---
description: Devoted Health grew Medicare Advantage membership 121 percent while UnitedHealth shed 1 million members and Humana faces a 3.5 billion dollar star rating headwind because purpose-built full-stack integration on the Orinoco platform generates genuine quality outcomes rather than depending on coding arbitrage that CMS is systematically eliminating
type: claim
domain: health
created: 2026-03-06
source: "Devoted Health membership data 2025-2026; CMS 2027 Advance Notice February 2026; UnitedHealth 2026 guidance; Humana star ratings impact analysis; TSB Series F and F-Prime due diligence"
confidence: likely
related:
- medicare-advantage-market-is-an-oligopoly-with-unitedhealthgroup-and-humana-controlling-46-percent-despite-nominal-plan-choice
reweave_edges:
- medicare-advantage-market-is-an-oligopoly-with-unitedhealthgroup-and-humana-controlling-46-percent-despite-nominal-plan-choice|related|2026-03-31
sourced_from:
- inbox/archive/health/2026-03-22-openevidence-sutter-health-epic-integration.md
---

# Devoted is the fastest-growing MA plan at 121 percent growth because purpose-built technology outperforms acquisition-based vertical integration during CMS tightening

Devoted Health's Medicare Advantage membership grew 121 percent, making it the fastest-growing MA plan in the country during a period when the largest incumbents are contracting. UnitedHealth expects to lose 1 million MA members in 2026 from repricing driven by margin pressure. Humana faces an estimated $3.5 billion headwind from star rating declines. The divergence is structural, not cyclical.

**Why Devoted grows while incumbents shrink.** The CMS regulatory environment is systematically eliminating the profit mechanisms that acquisition-based vertical integration depends on. Since [[CMS 2027 chart review exclusion targets vertical integration profit arbitrage by removing upcoded diagnoses from MA risk scoring]], retrospective chart review coding — the primary revenue lever for Optum/UHC and CenterWell/Humana — is being excluded from risk adjustment. Simultaneously, CMS is tightening star ratings methodology toward member experience and clinical outcomes, away from administrative process metrics.

Devoted was built from scratch on the Orinoco platform — a unified AI-native operating system that integrates insurance, care delivery, and member engagement on a single technology stack. Unlike acquisition-based integrators who stitch together legacy systems from purchased companies, Devoted's clinical data flows through Orinoco as part of actual care delivery. Chart review exclusion has minimal impact because Devoted's risk scores reflect genuine clinical encounters, not after-the-fact coding.

**The cost advantage.** Devoted operates with a structural cost advantage estimated at 9 points of medical loss ratio below incumbents whose economics depend on coding arbitrage and intercompany transfer pricing. This advantage widens as CMS tightens because Devoted's economics improve with genuine quality competition while incumbents' economics deteriorate as arbitrage mechanisms are closed.

**Star ratings as competitive moat.** Devoted achieved a 4.19 weighted star rating through genuine member experience — the "Treat Everyone Like Family" prime directive operationalized through technology. In an environment where CMS is shifting star methodology toward outcomes and experience, high organic star ratings become a compounding advantage: quality bonus payments fund further investment in care delivery, which improves outcomes, which sustains ratings.

**The proof of concept for purpose-built integration.** Since [[four competing payer-provider models are converging toward value-based care with vertical integration dominant today but aligned partnership potentially more durable]], Devoted's growth during CMS tightening is the strongest evidence that purpose-built full-stack integration outperforms acquisition-based integration when the regulatory environment penalizes coding arbitrage. The aligned partner model — building technology and care delivery together rather than acquiring existing systems — proves more durable when the environment shifts to genuine quality competition.

Since [[proxy inertia is the most reliable predictor of incumbent failure because current profitability rationally discourages pursuit of viable futures]], UnitedHealth's $9 billion annual technology spend directed at optimizing existing infrastructure (consolidating 18 EMRs, AI scribing within legacy workflows) rather than rebuilding around prevention is textbook proxy inertia. The margin from coding arbitrage rationally prevents pursuit of the purpose-built alternative.


### Additional Evidence (extend)
*Source: 2025-07-24-kff-medicare-advantage-2025-enrollment-update | Added: 2026-03-15*

Market concentration data shows UHG gained 505K members while Humana lost 297K in 2025, suggesting the oligopoly is consolidating further toward the largest player. This creates the competitive environment where purpose-built entrants like Devoted can differentiate through technology rather than scale.


### Additional Evidence (confirm)
*Source: [[2026-02-01-cms-2027-advance-notice-ma-rates]] | Added: 2026-03-16*

Industry analysis explicitly notes that 'purpose-built MA plans (lower coding intensity, genuine care delivery) are better positioned than acquisition-based plans' in response to the 2027 reform package. Insurers warn that flat rates plus chart review exclusion could drive benefit cuts and market exits, suggesting acquisition-based models face existential pressure.

---

Relevant Notes:
- [[CMS 2027 chart review exclusion targets vertical integration profit arbitrage by removing upcoded diagnoses from MA risk scoring]] -- the regulatory catalyst that advantages purpose-built models
- [[four competing payer-provider models are converging toward value-based care with vertical integration dominant today but aligned partnership potentially more durable]] -- the structural landscape in which Devoted competes
- [[proxy inertia is the most reliable predictor of incumbent failure because current profitability rationally discourages pursuit of viable futures]] -- why incumbents cannot pivot to the purpose-built model
- [[healthcares defensible layer is where atoms become bits because physical-to-digital conversion generates the data that powers AI care while building patient trust that software alone cannot create]] -- Devoted's atoms-plus-bits integration at the care delivery level
- [[value-based care transitions stall at the payment boundary because 60 percent of payments touch value metrics but only 14 percent bear full risk]] -- Devoted demonstrates what genuine full-risk VBC looks like
- [[anti-payvidor legislation targets all insurer-provider integration without distinguishing acquisition-based arbitrage from purpose-built care delivery]] -- the regulatory risk that could affect Devoted despite its structural differentiation

Topics:
- health and wellness
