Milliman $15.5 Million Class Action Settlement, Who Qualifies for Payments Over Inaccurate Life Insurance Reports?

Milliman Inc., which sells IntelliScript medical and prescription history reports to life insurers, has agreed to pay $15.5 million to settle a nationwide Fair Credit Reporting Act (FCRA) class action. The plaintiffs filed the proposed settlement for preliminary court approval on Monday, October 26, 2026, in the U.S. District Court for the Western District of Washington. The case is Healy, et al. v. Milliman Inc., No. 2:20-cv-01473.

This is a proposed settlement, not an approved one. As of November 4, 2026, the court has not granted preliminary approval, there is no claim form, no claim deadline and no payment date. Milliman denies the allegations and has not admitted wrongdoing.

Milliman $15.5 Million Settlement Quick Facts

Detail	Information
Settlement amount	$15,500,000
Defendant	Milliman Inc., doing business as IntelliScript
Case	Healy, et al. v. Milliman Inc., No. 2:20-cv-01473
Court	U.S. District Court, Western District of Washington
Case filed	October 5, 2020
Proposed settlement filed for preliminary approval	October 26, 2026
Lead plaintiff	James Healy
Law	Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq.
Estimated class size	About 780,965 U.S. residents across three classes (per reported terms)
Amount for class-member claims	About $9 million (per reported terms)
Estimated payment	Roughly $30 to $1,000 per valid claim, an estimate by class counsel
Fund type	Non-reversionary (no money returns to Milliman)
Eligibility period cutoff	June 30, 2026 (this is not a claim deadline)
Status	Preliminary approval pending
Claim form and deadline	Not yet available or announced
Official settlement website	Not yet launched. It is expected to be published in the court-approved notice after preliminary approval.
Class counsel	Beth E. Terrell, Jennifer Rust Murray and Blythe H. Chandler of Terrell Marshall Law Group PLLC; James A. Francis, John Soumilas, Lauren KW Brennan and Travis Martindale-Jarvis of Francis Mailman Soumilas, P.C.
Court docket	Healy v. Milliman Inc. docket (Justia)

The class size, allocation, points and payment estimates come from reports of the proposed agreement. The settlement agreement and court-approved notice will control.

What Is the Milliman IntelliScript Class Action About?

When you apply for life insurance, the insurer may buy a report on your medical and prescription history. Milliman’s IntelliScript service compiles those reports from sources such as pharmacies, pharmacy benefit managers and health insurers, and sells them to insurers for underwriting decisions.

The lawsuit alleges Milliman used flawed matching procedures, including “fuzzy matching” on similar names and other identifiers rather than exact matches, so that one person’s medical records could appear in another person’s report. It also alleges that Milliman did not properly reinvestigate disputes and gave incomplete file disclosures to consumers who asked for their reports.

What happened to James Healy?

According to the Ninth Circuit’s January 9, 2026 opinion and reporting on it, Healy applied for life insurance through Americo in April 2020. Milliman’s report allegedly included another person’s medical records and Social Security number, labeled Healy high-risk, and led to Americo denying his application. He says he repeatedly asked Milliman to fix the errors and that Milliman did not promptly investigate or correct them.

These are allegations. No court has found that Milliman violated the FCRA.

How Does Milliman IntelliScript Matching Work?

Per the Ninth Circuit’s description, an insurer sends Milliman applicant details such as name, date of birth, gender, Social Security number and ZIP code. Milliman matches those to medical and prescription records, mostly using Social Security numbers and in some cases using fuzzy matching on other identifiers. Reports carry red, yellow and green flags based on the insurer’s underwriting criteria, and a red flag can signal that the applicant should be declined.

The case focuses on whether Milliman’s procedures were reasonable to make sure records were matched to the right person.

Who Qualifies? The Three Proposed Milliman Settlement Classes

The classes below are the reported proposed definitions. Exact definitions will be in the official notice. Qualifying for a class does not guarantee a payment, and you may need to submit a valid claim.

Class	Who it covers (as reported)	Points
Inaccuracy Class	Consumers whose Milliman report, sold from October 5, 2015 through June 30, 2026, included a medium- or high-risk medical or prescription record tied to a Social Security number that differed from theirs by more than two changes	5 (20 for certain higher-impact matches, such as the same matching pattern as Healy’s or a mismatched last name and birth date)
Reinvestigation Class	Consumers who disputed a Milliman report starting October 5, 2015 and received a form response or no timely resolution during the applicable period	3
File Disclosure Class	Consumers who requested their consumer file from Milliman from March 23, 2018 through June 30, 2026 and received a disclosure allegedly missing required information	1

A denied life insurance application by itself does not make you a class member. The inaccuracy class turns on the Social Security number mismatch and the risk level of the record. The reinvestigation class requires that you disputed your report. People can fall into more than one class.

How Much Could You Get From the Milliman Settlement?

The $15.5 million fund is not all paid to class members. About $9 million is reportedly set aside for valid claims. The rest covers attorneys’ fees and costs (subject to court approval), settlement administration and service awards to named plaintiffs.

Payments use a points system, so each valid claim gets a pro rata share based on total points claimed. Class counsel estimates payments of roughly $30 to $1,000. That is an estimate:

• It does not guarantee $1,000.
• Having claims in more than one class does not mean you receive the maximum for each.
• The final amount depends on the approved agreement, the number of valid claims and the points they carry.

Because the fund is non-reversionary, unclaimed money does not go back to Milliman. How any remainder is handled will be set by the approved agreement.

What Will Milliman Change Under the Settlement?

According to the reported terms, the settlement also requires business changes for at least five years:

• Automated mismatch checks to reduce wrong matches between records and applicants
• Better tracking of consumer disputes and how they are resolved
• More complete disclosures of reports compiled in the two years before a qualifying consumer request

What Law Applies? The Fair Credit Reporting Act

The FCRA covers more than credit reports. A report used to decide eligibility for insurance can be a “consumer report,” so a company that assembles and sells such reports can be a consumer reporting agency.

Provision	What it does	How it matters here
15 U.S.C. § 1681a(d) and (f)	Defines “consumer report” and “consumer reporting agency,” including reports used to establish eligibility for insurance	Brings IntelliScript underwriting reports within the FCRA
15 U.S.C. § 1681b	Lists permissible purposes, including insurance underwriting	Insurers may obtain these reports, but the agency must follow the Act
15 U.S.C. § 1681e(b)	Requires “reasonable procedures to assure maximum possible accuracy”	The core inaccuracy claim. See Guimond v. Trans Union Credit Information Co., 45 F.3d 1329 (9th Cir. 1995)
15 U.S.C. § 1681i	Requires a reasonable reinvestigation of disputed information, generally within 30 days, extendable by up to 15 days in some cases	The reinvestigation class
15 U.S.C. § 1681g	Requires disclosure of the information in your file and its sources	The file disclosure class
15 U.S.C. § 1681j(b)	Free file disclosure after certain adverse actions	Lets you get a free copy after an insurance denial based on a report
15 U.S.C. § 1681m	Adverse-action notice duties for users of reports, such as insurers	Insurer must tell you which agency supplied the report and your right to a free copy within 60 days
15 U.S.C. § 1681n	Remedies for willful violations: actual damages or $100 to $1,000 statutory damages, possible punitive damages, costs and attorney fees	Willfulness includes reckless disregard under Safeco Insurance Co. of America v. Burr, 551 U.S. 47 (2007)
15 U.S.C. § 1681o	Remedies for negligent violations: actual damages, costs and attorney fees	Individual claims
15 U.S.C. § 1681p	Statute of limitations: the earlier of two years after discovery or five years after the violation	Matters for anyone considering an individual claim

The insurer’s duties under § 1681m are separate from the reporting agency’s duties. An insurer is not automatically responsible for a reporting agency’s matching errors.

Procedure and Standing: What the Ninth Circuit and Federal Rules Add

The Ninth Circuit ruling (January 9, 2026)

The district court had granted Milliman partial summary judgment, finding Healy had not shown class-wide standing for the inaccuracy claims. In Healy v. Milliman, Inc., No. 24-3327 (9th Cir. Jan. 9, 2026), a unanimous panel reversed. It held that named and unnamed members of a certified damages class must present evidence of standing at summary judgment, under ordinary summary-judgment standards, which can include circumstantial evidence. The court cited the standing rule from TransUnion LLC v. Ramirez, 594 U.S. 413 (2021). The ruling did not decide whether Milliman violated the FCRA. Read the opinion.

How a class settlement gets approved

• Fed. R. Civ. P. 23(e): a court must approve a class settlement as fair, reasonable and adequate. It first decides whether it will likely approve the deal and notice should go out (preliminary approval), then holds a final fairness hearing.
• Rule 23(c)(2)(B) and 23(e)(5): class members can opt out or object, under the procedures in the court-approved notice.
• Rule 23(h): the court reviews class counsel’s fee request.
• Class Action Fairness Act, 28 U.S.C. § 1715: the defendant must notify federal and state officials of a proposed class settlement, and final approval cannot come until at least 90 days after that notice.

If you do nothing and the settlement is finally approved, you are generally bound by the release unless you opt out. Read the notice carefully before deciding.

Timeline of Healy v. Milliman

Date	Event
October 5, 2020	James Healy files the class action in the Western District of Washington
After filing	The district court certifies an inaccuracy class and a reinvestigation class
January 9, 2026	Ninth Circuit reverses partial summary judgment for Milliman and remands
March 20, 2026	Joint status report says the parties want to mediate. It identifies related cases Morris v. Milliman Inc., No. 2:23-cv-00446, and Michalski v. Milliman Inc., No. 2:26-cv-00615
October 26, 2026	Plaintiffs file an unopposed motion for preliminary approval of the $15.5 million settlement
October 27, 2026	Law360 reports the proposed deal
Next	Court decision on preliminary approval, then notice and claims, then final approval hearing

Do You Need to File a Claim? What to Do Now

No claim process is open yet. According to the reported proposal, class members would get notice by email or postcard and have at least 60 days after notice begins to file a claim online or by mail. Do not pay anyone, or give personal information to a website, that claims to file Milliman settlement claims for you before the official notice.

Documents worth keeping

• Life insurance applications, denial letters and adverse-action notices
• Copies of Milliman or IntelliScript reports
• Your requests for your Milliman file and Milliman’s responses
• Dispute letters, proof of delivery and supporting medical records
• Messages with the insurer about an inaccurate report

If an inaccurate medical record affected your life insurance application

1. Get the report. After an adverse action based on a consumer report, you generally have the right to a free copy from the reporting agency if you ask within 60 days.
2. Mark the errors. Compare the report to your actual medical and prescription history.
3. Dispute in writing. Identify each wrong record, explain why it is not yours, include supporting documents and keep proof of delivery.
4. Keep the response. Save Milliman’s investigation results.
5. Go back to the insurer. Ask whether it will reconsider after the report is corrected.

If a dispute is not properly handled, an FCRA or consumer protection attorney can explain your options. The deadline in 15 U.S.C. § 1681p can pass quietly, so do not wait.

How Is the Milliman Case Different From Other Credit Reporting Cases?

The Milliman case involves medical and prescription reports for life insurance underwriting. It is related to other FCRA matters, but the reports, defendants and eligibility rules differ. For other consumer reporting coverage, see:

• TransUnion Fraudulent Credit Report Block Class Action Lawsuit, Were You Denied an Identity Theft Block on Your Credit Report?
• Equifax Credit Reporting Error Settlement, Check If You Qualify
• GEICO $1,650,000 CLUE Report Settlement, Deadline Oct. 20

When Will Milliman Settlement Payments Be Sent?

There is no payment date. The order of events is:

1. The court rules on preliminary approval.
2. Notice goes to class members.
3. Class members file claims, or opt out or object, within the deadlines.
4. The court holds the final approval hearing.
5. If the court grants final approval and any appeals are resolved, the administrator calculates and sends payments.

Frequently Asked Questions About the Milliman $15.5 Million Settlement

Is the Milliman settlement approved?

No. As of November 4, 2026, it is proposed and awaiting preliminary approval.

Who qualifies for the Milliman settlement?

People in three proposed classes: inaccurate IntelliScript reports, mishandled disputes and incomplete file disclosures. Each class has specific criteria, so a denied application alone is not enough.

How much will I get?

Class counsel estimates roughly $30 to $1,000 per valid claim. The final amount depends on points and the number of valid claims. No payment is guaranteed.

Is the full $15.5 million going to class members?

No. About $9 million is reportedly allocated to class-member claims, and the rest covers fees, costs, administration and service awards, subject to court approval.

Is June 30, 2026 the claim deadline?

No. It is the end of the eligibility period for the proposed classes. No claim deadline has been announced.

Do I need proof of an inaccurate record?

The notice and claim form will say what is required. Keep your reports, letters and dispute records.

Is the settlement only for Washington residents?

No. It is described as nationwide, but you must meet one of the three class definitions.

Did Milliman admit its reports were inaccurate?

No. Milliman denies the allegations, and the settlement is not a finding of liability.

Is there an official Milliman settlement website?

Not yet. One is expected to be named in the court-approved notice after preliminary approval. Avoid unofficial registration sites.

Can I sue Milliman on my own instead?

The settlement does not replace your individual FCRA rights, but if the settlement is finally approved and you do not opt out, you may be giving up claims covered by the release. Speak with an attorney before deciding. Check the limitations period in 15 U.S.C. § 1681p.

Final Takeaway: The Milliman Settlement Is Proposed, Not Paid

Milliman’s proposed $15.5 million settlement targets inaccurate medical and prescription reports used in life insurance underwriting, and would require practice changes for at least five years. It still needs preliminary and final court approval. Nothing is payable yet. Save your records, watch the docket for the notice, and rely only on the official notice and administrator website.

Sources and Legal References

Court and case materials

1. Ninth Circuit, Healy v. Milliman, Inc., No. 24-3327 (Jan. 9, 2026)
2. Justia Dockets, Healy v. Milliman Inc., No. 2:20-cv-01473 (W.D. Wash.)
3. Law360, Milliman Reaches $15.5M Deal in Life Insurance FCRA Suit (Oct. 27, 2026)
4. ABA Banking Journal, Ninth Circuit rules unnamed class members must show Article III standing at summary judgment
5. Top Class Actions, $15.5M Class Action Settlement Proposed Over Inaccurate Life Insurance Reports (Nov. 3, 2026)

Statutes, rules and cases

6. Fair Credit Reporting Act, 15 U.S.C. §§ 1681 et seq. (Office of the Law Revision Counsel)
7. Federal Trade Commission, Fair Credit Reporting Act
8. Fed. R. Civ. P. 23; 28 U.S.C. § 1715
9. TransUnion LLC v. Ramirez, 594 U.S. 413 (2021); Safeco Insurance Co. of America v. Burr, 551 U.S. 47 (2007); Guimond v. Trans Union Credit Information Co., 45 F.3d 1329 (9th Cir. 1995)

AllAboutLawyer.com is an independent legal information website, not a law firm. The allegations against Milliman have not been proven, and the proposed settlement is subject to court approval. This article is for education and is not legal advice.

Researched and written by Israr Ahmad, legal content researcher and founder of AllAboutLawyer.com. All facts verified against the Ninth Circuit opinion in Healy v. Milliman (No. 24-3327), the Western District of Washington docket for No. 2:20-cv-01473 and published reporting on the proposed settlement, as of November 4, 2026. The settlement’s official website has not yet been launched. Last Updated: November 4, 2026.