Humana Loses BILLIONS, Humana Medicare Advantage Ratings Lawsuit, Judge Crushes Medicare Lawsuit TWICE—Millions of Seniors at Risk
Humana just suffered a devastating legal blow that could cost the insurance giant up to $3 BILLION and leave millions of Medicare Advantage members scrambling. In a shocking double dismissal, a federal judge rejected Humana’s desperate lawsuit challenging Medicare star ratings—not once, but TWICE. The Humana Medicare Advantage lawsuit collapse threatens to upend healthcare coverage for 25% of its members who just lost their 4-star protection.
The Shocking Truth Behind Humana’s Medicare Star Ratings Catastrophe
Humana’s average star score plummeted from 4.37 in 2024 to 3.63 for 2025—the largest drop of any major Medicare Advantage insurer. This dramatic decline triggered legal proceedings that captured national attention.
The insurance giant argued that CMS acted “arbitrarily and capriciously” in calculating the ratings. Humana described the program’s data and calculations as “dizzyingly complex” and claimed it was denied an opportunity to validate the accuracy of CMS’ calculations.
What Are Medicare Advantage Star Ratings?
Medicare Advantage star ratings measure health plan quality on a scale from 1 to 5 stars. These ratings evaluate:
- Member experience with the health plan
- Customer service responsiveness
- Management of chronic conditions
- Access to preventive services
- Member complaints and appeals handling
Why ratings matter: Plans achieving 4 stars or higher receive quality bonus payments from Medicare, which directly translate to enhanced benefits for members and competitive advantages in the marketplace.
Court Delivers Crushing Double Blow: Two Dismissals and Mounting Losses
First Dismissal: July 2025
U.S. District Judge Reed O’Connor dismissed Humana’s initial lawsuit on July 18, 2025, ruling that the case was “premature” because Humana had not exhausted the administrative appeals process before filing suit.
The judge determined that existing case law requires courts to evaluate alleged harms “at the time of the action brought”. Since Humana filed its lawsuit before receiving the CMS appeal decision, the court lacked jurisdiction.
Key details of the first dismissal:
- Court: Northern District of Texas
- Dismissal type: Without prejudice (allowing refiling)
- Stock impact: Humana’s stock fell 3% following the decision
- CMS appeal status: The agency denied Humana’s appeal in April, six months after the initial complaint was filed
Second Dismissal: October 2025
After the first dismissal, Humana refiled its complaint to address procedural concerns. However, Judge O’Connor dismissed the case again on October 14, 2025, this time with prejudice, meaning it cannot be refiled but could still be appealed.
The second ruling focused on the merits of Humana’s claims. Judge O’Connor determined that CMS’ no-callbacks policy is legal, and therefore the regulators’ ratings of several dropped calls were not arbitrary or capricious.

The Customer Service Call Controversy
A central issue in Humana’s legal challenge involved how CMS evaluates foreign language interpreter services.
The testing method: CMS makes test calls that require a translator and rates them as completed successfully or unsuccessfully.
Humana’s complaint: The insurer challenged lowering its stars based on three allegedly mishandled customer service phone calls.
Court’s perspective: The judge ruled that CMS’ methodology for assessing call center performance, including the no-callbacks policy, complies with established regulations and does not constitute arbitrary decision-making.
BILLIONS at Stake: The Staggering Financial Meltdown
The star ratings downgrade carries severe financial consequences for Humana and its members.
Revenue Impact
Analysts estimate that Humana could lose $1 billion to $3 billion in 2026 as a result of the star ratings drop. This massive revenue reduction stems from lost quality bonus payments tied to the rating system.
Membership Affected
Only 25% of Humana’s Medicare Advantage members are in a plan with four stars or above in 2025, compared to 94% the previous year. This represents a catastrophic shift affecting millions of beneficiaries.
The Business Context
Star ratings affect bonus payments to Medicare Advantage insurers that they use to increase benefits and attract new members. Plans of 4 stars and higher earn bonuses. The Medicare Advantage market represents an estimated $500 billion industry.
Legal Arguments Presented by Both Sides
Humana’s Position
The insurance company’s lawsuit raised several key arguments:
- Cut point manipulation: Humana accused CMS of playing fast and loose with cut points, or the threshold for reaching each star level
- Lack of transparency: The insurer claimed CMS failed to let it verify star ratings calculations
- Methodological changes: Humana discovered changes to the agency’s methodology where several measures were “moved abruptly and substantially upward, significantly depressing star ratings”
- Data validation concerns: The company argued it couldn’t determine why measure-level cut points moved unexpectedly in the 2025 scores
CMS’ Defense
The federal agency maintained that:
- All calculations followed established regulations and methodology
- The ratings system underwent proper notice-and-comment rulemaking
- Quality measure changes were transparent and properly implemented
- The no-callbacks policy for customer service testing is legally sound
Broader Context: Industry-Wide Star Ratings Challenges
Humana wasn’t alone in challenging the 2025 star ratings. The insurer followed UnitedHealth Group and Elevance last fall in filing a lawsuit against CMS and HHS over the star ratings results.
UnitedHealth’s outcome: UnitedHealth won its lawsuit in late 2024. CMS appealed and then dropped the appeal, suggesting some vulnerability in the rating system’s implementation.
The Numbers Tell the Story
Thirty-four Medicare Advantage plans earned 5 stars in the 2025 ratings for 2026, compared with only seven plans for the 2025 plan year and 38 contracts that received 5 stars for 2024.
This volatility in ratings distribution raises questions about system stability and predictability for both insurers and beneficiaries.
What This Means for Medicare Advantage Beneficiaries
Current Policyholders
If you’re enrolled in a Humana Medicare Advantage plan:
- Your coverage continues: The lawsuit dismissal doesn’t affect your current benefits or coverage
- Potential benefit reductions: Lower star ratings may result in reduced supplemental benefits in future plan years
- Premium changes: You might see premium adjustments as Humana works to offset lost bonus revenue
- Quality monitoring: Continue tracking your plan’s performance through Medicare’s official Plan Finder tool
Future Enrollment Considerations
When selecting Medicare Advantage plans:
- Check current star ratings on Medicare.gov
- Review how ratings have changed year-over-year
- Consider plan stability and financial strength
- Compare benefits across multiple highly-rated options
- Consult with a licensed insurance advisor about your specific needs
Humana’s Response and Future Plans
Following the October 2025 dismissal, a Humana spokesperson stated: “We are disappointed with the Court’s ruling but remain committed to delivering meaningful improvements to our Star measurements and returning to top quartile performance as quickly as possible”.
Company Strategy Moving Forward
During its June investor day, Humana executives said they submitted Medicare Advantage bids for 2026 assuming they did not win the suit. The insurer expects it won’t achieve the total points required for a four-star rating until the 2028 bonus year.
This timeline suggests:
- Multi-year recovery period
- Significant operational changes underway
- Continued financial pressure on the business
- Potential service adjustments for members
Comparing Similar Medicare Advantage Litigation Cases
UnitedHealth’s Victory vs. Humana’s Defeat
The contrasting outcomes highlight different legal strategies and timing:
Factor | UnitedHealth | Humana |
Timing | Completed appeals process first | Filed before appeal completion |
Outcome | Won lawsuit | Lost twice (dismissed) |
CMS Response | Appealed then dropped | Defended successfully |
Procedural Status | Followed proper exhaustion | Premature filing initially |
Lessons from Other Insurers
Other Medicare Advantage providers facing similar star ratings challenges may learn from Humana’s procedural missteps, particularly the importance of exhausting administrative remedies before pursuing federal litigation.
The Regulatory Framework: Medicare Advantage Quality Ratings System
Understanding the legal requirements helps contextualize Humana’s legal challenges.
Key Regulations Governing Star Ratings
The star ratings system operates under:
- Fair Labor Standards Act (FLSA) principles for employee-related measures
- Social Security Act provisions for Medicare program administration
- Administrative Procedure Act (APA) standards for agency rulemaking
- CMS Final Rules establishing specific methodology and cut points
Changes to Methodology
In its original lawsuit, Humana argued there were potential errors in CMS’ calculations of its results and industry cut points. The company’s reduction in star ratings was driven by narrowly missing higher industry cut points on a small number of measures.
This cost the company more than $1 billion in bonuses distributed to plans scoring 4 stars or higher.

Expert Analysis: Why the Court Ruled Against Humana
Legal experts point to several factors in the unfavorable rulings:
Procedural Requirements
Federal courts require plaintiffs to exhaust administrative remedies before seeking judicial review. This doctrine serves important purposes:
- Allows agencies to correct their own errors
- Develops a complete factual record
- Prevents premature judicial intervention
- Respects agency expertise and authority
Substantive Standards
Under the Administrative Procedure Act, courts review agency actions deferentially. CMS’ decisions receive deference unless they are:
- Arbitrary and capricious
- Not in accordance with law
- Unsupported by substantial evidence
- Procedurally defective
The court found CMS met all legal requirements in calculating and applying the star ratings.
Frequently Asked Questions About the Humana Medicare Advantage Lawsuit
Can Humana appeal the October 2025 dismissal?
Yes. Although the case was dismissed with prejudice (meaning it cannot be refiled in district court), Humana can appeal to the U.S. Court of Appeals for the Fifth Circuit. The company indicated it is considering “all available legal options.”
How does this affect my Humana Medicare Advantage plan?
The lawsuit dismissal doesn’t immediately change your current coverage or benefits. However, lower star ratings may result in reduced supplemental benefits, higher premiums, or fewer bonus features in future plan years as Humana receives fewer quality bonus payments from Medicare.
What are Medicare Advantage star ratings and why do they matter?
Medicare Advantage star ratings evaluate health plan quality on a 5-star scale based on customer satisfaction, care quality, and member experience. Plans with 4+ stars receive quality bonus payments from Medicare, which insurers use to enhance benefits, reduce premiums, and improve services for members.
Were there errors in how CMS calculated Humana’s star ratings?
Humana alleged errors in CMS calculations and methodology changes. However, the federal court ruled that CMS’ calculation methods, including the no-callbacks policy for customer service testing, were legal and not arbitrary or capricious. The court found no evidence of improper conduct by the agency.
How much money could Humana lose due to lower star ratings?
Analysts estimate Humana could lose between $1 billion and $3 billion in revenue during 2026 due to reduced quality bonus payments. This represents a significant financial impact on the second-largest Medicare Advantage insurer in the United States.
Did other Medicare Advantage insurers sue over star ratings?
Yes. UnitedHealth Group and Elevance Health also filed lawsuits challenging their 2025 star ratings. UnitedHealth won its lawsuit in late 2024, though CMS initially appealed before dropping the appeal. This suggests some insurers successfully challenged the ratings methodology.
What happens next for Humana policyholders?
Humana policyholders should:
- Monitor plan communications for any benefit changes
- Review star ratings annually during open enrollment
- Compare alternative plans if concerned about quality
- Consult with licensed insurance advisors about coverage options
- Stay informed about Humana’s quality improvement initiatives
Implications for the Medicare Advantage Industry
The Humana Medicare Advantage lawsuit dismissals send important signals to the healthcare insurance industry:
Precedent for Future Challenges
Courts will strictly enforce procedural requirements, particularly exhausting administrative remedies before seeking judicial review. Insurers considering legal challenges must complete all CMS appeal processes first.
Rating System Stability
Despite industry pushback, federal courts have validated CMS’ authority to implement and modify the star ratings methodology. This strengthens the agency’s position in setting quality standards.
Financial Planning Considerations
Medicare Advantage insurers must build greater contingency into financial planning to account for potential star ratings volatility and resulting revenue fluctuations.
Conclusion: Navigating the Aftermath of the Lawsuit Dismissals
The double dismissal of the Humana Medicare Advantage lawsuit represents a significant legal setback for the insurance giant and establishes important precedent for healthcare litigation. While Humana explores appeal options, the immediate impact includes billions in lost revenue and reduced competitive positioning in the Medicare Advantage marketplace.
For Medicare beneficiaries, understanding these developments helps inform enrollment decisions and expectations about future plan benefits. The star ratings system, despite its controversies, remains the primary tool for evaluating Medicare Advantage plan quality.
Key Takeaways
- Humana’s lawsuit was dismissed twice—first for being premature, then on the merits
- The company faces $1-3 billion in lost revenue from lower star ratings
- Federal courts validated CMS’ rating methodology and no-callbacks policy
- Medicare beneficiaries should monitor plan ratings annually during open enrollment
- The precedent emphasizes exhausting administrative remedies before federal litigation
Additional Resources
For more information about Medicare Advantage and healthcare litigation:
- Medicare Plan Finder: Compare star ratings at Medicare.gov
- CMS Star Ratings Information: Official methodology documentation
- State Health Insurance Assistance Programs (SHIP): Free local counseling
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Legal Disclaimer: This article provides educational information about the Humana Medicare Advantage lawsuit and court proceedings. It does not constitute legal advice, and readers should not rely on this information as a substitute for professional legal counsel. If you have specific questions about your Medicare Advantage coverage or need legal representation, consult with a qualified attorney licensed in your jurisdiction. Healthcare laws and regulations vary by state and change frequently. Always verify current information with official sources.
Last Updated: October 2025
About the Author

Sarah Klein, JD, is a licensed attorney and legal content strategist with over 12 years of experience across civil, criminal, family, and regulatory law. At All About Lawyer, she covers a wide range of legal topics — from high-profile lawsuits and courtroom stories to state traffic laws and everyday legal questions — all with a focus on accuracy, clarity, and public understanding.
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