The Court of Appeals for the D.C. Circuit has ruled in favor of the U.S. Department of Health and Human Services (HHS) in a case involving Alignment Healthcare Inc. The court's decision, made on July 14, 2026, addresses concerns raised by Alignment regarding the accuracy of survey results for its Medicare Advantage plans. This ruling has significant implications for how health insurance companies can challenge survey data used to determine their performance ratings.
Alignment Healthcare, a company that offers Medicare Advantage plans, claimed that inaccuracies in survey results negatively impacted its ratings. The court's ruling means that Alignment must accept the survey results as they were reported by HHS, which could affect its funding and reputation. The case highlights the importance of accurate survey administration in the Medicare system, which influences how beneficiaries choose their health plans.
Alignment Healthcare, the appellant in this case, provides Medicare Advantage plans that are regulated by the Centers for Medicare & Medicaid Services (CMS), part of HHS. The dispute arose when Alignment alleged that surveys sent to Spanish-speaking enrollees were not administered correctly. Specifically, they claimed that some Spanish-speaking customers received surveys in English, contrary to their language preference. This issue was brought to CMS in September 2024, leading to a series of communications between Alignment and the agency.
In its appeal, Alignment argued that CMS's refusal to disregard the survey results constituted an arbitrary and capricious decision. The company maintained that the survey administration error treated it unfairly compared to other Medicare Advantage plans, which may have had their ratings based on properly administered surveys. However, the district court ruled in favor of CMS, prompting Alignment to take the case to the Court of Appeals.
The D.C. Circuit Court upheld the district court's decision, affirming that CMS acted within its authority. The court stated, "Even if CMS protocols made Alignment’s request to distribute Spanish-language questionnaires binding on the vendor, Alignment fails to establish that its request was disregarded." The ruling emphasized that CMS had adequately examined Alignment's concerns and provided explanations for its decisions.
The court's opinion, delivered by Senior Circuit Judge Rogers, noted that the agency's actions were reasonable and consistent with its established protocols. The court found no evidence that CMS acted arbitrarily or capriciously in its handling of the survey data. The ruling concluded that Alignment did not meet the burden of proof required to show that CMS's decision was unjustified.
This ruling has significant implications for Alignment Healthcare and other companies offering Medicare Advantage plans. It reinforces the idea that health insurers must ensure their survey processes comply with CMS protocols to avoid disputes over rating accuracy. The court's decision may also serve as a precedent for future cases involving similar disputes between health insurance providers and regulatory agencies.
Looking ahead, Alignment Healthcare may have limited options for appealing this decision. The court's ruling is final unless new evidence or arguments arise that could warrant a reconsideration. Additionally, there are no related cases pending that could influence this ruling further. The outcome of this case underscores the importance of clear communication and adherence to established protocols in the administration of Medicare Advantage surveys.