Department of Defense) TRICARE ® is the military health care program available to active-duty service members, active-duty family members, National Guard and Reserve members and their family members, retirees and retiree family members, survivors and certain former spouses.
The primary competitive factors in the industry include the ability to negotiate with retail pharmacies to ensure retail pharmacy networks meet the needs of clients and customers;
provide home delivery and specialty pharmacy services;
−Removed: negotiate pricing of
−Removed: prescription drugs with drug manufacturers;
+Added: negotiate with drug manufacturers to lower the cost of prescription drugs;
manage cost and quality of specialty drugs;
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improve access, outcomes, and efficiencies within the health care ecosystem;
−Removed: deliver quality primary and behavioral care in virtual-led hybrid settings, in the workplace and in home-based settings;
+Added: deliver quality primary and behavioral care in virtual-led hybrid settings and in the workplace;
navigate the complexities of government-reimbursed business including Medicare, Medicaid and the public exchanges;
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group purchasing organizations;
−Removed: clinical solutions companies, health care data analytics companies;
+Added: clinical solutions companies;
+Added: health care data analytics companies;
and care services providers.
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CIGNA HEALTHCARE
−Removed: Cigna Healthcare includes the U.S.
−Removed: Healthcare and International Health operating segments, which provide comprehensive medical plan services and coordinated solutions to clients and customers.
−Removed: Excluding the businesses pending divestiture to Health Care Service Corporation ("HCSC"), Cigna Healthcare is predominately comprised of foundational growth businesses.
+Added: Cigna Healthcare includes our U.S.
+Added: Healthcare and International Health operating segments, which provide comprehensive medical and coordinated solutions to clients and customers.
+Added: Healthcare provides medical plans and other benefits and solutions for insured and self-insured clients as well as for individual and family plan customers.
+Added: International Health provides health care solutions in our international markets, as well as health solutions for globally mobile individuals and employees of multinational organizations.
How We Deliver
−Removed: • Multifaceted approach to affordability with a focus on high-quality care to lower costs and drive better outcomes through deep collaborative partnerships with high-performing providers and superior clinical expertise and analytics to guide customers to the highest quality, most affordable sites of care.
+Added: • Multifaceted approach to affordability with a focus on high-quality care to lower costs and drive better outcomes through deep collaborative partnerships with high-performing providers and superior clinical expertise and analytics to guide customers to the highest quality, most affordable sites of care and reduce health care waste.
• Talented and experienced people who bring a highly consultative orientation to market and partner with clients to understand their business and goals to address the unique health needs of their population.
• Modular portfolio of products, services and funding options that provides choice and enables us to build and tailor a unique combination to meet the specific needs of each client.
−Removed: • Partnering with Evernorth to drive cross-enterprise leverage to deliver a spectrum of integrated solutions that create value and savings for our customers, clients and partners.
−Removed: We offer administrative services only ("ASO") and insurance funding solutions to employers, groups and individuals along with other health care benefits and solutions to improve the quality of care, lower costs and help customers achieve better health outcomes.
−Removed: Funding solutions, referring to the entity assuming financial risk, are described in the Premiums and Fees section below.
+Added: • Partnering with Evernorth to deliver a spectrum of integrated solutions that create value and savings for our customers, clients and provider partners.
+Added: • Commitment to improving the health care experience for patients and physicians through easier access to care, better support, better value, accountability and transparency.
+Added: We offer administrative services only ("ASO") and insurance funding options to employers, groups and individuals along with other health care benefits and solutions to improve the quality of care, lower costs and help customers achieve better health outcomes.
+Added: Funding options, referring to the entity assuming financial risk, are described in the Premiums and Fees section below.
Principal Products and Services
Healthcare Medical Plans
−Removed: • Employer Medical Plans include health maintenance organizations ("HMOs"), LocalPlus ® , Network and Open Access Plus offered through our insurance companies, and third-party administrators ("TPAs").
+Added: • Employer Medical Plans are offered by our insurance companies, health maintenance organizations ("HMOs") and third-party administrators ("TPAs"), and include Open Access Plus, LocalPlus ® and HMO options.
These plans use cost-sharing incentives to encourage the use of "in-network" rather than "out-of-network" health care providers.
−Removed: Preferred Provider Organization ("PPO") plan offerings feature broader provider access than the other plans, do not require referrals and typically have a higher cost-share for out-of-network services.
+Added: We also offer Preferred Provider Organization ("PPO") plans that feature broader provider access than the other plans, do not require referrals and typically have a higher cost-share for out-of-network services.
Plans are offered nationwide, and our funding solutions include ASO (self-funded), insured guaranteed cost ("GC") and insured experience rated ("ER").
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Health Savings Accounts, Health Reimbursement Accounts and Flexible Spending Accounts encourage customers to play an active role in managing their health and health care costs.
−Removed: • Individual and Family Plans ("IFPs") are Patient Protection and Affordable Care Act ("ACA") compliant exclusive provider organizations ("EPOs") or HMO plans marketed to individuals under age 65 without access to health care coverage through an employer or government program such as Medicare or Medicaid.
+Added: • Individual and Family Plans ("IFP") are Patient Protection and Affordable Care Act and related amendments ("ACA") compliant exclusive provider organizations ("EPOs") or HMO plans marketed to individuals under age 65 without access to health care coverage through an employer or government program such as Medicare or Medicaid.
Customers receive comprehensive health care benefits and have access to a local network of health care providers who have been selected with cost and quality in mind.
Plans are currently offered in 11 states with a GC funding solution.
−Removed: Held for Sale
−Removed: In January 2024, the Company entered into a definitive agreement to sell the Medicare Advantage, Medicare Individual Stand-Alone Prescription Drug Plans, Medicare and Other Supplemental Benefits, and CareAllies businesses within the U.S.
−Removed: Healthcare operating segment to HCSC subject to applicable regulatory approvals and other customary closing conditions, including adjustments to align with the final balance sheet of the divested businesses (the "HCSC transaction").
+Added: Sold Businesses
+Added: On March 19, 2025, the Company completed the sale of our Medicare Advantage, Medicare Individual Stand-Alone Prescription Drug Plans, Medicare and Other Supplemental Benefits, and CareAllies ® businesses to Health Care Service Corporation ("HCSC," and such transaction, the "HCSC transaction").
+Added: Prior to the disposal date, U.S.
+Added: Healthcare's results include these businesses.
See Note 5 to the Consolidated Financial Statements for further information.
−Removed: • Medicare Advantage Plans allow Medicare-eligible customers to receive health care benefits, including prescription drugs, through a managed care health plan.
−Removed: Our plans include HMO and PPO plans with a GC funding solution marketed to individuals and qualified employer groups in 29 states and the District of Columbia.
−Removed: • Medicare Individual Stand-Alone Prescription Drug ("Part D") Plans provide a number of prescription drug plan options, as well as service and information support to Medicare-eligible individuals.
−Removed: Our stand-alone plans offer the coverage of Medicare combined with the flexibility to select a product that provides enhanced benefits and a formulary that aligns with the individual's needs.
−Removed: Plans are offered nationwide with a GC funding solution .
−Removed: • Medicare Supplement Plans provide Medicare-eligible customers with federally standardized Medigap plans.
−Removed: Customers may select among the various Center for Medicare and Medicaid Services ("CMS") standardized plan designs to meet their unique needs and may visit any health care provider or facility that accepts Medicare throughout the United States without the need for a referral.
−Removed: Plans are offered in 48 states and the District of Columbia with a GC funding solution.
Healthcare Benefits and Solutions
−Removed: The following benefits and solutions are offered nationwide with various funding solutions to enhance the benefits from our health care medical plans.
−Removed: • Behavioral Health solutions consist of a broad national network of providers, including one of the largest virtual networks in the United States, specialty case and utilization management, a 24/7-accessible crisis intervention phone line, employee assistance programs, and work/life programs.
+Added: The following benefits and solutions are offered nationwide with various funding options to enhance the benefits from our health care medical plans.
+Added: • Behavioral Health solutions consist of a broad national network of providers, including one of the largest virtual networks in the United States;
+Added: specialty case and utilization management;
+Added: a 24/7-accessible crisis intervention phone line;
+Added: employee assistance programs;
+Added: and work/life programs.
• Consumer Health Engagement solutions include an array of health management, disease management and wellness programs to improve customers' health and well-being.
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We provide products and services that meet the needs of multinational employers, intergovernmental and nongovernmental organizations, and globally mobile individuals with a focus on keeping employees healthy and productive.
−Removed: Products and services are offered worldwide except as limited by applicable law and include ASO, GC and ER funding solutions.
+Added: Products and services are offered worldwide except as limited by applicable law and include ASO, GC and ER funding options.
• Local Health Care offerings include medical, dental, pharmacy and vision as well as life coverage.
Customers include employers and individuals located in specific geographies (China, Singapore, Hong Kong, Spain and India, along with various countries in the Middle East) where the products and services are purchased.
−Removed: Offerings include ASO, GC and ER funding solutions.
+Added: Offerings include ASO, GC and ER funding options.
Premiums and Fees
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We earn fees for providing access to our participating provider networks, claims administration services, and other benefits and solutions.
−Removed: ASO arrangements represent approximately 26% of segment revenues and 74% of Cigna Healthcare medical customers.
+Added: ASO arrangements represent approximately 32% of 2025 segment revenues and 79% of Cigna Healthcare medical customers as of December 31, 2025.
Individual and group insurance premium rates generally must be approved by the applicable state regulatory agency, and state or federal laws may restrict or limit the use of rating methods.
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We retain any margin if costs are less than the premium charged (subject to minimum medical loss ratio ("MLR") rebate requirements) and bear the risk for costs in excess of the premium charged.
−Removed: Medicare Advantage (held for sale).
−Removed: We receiv e fixed monthly payments from CMS for each plan customer based on customer demographic data and actual customer health risk factors and may earn additional revenue from CMS related to quality performance measures ("Star Ratings").
−Removed: Premiums may be charged to customers when the plan premium exceeds the revenue determined by CMS.
The ACA subjects individual and small group policy rate increases above an identified threshold to review by the United States Department of Health and Human Services ("HHS"), and our U.S.
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The MLR represents the percentage of premiums used to pay claims and expenses for activities that improve the quality of care.
−Removed: If we do not satisfy the prescribed MLR, statutes require premium refunds to policyholders or to CMS.
−Removed: GC and ER insured arrangements, including Medicare Advantage, represent approximately 74% of segment revenues and 26% of Cigna Healthcare medical customers.
−Removed: See the "Business – Regulation" section of this Form 10-K for additional information about MLR requirements, Star Ratings and risk adjustment programs.
+Added: If we do not satisfy the prescribed MLR, statutes require premium refunds to policyholders.
+Added: GC and ER insured arrangements represent approximately 68% of 2025 segment revenues (which includes Medicare Advantage prior to the HCSC transaction) and 21% of Cigna Healthcare medical customers as of December 31, 2025.
+Added: See the "Business – Regulation" section of this Form 10-K for additional information about MLR requirements.
Market Segments
−Removed: Cigna Healthcare medical customers are comprised of the following market segments:
+Added: Cigna Healthcare serves medical customers across the following market segments:
• National Accounts.
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Employers with 2 to 50 eligible employees .
−Removed: Individual health insurance coverage both on and off the public exchanges and individual dental plans for customers across various distribution channels.
−Removed: • Medicare Advantage (held for sale) .
−Removed: Includes individuals who are Medicare-eligible, as well as employer group-sponsored post-65 retirees.
−Removed: Revenues from CMS are significant to the market segment.
+Added: Individual health insurance coverage both on and off the public exchanges.
• International Health.
Includes multinational employers and globally mobile individuals, and employers and individuals in specific countries outside of the United States.
+Added: • Medicare Advantage (sold business in 2025) .
+Added: Includes individuals who are Medicare-eligible, as well as employer group-sponsored post-65 retirees.
Clients and Customers
We provide clients and customers with access to a mix of medical and other health care benefits and solutions.
−Removed: Employers, TPAs, union-sponsored benefit plans, government health programs and other groups.
−Removed: Individuals who access our offerings through an employer-sponsored plan, government-sponsored plan, individual plan or other insured group.
+Added: Employers, TPAs, union-sponsored benefit plans and other groups.
+Added: Individuals who access our offerings through an employer-sponsored plan, government-sponsored plan in Medicare Advantage prior to the HCSC transaction, IFP or other individual plan, or other insured group.
Primary Distribution Channels
• Brokers and Consultants.
−Removed: Sales representatives distribute our products and solutions to a broad group of brokerage and consulting firms as well as individuals.
+Added: Sales representatives distribute our products and solutions through a broad group of brokerage and consulting firms as well as individuals.
Cigna Healthcare sales representatives distribute our products and solutions directly to employers, unions, and other groups or individuals.
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• Participating Provider Networks.
−Removed: We provide our customers with a national network of participating health care providers, hospitals, and other facilities, pharmacies and providers of health care services and supplies.
−Removed: network has approximately 1.8 million physicians, including specialists, and over 6,000 hospitals.
+Added: We provide our customers with a national network of participating health care providers;
+Added: and other facilities, pharmacies and providers of health care services and supplies.
+Added: As of December 31, 2025, our U.S.
+Added: network had approximately 1.7 million physicians, including specialists, and over 6,000 hospitals.
We have strategic alliances with several regional managed care organizations to gain access to their provider networks and discounts.
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With more than 200 arrangements with primary care groups, our flagship program is the Cigna Collaborative Accountable Care program, which rewards providers for improving quality outcomes and medical cost performance.
−Removed: We have approximately 100 arrangements with specialist groups across six different disciplines that include incentives for enhanced care coordination or reimbursements for meeting cost and quality goals.
−Removed: We also have contracts with more than 200 hospital systems, involving more than 800 hospitals, with reimbursements tied to quality metrics.
+Added: As of December 31, 2025, we had approximately 100 arrangements with specialist groups across a variety of disciplines that include incentives for enhanced care coordination or reimbursements for meeting cost and quality goals.
+Added: We also had contracts with more than 200 hospital systems, involving more than 750 hospitals, with reimbursements tied to quality metrics.
• Site of Care Optimization.
−Removed: We encourage the use of clinically appropriate settings to reduce the cost of care while ensuring high-quality care and service through our clinical programs and partnership with EviCore.
−Removed: We expand access, reduce the cost of care and offer flexibility while supporting the patient/provider relationship by providing access to virtual care services, including MD Live.
+Added: We encourage the use of clinically appropriate settings to reduce the cost of care while ensuring high-quality care and service through our clinical programs.
+Added: Through our clinical programs and partnership with EviCore, we guide care to the most appropriate settings, reducing unnecessary costs while preserving quality and service, and offer virtual care options, including MD Live, to improve convenience and access.
OTHER OPERATIONS
Other Operations comprises the remainder of our business operations, which includes certain continuing, run-off and other non-strategic businesses.
−Removed: Other Operations also included the international life, accident and supplemental benefits businesses and our interest in a joint venture in Türkiye prior to the divestiture of these businesses in 2022.
Continuing Business
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Fees for universal life insurance products consist primarily of mortality and administrative charges assessed against the policyholder's fund balance.
−Removed: Interest credited and mortality charges for
−Removed: universal life and mortality charges on variable universal life may be adjusted prospectively to reflect expected interest and mortality experience.
+Added: Interest credited and mortality charges for universal life and mortality charges on variable universal life may be adjusted prospectively to reflect expected interest and mortality experience.
To reduce our exposure to large individual losses, we purchase reinsurance from unaffiliated reinsurers.
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The individual life insurance and annuity business and the retirement benefits business were sold through reinsurance agreements in 1998 and 2004, respectively.
−Removed: For more information regarding the arrangements that secure our reinsurance recoverables for the retirement benefits business, see Note 10 to the Consolidated Financial Statements.
+Added: For more information
+Added: regarding the arrangements that secure our reinsurance recoverables for the retirement benefits business, see Note 10 to the Consolidated Financial Statements.
MISCELLANEOUS
−Removed: • Revenues from a single pharmacy benefit client were approximately 16% of consolidated revenues for the year ended December 31, 2024.
+Added: • Revenues from a single pharmacy benefit client were approximately 19% and 16% of total revenue from external customers for the years ended December 31, 2025 and 2024, respectively.
These amounts were reported in the Evernorth Health Services segment.
• Revenues from U.S.
−Removed: Federal Government agencies, under a number of contracts, were approximately 11%, 15% and 14% of consolidated revenues for the years ended December 31, 2024, 2023 and 2022, respectively.
+Added: Federal Government agencies, under a number of contracts, were 11% and 15% of total revenue from external customers for the years ended December 31, 2024 and 2023, respectively.
These amounts were reported in the Evernorth Health Services and Cigna Healthcare segments.
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We routinely monitor and evaluate the status of our investments, obtaining and analyzing relevant investment-specific information and assessing current economic conditions, trends in capital markets and other factors, such as industry-sector, geographic and property-specific information.
−Removed: The Cigna Group Ventures.
−Removed: In addition to the core insurance and operating investment portfolios described above, The Cigna Group has committed $700 million in aggregate since the formation of The Cigna Group Ventures, our strategic corporate venture fund that invests in promising startups and growth-stage companies making groundbreaking progress in three strategic areas:
−Removed: data and technology, digital health, and care delivery.
−Removed: Through these partnerships, we collaborate, innovate and develop new solutions to improve the health and vitality of those we serve.
DIGITAL, DATA AND TECHNOLOGY
−Removed: The Cigna Group investments in digital, data and technology are focused on cultivating robust digital-first capabilities to better engage with customers and stakeholders.
−Removed: Customer-centric, digital-first, virtual-led vision for health care remains at the forefront of our priorities.
−Removed: The advancement of our internal innovative capabilities and strategic partnerships continues to produce new and more effective ways to engage with our customers to help close gaps in care, optimize treatment and improve outcomes.
−Removed: At The Cigna Group, we use artificial intelligence ("AI") to support health care transformation by helping to enable the next generation of accessible, effective, affordable and enhanced health care solutions.
+Added: The Cigna Group investments in digital, data and technology are focused on cultivating robust, innovative digital-first capabilities to better engage with customers and stakeholders.
+Added: Our Commitments to Better.
+Added: The Cigna Group is on a multiyear journey toward making the health care experience better for those we serve.
+Added: We are taking action on our five commitments, which are outlined above.
+Added: The Cigna Group is driving meaningful improvements for all customers through strong governance and collaboration across the organization.
+Added: These partnerships guide our efforts to enhance health outcomes for the millions we serve while ensuring transparency and accountability every step of the way.
+Added: At the core of the Company's strategic priorities lies a culture of innovation and enablement - one that empowers a customer-centric, digital-first, virtual-led vision for health care.
+Added: The advancement of our internal innovative capabilities and strategic partnerships empowers teams to continuously challenge conventions, embrace experimentation and produce new and more effective ways to engage with our customers to help close gaps in care, optimize treatment and improve outcomes.
+Added: The Cigna Group is committed to innovative, transformative changes by reimagining our operating models, products and interactions to create new sources of value.
+Added: We use artificial intelligence ("AI") to support health care transformation by helping to enable the next generation of accessible, effective, affordable and enhanced health care solutions.
AI models can facilitate personalized solutions for individuals, inform earlier interventions and simplify health care experiences.
−Removed: We do not view AI as a replacement for expert decisions made by physicians or employees at The Cigna Group.
+Added: There is human engagement in claims reviews, including expert decisions made by physicians or employees at The Cigna Group.
Given this, we consider most of the AI models we use as augmented intelligence, providing information to human experts for further consideration, in combination with many other factors evaluated in care and benefit administration decisions.
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Our EMG team oversees the development, deployment and monitoring of AI models driven by our Responsible AI Principles:
−Removed: validity and reliability;
−Removed: transparency;
−Removed: and accountability.
−Removed: EMG is governed by the EMG Board, comprised of senior leaders from across the company, with representation from business, clinical, privacy, legal, internal audit, information protection and other departments.
+Added: validity and reliability, safety, privacy, fairness, transparency, and accountability.
+Added: EMG is governed by the EMG Board, consisting of senior
+Added: leaders from across the company, with representation from business, clinical, privacy, legal, internal audit, information protection and other departments.
The EMG Board oversees an enterprise-wide model approval and governance process for review of AI models in use or in development across the enterprise.
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Data and Analytics.
+Added: Data and analytics power the Company's strategy, fueling informed decisions, deeper insights and accelerated growth.
+Added: We are creating technology that drives AI processes and enables predictive, personalized and adaptive business outcomes.
We conduct timely, rigorous and objective research and analysis that informs evidence-based medical and pharmacy benefit management decisions and evaluates the clinical, economic and individual impact of enhanced benefit designs and programs, ultimately resulting in rich, integrated data that helps to provide differentiated outcomes.
−Removed: The combination of our predictive analytics, and our machine learning ("ML") and deep learning capabilities create actionable intelligence that informs decision-making of our health care professionals, improves operational efficiency and enables greater innovation.
−Removed: Our data-driven approach to behavioral health provides personalized and customized care across the entire continuum for the populations we serve.
−Removed: These solutions predict emerging health needs, close gaps in care and drive cost savings, all while empowering whole-person and whole-family health.
−Removed: Our digital health focus has shown value across the enterprise by imagining the future of health care and creating engaging experiences that give customers the right information at the right time.
−Removed: We deliver resource-efficient products and features at scale and on time with a commitment to security, resiliency and compliance.
−Removed: At its core, digital is a connected ecosystem that serves customers, clients and providers, and it paves the way to direct-to-consumer relationships and new growth opportunities.
−Removed: Our digital strategy focuses on the drive from analog to digital, which complements the growth strategy of The Cigna Group, creates efficiency and amplifies the value of existing offerings, as well as creates option value with industry-leading personalization and precision to drive better health and business outcomes.
+Added: The combination of our predictive analytics, and our machine learning ("ML") and deep learning capabilities help to uncover trends, anticipate needs and create actionable intelligence that assists and accelerates decision-making of our health care professionals, improves operational efficiency and enables greater innovation.
+Added: Our data-driven approach to building products and solutions provides personalized and customized care across the entire continuum for the populations we serve.
+Added: These solutions predict emerging health needs, close gaps in care and drive cost savings, all while focusing on improving the health and vitality of the lives we touch.
+Added: Our digital health focus has shown value across the enterprise by reimagining the future of health care and creating engaging experiences that give customers the right information at the right time.
+Added: We are positioning our lines of business for today's market pressures while ensuring we are building a sustainable advantage through data, insights and digital innovation.
+Added: We drive efficiencies, improve sentiment and create market differentiation, while accelerating our path toward personalized, AI-driven solutions for customers, clients and providers.
+Added: We deliver digital products and features at scale with a commitment to security, resiliency and compliance.
+Added: Our digital strategy also focuses on the drive from analog to digital, which complements the growth strategy of The Cigna Group, creates efficiency and amplifies the value of existing offerings, as well as creates option value with industry-leading personalization and precision to drive better health and business outcomes.
Cybersecurity protections continue to be a top priority across The Cigna Group digital offerings to further strengthen our security posture and grow the trust of those we serve.
−Removed: Item 1C - "Cybersecurity" of this Form 10-K for additional information regarding our cybersecurity practices and governance.
+Added: See Part I, Item 1C - "Cybersecurity" of this Form 10-K for additional information regarding our cybersecurity practices and governance.
Technology Operations.
−Removed: Our technology team supports the various information systems essential to our operations, including the health benefit claims processing systems and specialty and home delivery pharmacy systems.
−Removed: Uninterrupted point-of-sale electronic retail pharmacy claims processing is a significant operational requirement for our business.
+Added: Our technology team consistently maintains a high degree of availability and reliability to our various information systems critical to client and customer care operations, providers, and overall customer experience.
+Added: Within Evernorth Health Services, uninterrupted point-of-sale electronic retail pharmacy claims processing is a significant operational requirement for our business.
We believe we have substantial capacity for growth in our U.S.
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A healthy and diverse global workforce is essential to achieving our mission and our business growth strategies.
−Removed: We continually invest in our global workforce to support our employees' health and vitality, provide fair and market-competitive pay, and foster growth and development for every employee.
−Removed: As of the end of 2024, we had approximately 73,500 employees, with approximately 90% of our employees based in the United States.
−Removed: Approximately 97% of our employees are full-time.
−Removed: The Cigna Group has a long-standing and deep commitment to fair opportunity for all, regardless of gender, race or ethnicity.
−Removed: As of the end of 2024, our global workforce was approximately 70% women and 30% men.
−Removed: Approximately 41% of our employees in the United States were ethnic minorities.
+Added: We continually invest in our employees by supporting their health and vitality, providing fair and market-competitive compensation, and fostering opportunities for growth and development.
+Added: As of the end of 2025, The Cigna Group employed approximately 67,700 employees worldwide, with about 88% of our employees based in the United States.
+Added: Roughly 97% of our workforce is full-time.
+Added: At year-end 2025, our global workforce was approximately 69% women and 31% men, and about 40% of our U.S.
+Added: employees identified as ethnic minorities.
+Added: We have a long-standing and deep commitment to cultivating a purpose and performance driven workforce that is equipped and empowered to drive growth and innovation across our businesses.
Health, Vitality and Other Benefits.
−Removed: Tending to our employees' health and vitality is a critical business imperative for our company and one of the most important investments in our enterprise that we make each year.
−Removed: We believe that when we support our employees' health and well-being, they are more productive and engaged in driving our mission and business strategy forward, thereby creating shareholder value.
−Removed: In 2024, The Cigna Group invested approximately 19% of total payroll in health, well-being and other benefits, including life and disability programs, 401(k) contributions, and retirement-related benefits for our employees in the United States.
−Removed: In addition to traditional medical and pharmacy benefits, we provide multidimensional wellness programming to support the physical, mental, financial, and social health as well as overall vitality of employees.
−Removed: Additionally, we encourage employees to self-report additional demographic information, including whether they are a military veteran or living with a disability, so that we can better support the health and vitality of every employee in light of their unique background, experiences and perspectives.
+Added: Supporting our employees' health and vitality is not only a core value, it's a critical business imperative.
+Added: Each year, we make continued investments to help ensure our workforce is healthy, engaged and empowered to advance our mission and business strategy, ultimately creating long-term shareholder value.
+Added: In 2025, The Cigna Group invested approximately 20% of total payroll in health, well-being and other benefits.
+Added: These investments include comprehensive medical and pharmacy coverage, paid time off, life and disability programs, 401(k) contributions, and retirement-related benefits for our employees in the United States.
+Added: Beyond traditional medical and pharmacy benefits, we provide multidimensional wellness programs designed to support many aspects of well-being (physical, mental, financial and social health) while promoting overall vitality.
+Added: We also encourage employees to voluntarily share additional demographic information, such as military veteran status or disability, so we can tailor resources and programs to meet their unique needs and perspectives.
Talent Acquisition, Development and Retention.
−Removed: Our talent acquisition and rewards strategies are designed to attract and retain skilled employees who are engaged in our mission.
−Removed: We are committed to attracting and recruiting key talent from all backgrounds into positions at all levels of the enterprise, including underrepresented groups in various leadership roles across the business.
−Removed: Our compensation program, rooted in our pay-for-performance philosophy, aims to provide market-competitive base salaries and incentives that reward contributions that advance the Company's strategy and mission.
+Added: Our talent acquisition and rewards strategies are designed to attract and retain skilled employees who are committed to our mission.
+Added: We strive to reach a broad and diverse pool of candidates to engage and recruit top talent across all levels and functions of the Company.
In 2025, the voluntary turnover rate was approximately 9% for all employees.
Our compensation practices, rooted in our pay-for-performance philosophy, promote fair and competitive pay through measures such as benchmarking compensation by role, eliminating inquiries regarding applicants' compensation history from the hiring process and monitoring for potential disparities.
−Removed: Our most recent pay equity analysis among our U.S.
−Removed: employees, conducted in 2025, illustrated that female employees of The Cigna Group earn more than 99 cents for every dollar earned by similarly situated male employees, and ethnic minority employees (which includes Black/African American, Hispanic or Latino/a, Pacific Islander.
−Removed: and American Indian/Alaskan employees) earn more than 99 cents for every dollar earned by similarly situated white employees.
−Removed: We also analyzed gender pay on a global basis and found that across the entire Company, female employees at The Cigna Group earn more than 99 cents for every dollar earned by similarly situated male employees.
+Added: Within the U.S., female employees of The Cigna Group earn more than 99 cents for every dollar earned by similarly situated male employees, and employees from underrepresented groups earn more than 99 cents for every dollar earned by similarly situated white employees.
+Added: On a global basis, across the entire Company, female employees at The Cigna Group earn more than 99 cents for every dollar earned by similarly situated male employees.
Our online learning platform and career development tools, including a career portal and career planning tool, offer a broad range of training, education and development resources to all employees.
In 2025, based on internal data, employees on average engaged in 45 hours of learning through these resources.
−Removed: Our agile leadership development strategy, anchored by The Cigna Group Leader Profile and aligned with our mission and enterprise goals, serves to cultivate leadership capabilities for people leaders and critical segments across our organization through innovative programs and resources.
−Removed: The Cigna Group also offers an education reimbursement program for both full- and part-time employees who meet the continuing education criteria.
+Added: Our leadership development strategy, anchored by The Cigna Group Leader Profile and aligned with our mission and enterprise goals, serves to cultivate leadership capabilities for people leaders and critical segments across our organization through innovative programs and resources.
+Added: The Cigna Group also offers an education reimbursement program for both full-time and part-time employees who meet the continuing education criteria.
We believe these strategies and programs contribute to employee engagement and retention and prepare our employees to meet our needs now and in the future.
−Removed: ENVIRONMENTAL, SOCIAL AND GOVERNANCE
−Removed: The Cigna Group environmental, social and governance framework is structured around four connected pillars that underscore our enterprise mission to improve the health and vitality of those we serve.
−Removed: We drive action through this framework to deliver on our purpose and performance vision:
+Added: CORPORATE IMPACT AND SUSTAINABILITY
+Added: The Cigna Group corporate impact and sustainability framework is structured around four connected pillars that underscore our enterprise mission to improve the health and vitality of those we serve.
+Added: We drive action through this framework to deliver on our vision:
to transform the ecosystem of health into one that is well-functioning, sustainable, accessible and equitable - advancing better health for all.
−Removed: Our commitment to this vision guides us in our multidimensional value-creation strategy as we strive to meet the needs of our many stakeholders.
+Added: Our commitment to this vision guides us in our value-creation strategy as we strive to meet the needs of our many stakeholders.
The four pillars of this framework are as follows:
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We drive progress by aligning our products and services with value-based care models, leveraging integrated benefits, managing drug costs through innovation, expanding digital offerings and reviewing coverage policies for health equity.
+Added: We also give back through charitable giving and volunteerism in communities where we operate around the world.
Healthy Workforce.
We believe that employers play a vital role in the health care system, and we strive to be a model for others by prioritizing and investing in the health and vitality of employees within our own company.
−Removed: We aim to cultivate a purpose- and performance-driven workforce that is equipped and empowered to drive growth and innovation across our diverse businesses.
+Added: We aim to cultivate a workforce that is equipped and empowered to drive growth and innovation across our diverse businesses.
See further discussion of this pillar within Part I, Item 1 "Human Capital Management" section above.
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We have a deep and long-held commitment to strong governance as well as ethical and resilient business practices.
−Removed: This includes protecting the sensitive data of our clients and customers by ensuring cybersecurity incident response preparedness, supporting a responsible supply chain and committing to increasing our annual diverse supplier spend.
+Added: This includes protecting the sensitive data of our clients and customers by ensuring cybersecurity incident response preparedness, as well as supporting a responsible supply chain.
We are regulated by federal, state and international legislative and executive bodies and agencies, which generally have discretion to issue regulations and interpret and enforce laws and rules.
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Our international subsidiaries face an increasingly complex regulatory dynamic, including as a result of rigorous regulations and the impact of geopolitical developments or tensions.
−Removed: Many aspects of our business are directly regulated by federal and state laws and administrative agencies, such as HHS, CMS, the Internal Revenue Service ("IRS"), the U.S.
−Removed: Departments of Labor ("DOL") and Treasury, the Office of Personnel Management ("OPM"), the Federal Trade Commission ("FTC"), the SEC, the Office of the National Coordinator for Health Information Technology, state departments of insurance and state boards of pharmacy.
+Added: Many aspects of our business are directly regulated by federal and state laws and administrative agencies, such as HHS, Centers for Medicare and Medicaid Services ("CMS"), the Internal Revenue Service ("IRS"), the U.S.
+Added: Departments of Labor ("DOL") and Treasury, the Office of Personnel Management ("OPM"), the Defense Health Agency ("DHA"), the Federal Trade Commission ("FTC"), the SEC, the Office of the National Coordinator for Health Information Technology, state departments of insurance, state boards of health and state boards of pharmacy.
Our business practices may also be shaped by enforcement actions of federal agencies, such as the Department of Justice ("DOJ"), state agencies and judicial decisions.
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Our operations are also subject to nonroutine examinations, audits and investigations by various state and federal regulatory agencies, generally as the result of a complaint.
−Removed: In addition, we may be implicated in investigations of our clients whose group benefit plans we administer on their behalf.
−Removed: As a result, we routinely receive subpoenas and other demands or requests for information from various state insurance and HMO regulatory agencies, state attorneys general, the HHS Office of Inspector General ("HHS-OIG"), the DOJ, the FTC, the DOL, and other state, federal and international authorities.
+Added: In addition, we may be subject to examination or investigation of our clients whose group benefit plans we administer on their behalf.
+Added: As a result, we routinely receive subpoenas and other demands or requests for information from various state insurance and HMO regulatory agencies, state attorneys general, the HHS Office of Inspector General ("HHS-OIG");
+Added: and other state, federal and international authorities.
We may also be called upon by members of the U.S.
−Removed: Congress to provide information regarding certain of our business practices.
+Added: Congress, state legislators, state regulators or attorneys general to provide information regarding certain business practices.
If The Cigna Group is determined to have failed to comply with applicable laws or regulations, these examinations, audits, investigations, reviews, subpoenas and demands may (a) result in fines, penalties, injunctions, consent orders or other settlement agreements (such as corporate integrity agreements or loss of licensure);
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For a discussion of the risks related to our compliance with these laws and regulations, please see the "Risk Factors" section located in Part I, Item 1A of this Form 10-K.
−Removed: Consolidated Appropriations Act, 2023
−Removed: The Consolidated Appropriations Act, 2023, ended federal medical assistance percentage increases that were in effect during the COVID-19 Public Health Emergency ("PHE"), which were tied to continuous coverage requirements for Medicaid enrollees during the PHE, and enabled states to restart Medicaid eligibility renewals and terminations for ineligible individuals.
−Removed: As a result, states resumed Medicaid redeterminations in April 2023 for the first time since the PHE began.
−Removed: Under the redeterminations, many beneficiaries are no longer eligible for Medicaid.
−Removed: As a result, some of the beneficiaries determined to be ineligible for Medicaid sought alternate coverage in the individual marketplace.
+Added: Federal Legislative Developments
+Added: In February 2026, the U.S.
+Added: Congress enacted the Consolidated Appropriations Act, 2026, which includes multiple provisions applicable to pharmacy benefit manager ("PBM") operations.
+Added: These provisions are expected to impact pharmacy benefit arrangements in the commercial market and the Medicare Part D program, with varying effective dates.
+Added: The ultimate impact of these provisions will depend, in part, on future regulatory guidance and implementation by the HHS and the DOL, among other federal agencies.
+Added: With respect to employer-sponsored health plans subject to the Employee Retirement Income Security Act ("ERISA"), the legislation includes provisions, effective beginning in August 2028, that require PBMs to remit 100% of certain rebates, fees and other remuneration to plan sponsors.
+Added: In addition, the legislation imposes enhanced disclosure and reporting requirements intended, among other things, to increase transparency into PBM compensation and prescription drug spending.
+Added: The legislation also includes provisions affecting PBM services provided in connection with Medicare Part D plans that, beginning in January 2028, prohibit PBMs from receiving compensation that is directly or indirectly linked to the list price of a covered Part D drug, limiting PBM compensation to bona fide service fees.
+Added: In addition, beginning January 2029, under the legislation, Medicare Part D plan sponsors will be required to contract with any pharmacy that is willing and able to meet standard contract terms and conditions.
+Added: The Company continues to monitor legislative and regulatory developments regarding the Consolidated Appropriations Act, 2026;
+Added: however, the full impact of these provisions on PBM operations cannot be determined at this time.
The Patient Protection and Affordable Care Act
−Removed: The Patient Protection and Affordable Care Act and amendments to the law (collectively, "ACA") mandated broad changes to the U.S.
−Removed: health care system that affect insured and self-insured health benefit plans and pharmacy benefit managers ("PBMs").
+Added: The ACA governs significant aspects of the U.S.
+Added: health care system that affect insured and self-insured health benefit plans and PBMs.
Our business model is impacted by the ACA and may be impacted by additional, future changes to the ACA, including our relationships with current and future producers and health care providers, products, service providers, and technologies.
−Removed: The ACA imposed, among other things, certain assessments on health insurers, created health insurance exchanges for individuals and small group employers to purchase insurance coverage, and implemented minimum MLRs for our Cigna Healthcare business.
+Added: The ACA, among other things, created health insurance exchanges for individuals and small group employers to purchase insurance coverage and implemented minimum MLRs for our Cigna Healthcare business.
The ACA allows states to adopt MLR requirements that are more stringent than those established by the ACA.
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In 2021, in response to the COVID-19 pandemic, the federal government temporarily expanded eligibility for ACA subsidies to higher-income people who did not otherwise qualify and increased ACA subsidies for lower-income people who already qualified in 2021 and 2022, among other actions.
−Removed: The Inflation Reduction Act of 2022 extended the increased premium tax credits for individuals enrolled in ACA-qualified health plans through December 31, 2025.
−Removed: Medicare and Medicaid Regulations
−Removed: Through our subsidiaries, we offer individual and group Medicare Advantage, Medicare Prescription Drug and Medicare Supplement products.
−Removed: We also provide Medicare Part D-related products and services to other Medicare Part D sponsors, Medicare Advantage Prescription Drug Plans, and employers and clients offering Medicare Part D benefits to Medicare Part D eligible beneficiaries, including those dually eligible for Medicare and Medicaid benefits ("dual-eligible").
−Removed: As part of our Medicare Advantage and Medicare Part D business, we contract with CMS to provide services to Medicare beneficiaries.
−Removed: We offer dual-eligible products and participate in state Medicaid programs directly or indirectly through our clients that are Medicaid managed care contractors.
−Removed: We also perform certain Medicaid subrogation services and certain delegated services for clients, including utilization management, which are regulated by federal and state laws.
−Removed: Our products and our participation in government-sponsored health care programs are regulated by CMS, state Medicaid agencies, HHS-OIG, DOJ, and other federal and state agencies, and we are subject to risks associated with audits of our performance and audits to determine compliance with contracts and regulations.
−Removed: Our ability to obtain payment (and the determination of the amount of such payments), market to, enroll and retain customers, and expand into new service areas is subject to compliance with CMS' numerous and complex regulations and requirements that are subject to administrative discretion, review and enforcement.
−Removed: For example, contracts with CMS for coverage of prescription drugs under Medicare Part D contain provisions for risk sharing, which affect our ultimate payments from CMS.
−Removed: Variances exceeding certain thresholds may require us to refund to CMS a portion of the payments we received.
−Removed: We expect federal and state agencies and third-party contractors, such as recovery audit contractors, to closely scrutinize our compliance with program and contractual requirements.
−Removed: Program terms and requirements may change because of rulemaking or enforcement activities, which could result in disruption in the marketplace.
−Removed: Noncompliance with these laws and regulations may result in significant consequences, including fines and penalties, enrollment sanctions, exclusion from the Medicare and Medicaid programs, limitations on expansion, restrictions on marketing our plans, corrections of improper payments and criminal penalties.
−Removed: CMS evaluates Medicare Advantage plans and Part D plans under its "Star Rating" system, which considers various measures adopted by CMS, including quality of care, preventive services, chronic illness management, coverage determinations and appeals, and customer satisfaction.
−Removed: Plans that perform very well are able to offer enhanced benefits, market more effectively and for longer periods of time than other plans, and obtain quality-bonus payments, with Medicare Advantage plans receiving a rating of four or more stars eligible for such payments.
−Removed: The Star Rating system is subject to change annually by CMS, which may make it more difficult to achieve and maintain four stars or greater.
−Removed: CMS provides risk-adjusted premium payments for Medicare Advantage plans based on our customer demographics and medical diagnoses, which may change based on the underlying health of our customers.
−Removed: Under the risk adjustment methodology, Medicare Advantage plans must collect and submit the necessary diagnosis code information from providers to CMS.
−Removed: We generally rely on
−Removed: providers to appropriately document their claims and other submissions with appropriate diagnoses from which we extract hierarchical condition codes to submit to CMS as the basis for our payments.
−Removed: CMS conducts audits to validate the risk adjustment data submitted by health plans.
−Removed: In 2023, CMS issued a final rule ("Final Rule") on its audit methodology and related policies for Risk Adjustment Data Validation ("RADV"), which is currently being challenged in federal court.
−Removed: The Final Rule codifies that CMS will use a statistically valid method for sampling and extrapolation of error rates and a decision not to apply a fee for service adjuster when determining RADV audit findings.
−Removed: Audits for payment years prior to 2018 are not subject to extrapolation.
−Removed: RADV audits for our contract years 2011 through 2015 are currently awaiting CMS finalization.
−Removed: The Company is not currently subject to RADV audits for 2018 and subsequent payment years.
−Removed: The DOJ is currently conducting industry-wide investigations of the risk adjustment data submission practices and business processes of several Medicare Advantage organizations.
−Removed: The Cigna Group was a party to such an investigation, which was settled during the third quarter of 2023 and is subject to a related Corporate Integrity Agreement (the "CIA").
−Removed: In January 2024, the Company entered into a definitive agreement to sell the Medicare Advantage, Medicare Individual Stand-Alone Prescription Drug Plans, Medicare and Other Supplemental Benefits, and CareAllies businesses within the U.S.
−Removed: Healthcare operating segment to HCSC.
−Removed: See Note 5 to the Consolidated Financial Statements for further information.
+Added: These ACA subsidies expired on December 31, 2025.
+Added: The Inflation Reduction Act of 2022 extended the increased premium tax credits for individuals enrolled in ACA-qualified health plans through December 31, 2025, which were not renewed.
Health Care Fraud and Abuse Laws
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Government Procurement Regulations
−Removed: We have a contract with the U.S.
−Removed: DoD that subjects us to applicable Federal Acquisition Regulations ("FAR") and the DoD FAR Supplement, which govern federal government contracts.
−Removed: Further, there are other federal and state laws applicable to our DoD arrangement and our arrangements with other clients that may be subject to government procurement regulations.
+Added: The Cigna Group is required to comply with applicable federal and state procurement laws and regulations which govern eligibility, bidding, contract performance, and ongoing operational obligations for entities participating in government purchasing and contracting activities.
+Added: As an example, we have a contract with the DHA that subjects us to applicable Federal Acquisition Regulations ("FAR") and the FAR Supplement, which govern federal government contracts.
+Added: Further, there are other federal and state laws applicable to our DHA arrangement and our arrangements with other clients that may be subject to government procurement regulations.
In addition, certain of our clients participate as contracting carriers in the Federal Employees Health Benefits Program administered by the OPM, which includes various pharmacy benefit management standards.
−Removed: Employee Retirement Income Security Act
−Removed: Our domestic subsidiaries sell most of their products and services to sponsors of employee benefit plans that are governed by the Employee Retirement Income Security Act ("ERISA").
−Removed: ERISA is a complex set of federal laws and regulations enforced by the IRS and the DOL, as well as the courts.
−Removed: ERISA regulates certain aspects of the relationship between us, the employers that maintain employee welfare benefit plans subject to ERISA and the participants in such plans.
−Removed: Certain of our domestic subsidiaries are also subject to requirements imposed by ERISA affecting claim payment and appeals procedures for individual health insurance and insured and self-insured group health plans and for the insured plans we administer.
+Added: Laws and Regulations Affecting Pharmacy Benefit Plan Design, Administration and Pharmacy Network Access
+Added: The federal government and states have laws, regulations and guidance that affect our ability, or our clients' ability, to limit access to pharmacy provider networks or that prohibit plan sponsors from implementing certain network and benefit plan design features, including provisions relating to the pharmacy benefit.
+Added: These laws can negatively impact the use of cost-saving network and benefit configurations for plan sponsors or affect access.
+Added: One state recently enacted legislation prohibiting PBMs from owning or operating pharmacies within the state, which affects vertically integrated entities such as ours and is currently the subject of ongoing litigation.
+Added: Similarly, the federal government and some states have issued laws, regulations and guidance that impose restrictions and generate additional costs by limiting our ability to maximize efficiencies that could otherwise be gained through certain prescription and refill processes or by imposing mandated coverage of certain benefits, conditions or U.S.
+Added: Food and Drug Administration ("FDA")-approved drugs that may also restrict certain therapeutic interventions.
+Added: Pharmacy Benefit Manager and Drug Pricing Regulation
+Added: Our pharmacy benefit management services are subject to numerous laws and regulations that govern critical practices, including disclosure, receipt and retention of rebates and other payments received from pharmaceutical manufacturers;
+Added: certain pharmacy contracting practices, including disclosure of cost information to customers;
+Added: pharmacy reimbursement mandates;
+Added: the receipt and
+Added: retention of transmission fees from contracted pharmacies;
+Added: performance-based price concessions;
+Added: pharmacy price concessions to drug prices at the point of sale;
+Added: audits of contracted pharmacies;
+Added: use of, administration of or changes to drug formularies, the use and disclosure of maximum allowable cost ("MAC") pricing, or clinical programs;
+Added: "most favored nation" pricing, which provides that a pharmacy participating in a specific government program must give the program the best price the pharmacy makes available to any third-party plan;
+Added: disclosure of data to third parties;
+Added: drug utilization management practices;
+Added: the level of duty a PBM owes its clients or customers;
+Added: configuration of pharmacy networks;
+Added: the operations of our subsidiary pharmacies;
+Added: fiduciary requirements;
+Added: referrals to affiliated pharmacies;
+Added: disclosure of negotiated provider reimbursement rates;
+Added: disclosure of negotiated drug rebates;
+Added: calculation of certain customer cost-share for prescription drug claims;
+Added: pricing that includes differential or spread (i.e., a difference between the drug price charged to the plan sponsor by a PBM and the price paid by the manager to the dispensing provider);
+Added: disclosure of fees associated with administrative service agreements and patient care programs that are attributable to customers' drug utilization;
+Added: utilization management;
+Added: and registration or licensing of PBMs.
+Added: Pharmacy and Pharmaceutical Distribution Regulation
+Added: We are licensed to do business as a pharmacy in the states in which our pharmacies are located, and the health care professionals who we employ are also licensed by, and subject to the laws and regulations of, state boards of pharmacy and other governmental authorities.
+Added: Participation in Medicare and Medicaid programs requires our pharmacies to comply with the applicable Medicare and Medicaid provider rules and regulations and exposes the pharmacies to reimbursement, claims submission, pricing and other changes.
+Added: In addition to the health care fraud and abuse laws and the privacy and security laws described above, our home delivery and specialty pharmacy operations are also subject to extensive federal and state laws and regulations that govern the labeling, packaging, repackaging, compounding, storing, holding, disposal, distribution, advertising, misbranding, adulteration, transfer, handling and security of prescription drugs and the dispensing of prescription, over-the-counter, hazardous and controlled substances, as well as laws enforced by the U.S.
+Added: Drug Enforcement Administration, the FDA, state-controlled substance authorities, the FTC and the United States Postal Service.
+Added: Violations of pharmacy laws and regulations may result in warning letters, civil and criminal penalties, seizures, suspension, termination or revocation of licenses and registrations, restrictions on facilities or operations, and other enforcement actions.
+Added: Certain of our subsidiaries engage in pharmaceutical distribution operations, which are subject to state and federal licensing, reporting and compliance requirements, including state drug distribution licensing regulations, supply chain security laws and controlled substances monitoring requirements.
+Added: If we fail to satisfy state or federal regulatory expectations, we could be subject to fines, suspension or revocation of our distributor licenses, restrictions on operation, and other enforcement actions.
Privacy, Security and Data Standards Regulations
−Removed: On the federal level, we are subject to a number of sector-specific regulations related to the creation, collection, dissemination, receipt, maintenance, protection, use, transmission, disclosure, privacy, confidentiality, security, availability, integrity, processing and disposal of protected health information ("PHI") and other personally identifiable information ("PII").
+Added: On the federal level, we are subject to a number of sector-specific regulations related to the creation, collection, dissemination, receipt, maintenance, protection, use, transmission, disclosure, privacy, confidentiality, security, availability, integrity, disposal and other processing of protected health information ("PHI") and other personally identifiable information ("PII").
The federal Health Insurance Portability and Accountability Act of 1996, as amended, and the regulations that implement such laws (collectively, "HIPAA") impose requirements on covered entities and business associates (and we are both) that address the privacy and security of PHI, regulate permissible uses and disclosures of PHI, and impose breach notification requirements.
−Removed: Violations of HIPAA may result in enforcement actions, civil and criminal penalties and settlement, resolution and monitoring agreements.
−Removed: State attorneys general may also bring civil actions seeking injunctions or damages in response to violations of HIPAA that threaten the privacy of state residents.
+Added: Violations of HIPAA may result in enforcement actions;
+Added: civil and criminal penalties;
+Added: and settlement, resolution and monitoring agreements.
+Added: State attorneys general may also bring civil actions seeking injunctions or damages in response to violations of HIPAA that threaten the privacy of state residents, and violations of privacy, data-security or HIPAA-related requirements could subject us to private litigants or other claims under state or common law theories.
We may also be held liable under HIPAA for violations by our vendors.
−Removed: There can be no assurance that we will not be the subject of an investigation,
−Removed: audit or compliance review regarding our compliance with HIPAA.
+Added: There can be no assurance that we will not be the subject of an investigation, audit or compliance review regarding our compliance with HIPAA.
HIPAA does not preempt more stringent state health privacy laws and regulations, which may protect the health information of certain individuals, such as minors, and certain types of sensitive health information, such as transgender care, HIV/AIDS status, reproductive health information, genetic information, and mental and behavioral health.
−Removed: federal and state consumer privacy laws typically exempt data and/or entities subject to HIPAA, but several states, such as Washington, Nevada and Connecticut, have recently enacted privacy laws to protect consumer health data and require consent for the collection, use and sharing of consumer health data.
+Added: federal and state consumer privacy laws typically exempt data and/or entities subject to HIPAA, but several states, such as Washington, Nevada and Connecticut, have enacted privacy laws to protect consumer health data and require consent for the collection, use, sharing and other processing of consumer health data.
These laws apply to data that is collected outside the scope of HIPAA.
−Removed: In addition, the California Consumer Privacy Act, as amended by the California Privacy Act ("CCPA"), became effective on January 1, 2020, and applies to data that is collected outside the scope of HIPAA (e.g., employee and business contact information).
−Removed: The CCPA increased the privacy protections afforded to California residents with respect to PII that falls outside the scope of HIPAA, including by providing such residents certain rights with respect to their PII and limiting how we may collect and process such residents' PII.
+Added: In addition, 19 states have enacted comprehensive state data privacy laws governing certain categories of personal information such as employee and business partner data, website visitor information, and customer data collected by entities not subject to HIPAA.
+Added: Under these laws, consumer rights to access, correction, and deletion limit how we may collect and process such residents' personal information.
states have laws requiring companies to notify individuals and state regulatory authorities in the event of certain data breaches.
+Added: Moreover, the U.S.
+Added: Congress has considered, and in the future will likely consider, proposals from time to time for comprehensive privacy and data security legislation to which we may be subject if enacted.
These laws and others may impact our businesses and practices.
3 unchanged sentences
State departments of insurance and certain federal agencies adopted implementing regulations as required by federal law.
−Removed: Additionally, under Section 5 of the Federal Trade Commission Act ("FTC Act"), the FTC has jurisdiction over certain privacy and security practices deemed unfair and deceptive acts and practices in or affecting commerce, which includes unfair and deceptive practices with respect to consumer privacy rights and safeguarding of PHI and PII.
+Added: Under Section 5 of the Federal Trade Commission Act ("FTC Act"), the FTC has jurisdiction over certain privacy and security practices deemed unfair and deceptive acts and practices in or affecting commerce, which includes unfair and deceptive practices with respect to consumer privacy rights and safeguarding of PHI and PII.
In addition to the FTC Act, the FTC also enforces other federal laws relating to consumers' privacy and security.
−Removed: The FTC has also been active with respect to companies' use of big data and AI, specifically ensuring fair and equitable use of these tools, and the FTC has named AI as an area of enforcement focus.
−Removed: state legislatures and regulators are similarly interested in the use of AI, particularly as it is used in modeling, and a handful of states have either passed legislation or issued regulatory guidance concerning AI.
−Removed: Additionally, the National Association of Insurance Commissioners ("NAIC"), an organization of state insurance regulators, recently established the Innovation, Cybersecurity and Technology Committee to provide a forum for regulators to learn about, monitor and confer on emerging technology issues, including, among others, cybersecurity and AI.
−Removed: State Departments of Insurance and other state government agencies and legislatures are increasingly aware and active in providing guidance in the AI space.
+Added: The FTC has also been active with respect to companies' use of data and AI, specifically ensuring fair and equitable use of these tools, and AI remains an FTC area of enforcement focus.
+Added: More broadly, the federal government has made AI development a priority, with executive orders from successive administrations addressing its adoption and regulation.
+Added: state legislatures and regulators are similarly interested in the use of AI, particularly where it may impact decision-making in the delivery of insurance or health care services.
+Added: A handful of states, such as California, Colorado and Texas, have either passed legislation or issued regulatory guidance concerning AI.
+Added: Additionally, the National Association of Insurance Commissioners ("NAIC"), an organization of state insurance regulators, established the Innovation, Cybersecurity and Technology Committee to provide a forum for regulators to learn about, monitor and confer on emerging technology issues, including, among others, cybersecurity and AI.
+Added: State Departments of Insurance, state attorneys general, and other state government agencies and legislatures are increasingly aware and active in providing guidance in the AI space.
The Cybersecurity Information Sharing Act of 2015 encouraged organizations to share cyber threat indicators with the federal government and, among other things, directed HHS to develop a set of voluntary cybersecurity best practices for organizations in the health care industry.
−Removed: States have also begun to issue regulations specifically related to cybersecurity, which may differ or conflict from state to state.
+Added: States have issued regulations specifically related to cybersecurity, which may differ or conflict from state to state.
In October 2017, the NAIC adopted the Insurance Data Security Model Law, which creates rules for insurers and other covered entities addressing data security, investigation and notification of breaches.
3 unchanged sentences
Over the past several years, the federal government has increasingly focused on the cybersecurity requirements applicable to government contractors, including enhanced guidance and regulation.
−Removed: These include compliance with the Privacy Act of 1974, the Defense Federal Acquisition Regulation Supplement cybersecurity requirements, the Cybersecurity Maturity Model Certification (going into effect over the next four years and based on the National Institute of Standards and Technology ("NIST") standards), the Federal Information Security Modernization Act and the White House's 2021 Executive Order on Improving the Nation's Cybersecurity.
−Removed: In addition, we are or may become subject to international laws, rules and regulations governing privacy, data protection, information security, AI and wider data regulation, such as the European Union's General Data Protection Regulation ("GDPR"), Artificial Intelligence Act and Digital Operational Resilience Act, which can be more stringent than those in the United States.
+Added: These include compliance with the Privacy Act of 1974, the Defense Federal Acquisition Regulation Supplement cybersecurity requirements, the Cybersecurity Maturity Model Certification (phasing in between November 2025 and November 2028 and based on the National Institute of Standards and Technology ("NIST") standards), the Federal Information Security Modernization Act, and the White House's 2021 Executive Order on Improving the Nation's Cybersecurity.
+Added: Certain of our businesses are also subject to the Payment Card Industry Data Security Standard ("PCI DSS"), which is designed to protect credit card account data as mandated by payment card industry entities.
+Added: In addition, we are or may become subject to international laws, rules and regulations governing privacy, data protection, information security, AI and wider data regulation, such as the European Union's General Data Protection Regulation ("GDPR"), the European Union Artificial Intelligence Act (the "EU AI Act"), and the Digital Operational Resilience Act, which can be more stringent than those in the United States.
Complying with these laws may increase our compliance costs or necessitate changes to our business activities, and any failure to comply could result in regulatory investigations, fines or other penalties.
4 unchanged sentences
We face increased risk under such laws and may be subject to consumer or other lawsuits, penalties, enforcement actions and sanctions.
−Removed: The FTC and state attorneys general are also increasingly exercising their regulatory and enforcement authorities in the areas of consumer privacy and data security.
−Removed: State and federal policymakers have taken actions intended to increase transparency and predictability of health care costs for consumers.
−Removed: For example, the Transparency in Coverage rule issued by the HHS, the DOL and the Department of the Treasury now requires most group health plans and health insurance issuers in the individual and group markets to publicly disclose price and cost-sharing information for all items and services to participants and enrollees.
−Removed: Congress also passed the No Surprises Act, which prohibits health care providers, in certain situations, from balance billing the patient and requires that they work directly with insurers to agree on out-of-network reimbursement, including utilizing an independent dispute resolution process outlined in the act.
−Removed: Many states already have addressed balance billing or surprise medical bills.
−Removed: These laws and regulations vary in their approach, resulting in different impacts on the health care system as a whole.
+Added: The FTC and state attorneys general are also increasingly exercising their regulatory and enforcement authorities in the areas of consumer privacy, including with respect to drug pricing, rebate, formulary or contracting practices, and data security.
+Added: State and federal policymakers have taken actions intended to increase transparency and predictability of health care costs for consumers and protect consumers from certain out-of-network surprise bills.
+Added: For example, the Transparency in Coverage rule issued by HHS, the DOL and the Department of the Treasury now requires most group health plans and health insurance issuers in the individual and group markets to publicly disclose price and cost-sharing information for all items and services to participants and enrollees.
+Added: The federal No Surprises Act and state laws prohibit health care providers, in certain situations, from balance billing the patient and require providers to work directly with insurers to agree on out-of-network reimbursement or use defined arbitration processes like independent dispute resolution.
+Added: These laws and regulations vary in their approach, impacting consumers and the health care system as a whole.
Additionally, most states have consumer protection laws that have been the basis for investigations and multistate settlements relating to financial incentives provided by drug manufacturers to retail pharmacies in connection with product conversion programs.
Such statutes have also been cited as the basis for claims or investigations by state attorneys general relative to privacy and data security.
+Added: Further, states continue to leverage their market conduct examination authority in both the health insurance and PBM contexts, which adds to the regulatory complexity that exists in the health care space.
+Added: Employee Retirement Income Security Act
+Added: Our domestic subsidiaries sell most of their products and services to sponsors of employee benefit plans that are governed by ERISA.
+Added: ERISA is a complex set of federal laws and regulations enforced by the IRS and the DOL, as well as the courts.
+Added: ERISA regulates certain aspects of the relationship between us, the employers that maintain employee welfare benefit plans subject to ERISA and the participants in such plans.
+Added: Certain of our domestic subsidiaries are also subject to requirements imposed by ERISA affecting claim payment and appeals procedures for individual health insurance and insured and self-insured group health plans and for the insured plans we administer.
+Added: Medicare and Medicaid Regulations
+Added: Through our subsidiaries, we provide services to Medicare Part D plan sponsors, Medicare Advantage Prescription Drug Plans, and employers and clients offering Medicare Part D benefits to Medicare Part D eligible beneficiaries, including those dually eligible for Medicare and Medicaid benefits ("dual-eligible").
+Added: We participate in state Medicaid programs directly or indirectly through our clients that are Medicaid managed care contractors.
+Added: We also perform certain Medicaid subrogation services and certain delegated services for clients, including utilization management, which are regulated by federal and state laws.
+Added: Government-sponsored health care programs are regulated by HHS and its agencies such as CMS, state Medicaid agencies, the HHS-OIG, DOJ, and other federal and state agencies, and we are subject to risks associated with audits of our performance and audits to determine compliance with contracts and regulations.
+Added: A company's ability to obtain payment (and the determination of the amount of such payments) and retain business is subject to compliance with CMS' numerous and complex regulations and requirements that are subject to administrative discretion, review and enforcement.
+Added: In July 2025, Congress enacted the Budget Reconciliation Act of 2025, which included provisions affecting Medicare and Medicaid, including measures expected to reduce federal Medicaid spending and modify Medicaid eligibility, among other changes.
+Added: Noncompliance with state and federal laws and regulations may result in significant consequences, including fines and penalties, exclusion from the Medicare and Medicaid programs, corrections of improper payments and criminal penalties.
+Added: On March 19, 2025, the Company completed the HCSC transaction.
+Added: See Note 5 to the Consolidated Financial Statements for further information.
Office of Foreign Assets Control Sanctions and Anti-Money Laundering
9 unchanged sentences
We believe that our health services operations comply with applicable state statutes regarding corporate practice of medicine, fee-splitting and similar issues.
−Removed: However, any enforcement actions by governmental officials alleging noncompliance with these statutes could subject us to penalties or restructuring or reorganization of our business.
−Removed: Laws and Legislation Affecting Pharmacy Benefit Plan Design, Administration and Pharmacy Network Access
−Removed: Some states have enacted laws that prohibit plan sponsors from implementing certain restrictive benefit plan design features, and many states have laws or have introduced legislation to regulate various aspects of plans, including provisions relating to the pharmacy benefit.
−Removed: Some states have also enacted legislation that can negatively impact the use of cost-saving network configurations for plan sponsors, such as limiting the implementation of pharmacy benefit designs and reimbursement structures that leverage affiliate pharmacies to reduce costs.
−Removed: CMS and some states have issued laws, guidance and regulations that impose restrictions that generate additional costs and limit our ability to maximize efficiencies, such as those that could otherwise be gained through certain prescription and refill processes.
−Removed: Some states mandate or have proposed to mandate coverage of certain benefits, conditions and U.S.
−Removed: Food and Drug Administration ("FDA")-approved drugs and to restrict certain therapeutic interventions.
−Removed: Additionally, Medicare Part D and most states now have laws, regulations or some form of legislation affecting our ability, or our clients' ability, to limit access to a pharmacy provider network or remove a provider from a network.
−Removed: Certain states have laws prohibiting certain pharmacy benefit management clients from imposing additional copayments, deductibles, limitations on benefits or other conditions on covered individuals utilizing a retail pharmacy when the same conditions are not otherwise imposed on covered individuals utilizing home delivery pharmacies.
−Removed: However, the laws require the retail pharmacy to agree to the same reimbursement amounts and terms and conditions as are imposed on the home delivery pharmacies.
−Removed: An increase in the number of prescriptions filled at retail pharmacies may have a negative impact on the number of prescriptions filled through home delivery.
−Removed: Pharmacy Benefit Manager and Drug Pricing Regulation
−Removed: Our pharmacy benefit management services are subject to numerous laws and regulations that govern, and proposed legislation and regulations that may govern, critical practices, including disclosure, receipt and retention of rebates and other payments received from pharmaceutical manufacturers;
−Removed: certain pharmacy contracting practices, including disclosure of cost information to customers;
−Removed: pharmacy reimbursement mandates;
−Removed: the receipt and retention of transmission fees from contracted pharmacies;
−Removed: performance-based price concessions;
−Removed: pharmacy price concessions to drug prices at the point of sale;
−Removed: audits of contracted pharmacies;
−Removed: use of, administration of or changes to drug formularies, the use and disclosure of maximum allowable cost ("MAC") pricing, or clinical programs;
−Removed: "most favored nation" pricing, which provides that a pharmacy participating in a specific government program must give the program the best price the pharmacy makes available to any third-party plan;
−Removed: disclosure of data to third parties;
−Removed: drug utilization management practices;
−Removed: the level of duty a pharmacy benefit manager owes its clients or customers;
−Removed: configuration of pharmacy networks;
−Removed: the operations of our subsidiary pharmacies;
−Removed: referrals to affiliated pharmacies;
−Removed: disclosure of negotiated provider reimbursement rates;
−Removed: disclosure of negotiated drug rebates;
−Removed: calculation of certain customer cost-share for prescription drug claims;
−Removed: pricing that includes differential or spread (i.e., a difference between the drug price charged to the plan sponsor by a pharmacy benefit manager and the price paid by the manager to the dispensing provider);
−Removed: disclosure of fees associated with administrative service agreements and patient care programs that are attributable to customers' drug utilization;
−Removed: utilization management;
−Removed: and registration or licensing of pharmacy benefit managers.
−Removed: We expect federal and state governments to continue to prioritize means of addressing vertical integration and out-of-pocket costs for consumers, particularly related to prescription drug costs.
−Removed: Recently enacted legislation, such as the Inflation Reduction Act and other policy proposals and regulations, including proposed legislation aimed at providing transparency with respect to pharmacy benefit managers, vary broadly in their approaches to achieve that goal.
−Removed: Additionally, proposals at the federal and state levels consider increased regulation of pharmacy benefit managers and health plans as a means to limit consumer out-of-pocket costs.
−Removed: The NAIC has also proposed laws intended to protect consumer drug benefits and has examined regulatory approaches to pharmacy benefit manager business practices.
−Removed: Some states have enacted statutes referred to as "MAC Transparency Laws" regulating the use of MAC pricing.
−Removed: MAC Transparency Laws generally require pharmacy benefit managers to disclose specific information related to MAC pricing to pharmacies and provide certain appeal rights for pharmacies.
−Removed: MAC Transparency Laws also restrict the application of MAC and may require operational changes to maintain compliance with the law.
−Removed: Some states have also enacted laws regulating pharmacy pricing and protecting the profitability of pharmacies for dispensing certain MAC-priced drugs.
−Removed: Some states have enacted laws requiring that the customer cost-share for a prescription drug claim not exceed certain price points, such as the pharmacy's usual and customary charge or its contracted reimbursement for the drug.
−Removed: In a recent Supreme Court decision, the Court found that certain MAC Transparency Laws may be applied by states to ERISA plans in addition to health plans regulated by the applicable state.
−Removed: Following this decision, state legislatures and regulators have sought to extend their oversight authority of self-funded ERISA plans to pharmacy benefit management functions and pharmacy benefit plan designs beyond MAC pricing.
−Removed: Pharmacy Regulation
−Removed: We are licensed to do business as a pharmacy in the states in which our pharmacies are located, and the health care professionals who we employ are also licensed by, and subject to, the laws and regulations of state boards of pharmacy and other governmental authorities.
−Removed: Participation in Medicare and Medicaid programs requires our pharmacies to comply with the applicable Medicare and Medicaid provider rules and regulations and exposes the pharmacies to reimbursement, claims submission, pricing and other changes.
−Removed: In addition to the health care fraud and abuse laws and the privacy and security laws described above, our home delivery and specialty pharmacy operations are also subject to extensive federal and state laws and regulations that govern the labeling, packaging, repackaging, compounding, storing, holding, disposal, distribution, advertising, misbranding, adulteration, transfer, handling and security of prescription drugs and the dispensing of prescription, over-the-counter, hazardous and controlled substances, as well as laws enforced by the U.S.
−Removed: Drug Enforcement Administration, the FDA, state-controlled substance authorities, the FTC and the United States Postal Service.
−Removed: Violations of pharmacy laws and regulations may result in warning letters, civil and criminal penalties, seizures, suspension, termination or revocation of licenses and registrations, restrictions on facilities or operations, and other enforcement actions.
+Added: However, any enforcement actions by government officials alleging noncompliance with these statutes could subject us to penalties or restructuring or reorganization of our business.
Financial Reporting, Internal Control and Corporate Governance
2 unchanged sentences
Our insurance and HMO subsidiaries are required to file periodic financial reports and schedules with regulators in most of the jurisdictions in which they do business as well as annual financial statements audited by independent registered public accounting firms.
−Removed: Certain insurance and HMO subsidiaries are required to file an annual report of internal control over financial reporting with
−Removed: most jurisdictions in which they do business.
+Added: Certain insurance and HMO subsidiaries are required to file an annual report of internal control over financial reporting with most jurisdictions in which they do business.
Insurance and HMO subsidiaries' operations and financial statements are subject to examination by regulators.
3 unchanged sentences
jurisdictions require insurance companies to support guaranty associations or indemnity funds that are established to pay claims on behalf of insolvent insurance companies.
−Removed: Some states have similar laws relating to HMOs and other payors, such as consumer operated and oriented plans (co-ops) established under the ACA.
+Added: Some states have similar laws relating to HMOs.
In the United States, these associations levy assessments on member insurers licensed in a particular state to pay such claims.
Certain states require HMOs to participate in guaranty funds, special risk pools and administrative funds.
−Removed: Additionally, certain states continue to require health insurers and HMOs to participate in assigned risk plans, joint underwriting authorities, pools or other residual market mechanisms to cover risks not acceptable under normal underwriting standards, although some states have eliminated these requirements as a result of the ACA.
Solvency and Capital Requirements
8 unchanged sentences
Holding Company Laws
−Removed: Our domestic insurance companies and certain of our HMOs are subject to state laws regulating subsidiaries of insurance holding companies.
−Removed: Under such laws, certain dividends, distributions and other transactions between an insurance company or an HMO subsidiary and its affiliates may require notification to, or approval by, one or more state insurance commissioners.
−Removed: In addition, the holding company acts of states in which our subsidiaries are domiciled restrict the ability of any person to obtain control of an insurance company or HMO subsidiary without prior regulatory approval.
+Added: Our insurance companies and most of our HMOs are regulated under state insurance holding company laws and regulations, which are largely based on the NAIC’s Insurance Holding Company System Regulatory Act and its companion model regulation.
+Added: These regulations provide a framework for monitoring risks in insurance groups and generally require registration with the applicable state insurance departments;
+Added: disclosure of enterprise risk information;
+Added: and approvals of certain dividends, distributions and affiliate transactions.
+Added: The regulations also generally require approval for acquisitions of control of an insurance company or HMO and authorize group-wide supervision to assess risk across the holding company structure, including the use of group capital calculation reporting and associated liquidity stress testing.
+Added: The Cigna Group is subject to such testing as may be required by our lead state regulator.
Marketing, Advertising and Products
In most states, our insurance companies and HMO subsidiaries are required to certify compliance with applicable advertising regulations on an annual basis and comply with certain federal and state marketing, advertising, and communications laws and regulations.
−Removed: In April 2023, CMS issued a final rule revising regulations governing marketing by Medicare Advantage and Medicare Part D plans, which requires, among other things, enrollees to be notified of their ability to opt out of phone calls regarding Medicare Advantage and Part D marketing, requires agents to explain the effect of an enrollee's enrollment choice on their current coverage, simplifies plan comparisons by requiring medical benefits to be listed in a specific order at the top of a plan's Summary of Benefits, requires Medicare Advantage organizations and Part D sponsors to have an oversight plan that monitors activities of agents and brokers and to report noncompliance to CMS, and limits the time a potential enrollee may be contacted about Medicare plan options to 12 months after the enrollee first asked for information.
Licensing, Registration and Utilization Management Requirements
4 unchanged sentences
laws standardizing the process for, and restricting the use of, utilization management rules;
−Removed: and laws shortening the time
−Removed: frames within which prescription drug prior authorization determinations must be made.
+Added: and laws shortening the time frames within which prescription drug prior authorization determinations must be made.
The inability to apply pre-authorization requirements could lead to increased costs to plan sponsors and issuers by way of the provision of unnecessary services.
The licensure requirements for our insurance companies and subsidiaries vary by jurisdiction and are subject to change.
+Added: Pharmacy and Professional Practice Requirements
+Added: State pharmacy professional practice laws, enforced by state boards of pharmacy, govern both the operation of the pharmacy as a licensed facility and the scope of practice of pharmacists and pharmacy technicians.
+Added: These laws establish the definition of the “practice of pharmacy,” outlining authorized professional functions such as compounding, dispensing, labeling, drug‑therapy management, and patient counseling, while specifying nondiscretionary tasks permitted for pharmacy technicians.
+Added: State boards of pharmacy also oversee pharmacy licensure and facility compliance, including requirements related to physical premises, storage conditions, security measures, prescription processing, recordkeeping, and adherence to federal and state controlled‑substance standards.
+Added: State law further defines operational parameters for pharmacies offering clinical services - such as collaborative drug‑therapy management, immunization programs, or test‑and‑treat protocols by establishing relevant documentation, supervision and procedural requirements.
International Regulations
2 unchanged sentences
Our operations in countries outside of the United States are subject to local regulations of the jurisdictions where we operate.
−Removed: in some cases, they are subject to regulations in the jurisdictions where customers reside;
−Removed: and in all cases, they are subject to the Foreign Corrupt Practices Act ("FCPA").
+Added: In some cases, they are subject to regulations in the jurisdictions where customers reside, and in all cases, they are subject to the Foreign Corrupt Practices Act ("FCPA").
The FCPA prohibits offering, promising, providing or authorizing others to give anything of value to a foreign government official or employee to obtain or retain business or otherwise secure a business advantage.
10 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.