UnitedHealth got the headline it wanted this month: an outside audit of its HouseCalls program found that the overwhelming majority of diagnoses generated during in-home visits to Medicare Advantage members were backed up by patients’ actual medical records. The company is framing that as vindication. Read past the topline number, though, and the report answers a narrower question than the one critics have actually been asking for years.
What was tested, and what came back
FTI Consulting, hired by UnitedHealth as part of a broader independent review the company pledged after a rough stretch of scrutiny, examined a random sample of 200 HouseCalls visits covering 494 diagnoses. It applied the same review methodology CMS itself uses. The result: 96.6% of diagnoses were supported by the medical record, leaving 17 diagnoses, or 3.4%, initially unsupported. UnitedHealth pushed back on even that residual figure, saying most of the 17 were actually backed by other documentation such as paid claims; FTI agreed that 12 of the 17 fell into that category after further review.
UnitedHealth’s framing is that a 3.4% error rate compares favorably with the error rate CMS itself found in its most recent audit of MA risk-adjustment data — by the company’s account, about a third as high. If that comparison holds, HouseCalls is not an outlier problem child within the broader MA billing ecosystem; it’s performing better than the industry baseline the government itself measures against.
That is a genuinely useful data point. It is also not the accusation HouseCalls has faced.
The gap between “supported by the record” and “medically necessary”
The core criticism of HouseCalls — and of similar in-home risk-assessment programs run by competitors — was never primarily that clinicians write down diagnoses nobody can find any paperwork for. It’s that the in-home visit structure creates conditions where diagnoses get documented and coded in ways that maximize Medicare’s risk-adjusted payment to the insurer, regardless of whether that diagnosis reflects an active, clinically meaningful health problem or changes how the patient is actually treated.
A 2024 investigation by the HHS Office of Inspector General took direct aim at that dynamic. It found that major MA insurers, UnitedHealth included, generated billions of dollars in payments tied to diagnoses surfaced specifically through health risk assessments — visits, in many cases, where no other clinician ever documented or acted on the condition afterward. The OIG traced $7.5 billion in MA payments in a single year to diagnoses sourced from in-home assessments, with $3.7 billion of that — roughly half — flowing to UnitedHealth alone.
That’s the allegation the FTI audit doesn’t really test. Confirming that a diagnosis exists somewhere in the medical record is a lower evidentiary bar than confirming that a diagnosis was clinically warranted, actively managed, or would have been identified in the normal course of care rather than manufactured by the structure of a one-time in-home visit built around Medicare’s payment incentives. A diagnosis can be fully “supported” on paper and still be an example of exactly the risk-adjustment gaming that regulators and researchers have flagged.
It’s also worth noting what the audit didn’t disclose. UnitedHealth did not say how much Medicare reimbursement was tied to the 17 initially unsupported diagnoses, nor what the 3.4% error rate would translate to in dollar terms if extrapolated across the company’s full MA book — a company that, by its own numbers, receives billions of dollars a year specifically from home-visit-sourced diagnoses. Without that figure, “3.4%” is a rate without a denominator that matters to anyone outside the company.
Reading this against UnitedHealth’s broader reset
The HouseCalls report doesn’t stand alone. It’s the latest installment in a self-review process CEO Stephen Hemsley commissioned after returning to the top job last year, following the company’s first quarterly earnings miss in roughly two decades and amid both civil and criminal Department of Justice scrutiny of its Medicare billing practices. The first tranche of that review, released in December, identified areas for improvement but did not find evidence supporting the more serious allegation that UnitedHealth is systematically exploiting its scale to inflate Medicare profits. The company says it has since implemented all 23 recommendations from that initial round, including standing up an independent coding-audit function and formalizing oversight of risk assessments.
Viewed that way, the HouseCalls numbers fit a consistent pattern in how UnitedHealth has managed this scrutiny: commission a review, get a result that clears the most serious version of the accusation, publicize the topline number, and use it to argue the broader narrative around the company is overblown — while declining to release the dollar-level detail that would let outsiders judge how much money is actually riding on the unresolved edge cases.
That’s a reasonable corporate strategy. It’s also not the same thing as an independent audit settling the underlying policy question. MedPAC, the OIG, and multiple academic researchers have argued for years that health risk assessments across the entire MA industry — not just at UnitedHealth — function partly as a revenue tool, generating diagnoses that inflate risk scores without demonstrably improving the care a beneficiary receives. A 96.6% documentation-support rate doesn’t resolve that argument one way or the other; it just confirms that when UnitedHealth’s clinicians write something down, they usually have a record backing it up. Whether that record reflects genuine clinical need, rather than a coding opportunity created by the payment structure itself, remains exactly the open question it was before the audit.
What would actually move this forward
For outside observers trying to judge whether HouseCalls is a legitimate care-delivery tool or primarily a risk-adjustment mechanism, a few pieces of information would matter more than the documentation-support rate UnitedHealth has now published:
- Dollar exposure. How much of UnitedHealth’s MA risk-adjustment revenue is tied to diagnoses that originate exclusively from a HouseCalls visit and are never referenced again in subsequent care — the pattern the 2024 OIG report flagged as the biggest risk area.
- Downstream clinical follow-through. What share of diagnoses surfaced in a home visit result in a referral, a prescription, a care plan, or any subsequent clinical action, versus sitting in the record purely as a coding entry.
- Comparability across the industry. Whether competitors running similar in-home assessment programs would produce comparable documentation-support rates under the same FTI methodology — without that baseline, UnitedHealth’s number can’t really be judged as good, average, or exceptional.
- Regulatory response. Whether CMS or the OIG treats this audit as responsive to their own findings, or continues to press forward with the broader crackdown on MA risk-adjustment practices that’s been building across multiple administrations.
Until those questions have answers, the FTI report is best read as a well-executed defense of a narrow claim — that HouseCalls diagnoses generally have paperwork behind them — rather than as evidence settling whether the program does what its critics say it does.
Sources:
- Healthcare Dive, “External audit of UnitedHealth senior home visits finds most diagnoses supported by medical data,” July 7, 2026
- UnitedHealth Group, FTI Consulting HouseCalls assessment summary and CEO letter, July 2026
- HHS Office of Inspector General, “Medicare Advantage: Some Companies Leveraged Chart Reviews and Health Risk Assessments to Add Billions in Risk-Adjusted Payments,” Report No. OEI-03-23-00380, 2024
- Healthcare Dive, “UnitedHealth commits to changes after independent review,” Dec. 22, 2025
- Healthcare Dive, coverage of UnitedHealth Department of Justice investigation into Medicare billing
- Healthcare Dive, coverage of UnitedHealthcare and Humana Medicare Advantage risk-adjustment practices, citing Alliance of Community Health Plans commentary
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