--- title: Public Record of 340B MA Underpayment Settlements Continues to Grow description: On December 9, 2025, the Fifth Circuit (Case 24-10934) overturned the Northern District of Texas decision in Baylor All Saints Medical Center v. Becerra, reinstating CMS’s “Exclusion Rule” at 42 CFR §412.106(b)(4)(iii). image: https://public.govdataservices.com/hubfs/Midsection%20of%20businesswoman%20with%20binders%20at%20office.jpeg --- [Skip to content](https://public.govdataservices.com/the-scoop/public-record-of-340b-ma-underpayment-settlements-continues-to-grow#main-content) Close - [Services](https://public.govdataservices.com/services-page) - [Medicare DSH](https://public.govdataservices.com/medicare-dsh) - [SSI Realignment](https://govdataservices-21378692.hs-sites.com/medicare-dsh#SSI) - [340B MA Underpayments](https://public.govdataservices.com/340b-medicare-advantage-underpayments) - [Medicare Bad Debt](https://public.govdataservices.com/medicare-bad-debt) - [Worksheet S-10 Uncompensated Care](https://public.govdataservices.com/s-10) - [Transfer DRG](https://public.govdataservices.com/transfer-drg) - [Medicare ID & Shadow Billing](https://public.govdataservices.com/medicare-id-shadow-billing) - [MBI ID Finder](https://public.govdataservices.com/mbi-id-finder) - [MIDaS Insurance ID](https://public.govdataservices.com/midas-insurance-id) - [Annual Wellness Visit](https://public.govdataservices.com/annual-wellness-visit) - [Eligibility & Other Services](https://public.govdataservices.com/eligibility-and-other) - [Bundle & Save](https://public.govdataservices.com/bundle-and-save) - [Demo](https://public.govdataservices.com/demo-diagnostics-review) - Resources - [Links](https://public.govdataservices.com/links) - [Blog](https://public.govdataservices.com/the-scoop) - [Contact Us](https://public.govdataservices.com/contact-us) SEARCH [Client Login](https://www.govdataservices.com/gdswebsite/DesktopDefault.aspx) [![GDSlogo\_avenir\_2](https://public.govdataservices.com/hs-fs/hubfs/GDSlogo_avenir_2.png?width=1194&height=340&name=GDSlogo_avenir_2.png)](https://public.govdataservices.com/) - [Services](https://public.govdataservices.com/services-page) - [Medicare DSH](https://public.govdataservices.com/medicare-dsh) - [SSI Realignment](https://govdataservices-21378692.hs-sites.com/medicare-dsh#SSI) - [340B MA Underpayments](https://public.govdataservices.com/340b-medicare-advantage-underpayments) - [Medicare Bad Debt](https://public.govdataservices.com/medicare-bad-debt) - [Worksheet S-10 Uncompensated Care](https://public.govdataservices.com/s-10) - [Transfer DRG](https://public.govdataservices.com/transfer-drg) - [Medicare ID & Shadow Billing](https://public.govdataservices.com/medicare-id-shadow-billing) - [MBI ID Finder](https://public.govdataservices.com/mbi-id-finder) - [MIDaS Insurance ID](https://public.govdataservices.com/midas-insurance-id) - [Annual Wellness Visit](https://public.govdataservices.com/annual-wellness-visit) - [Eligibility & Other Services](https://public.govdataservices.com/eligibility-and-other) - [Bundle & Save](https://public.govdataservices.com/bundle-and-save) - [Demo](https://public.govdataservices.com/demo-diagnostics-review) - Resources - [Links](https://public.govdataservices.com/links) - [Blog](https://public.govdataservices.com/the-scoop) - [Contact Us](https://public.govdataservices.com/contact-us) [Client Login](https://www.govdataservices.com/gdswebsite/DesktopDefault.aspx) [Chris Cusimano](https://public.govdataservices.com/the-scoop/author/chris-cusimano) Jul 30, 2026, 11:45:14 AM 2 min read # Public Record of 340B MA Underpayment Settlements Continues to Grow [Previous](https://public.govdataservices.com/the-scoop/medicare-dsh-win-courts-again-vacate-1115-exclusion-rule) [Next](https://public.govdataservices.com/the-scoop/cms-ffy-2027-inpatient-pps-final-rule) The public record of Medicare Advantage 340B underpayment settlements continues to grow, with at least three additional cases now appearing to have reached settlement since our blog just three weeks ago. The latest matters include:   - Norton Hospitals v. Aetna (Case No. 3:24-cv-683) - UF Health Jacksonville (Shands Jacksonville) v. Aetna (Case No. 2024 CA 003472) - University Health Systems of Eastern Carolina v. Humana (Case No. 4:25-cv-122) While each matter has its own factual and procedural history, together they reinforce a growing trend: Medicare Advantage 340B underpayment disputes continue to resolve before trial with notable frequency. The Public Record Likely Represents Only a Fraction of Actual Settlements: Many provider claims begin in arbitration rather than litigation, and arbitration proceedings are generally confidential. Even settlements from lawsuits often result in little more than a dismissal or notice of resolution. The publicly documented matters now span: Multiple Medicare Advantage organizations, including Aetna, Humana and UnitedHealthcare. Health systems across numerous states in both federal and state courts. Public disclosure of settlement terms remains the exception rather than the rule. GDS Continues to See Similar Trends: GDS has prepared hundreds of Medicare Advantage 340B damages analyses supporting arbitration and litigation matters involving alleged underpayments. In our experience, many disputes have been resolved shortly before expert reports, damages submissions, depositions, or other significant litigation milestones. As nationally recognized law firms continue pursuing these claims, the expanding public record increasingly reflects trends long observed outside public view. The growing body of publicly documented settlements does not establish liability or predict outcomes for additional providers. It does, however, demonstrate that these claims continue to be actively pursued and frequently resolved. ![avatar](https://public.govdataservices.com/hs-fs/hubfs/chriscusimano.jpg?width=290&name=chriscusimano.jpg) #### [Chris Cusimano](https://public.govdataservices.com/the-scoop/author/chris-cusimano) ## RELATED ARTICLES ### [Chris Cusimano Dec 15, 2025, 3:29:45 PM 1 min read Circuit Court Overturns District Court's Vacatur of Exclusionary Rule Regarding Certain 1115 Waiver Days On December 9, 2025, the Fifth Circuit (Case 24-10934) overturned the Northern District of Texas decision in Baylor All Saints ... Start Reading](https://public.govdataservices.com/the-scoop/circuit-court-overturns-district-courts-vacatur-of-exclusionary-rule-regarding-certain-1115-waiver-days) ### [Chris Cusimano Jan 11, 2023, 1:30:00 PM 2 min read District Court Rule January 10, 2023, to Allow HHS to Use Its Discretion to Determine How to Remedy the 340B Underpayments from January 1, 2018, through September 27, 2022 Tuesday, January 10, 2023, the District Court for the District of Columbia ruled to allow HHS to use its discretion to ... Start Reading](https://public.govdataservices.com/the-scoop/district-court-rule-january-10-2923-to-allow-hhs-to-use-its-discretion-to-determine-how-to-remedy-the-340b-underpayments-from-january-1-2018-through-se-1681184669749) ### [Chris Cusimano Jul 11, 2024, 3:57:13 PM 2 min read 340B MA Underpayments: Current Settlement Offers & Other Happenings Recently, a Medicare Advantage (MA) plan began issuing settlement offers to hospitals for 340B Underpayments and separately ... Start Reading](https://public.govdataservices.com/the-scoop/340b-ma-underpayments-current-settlement-offers) [![gds-logo-1](https://public.govdataservices.com/hs-fs/hubfs/gds-logo-1.png?width=500&height=150&name=gds-logo-1.png)](https://public.govdataservices.com/) **Get in Touch** Government Data Services 3200 W. Market St., Ste. 102 Akron, OH 44333-3324 Government Data Services 117 Seaboard Lane, F270 Franklin, TN 37067 Toll Free: (800) 370-7397 Email: [info@govdataservices.com](mailto:info@govdataservices.com) ![soc](https://public.govdataservices.com/hs-fs/hubfs/soc.jpg?width=44&name=soc.jpg)[![digicert](https://public.govdataservices.com/hs-fs/hubfs/digicert.png?width=117&name=digicert.png)](https://seal.digicert.com/seals/popup/?tag=VtfrmabA&url=www.govdataservices.com) © 2026 - Government Data Services LLC. All rights reserved - [Site Use Agreement](https://public.govdataservices.com/terms-of-use) - [Confidentiality and Privacy](https://public.govdataservices.com/privacy) ```json { "@context" : "http://schema.org", "@type" : "Organization", "knowsLanguage" : "en", "name" : "", "url" : "https://public.govdataservices.com/the-scoop/public-record-of-340b-ma-underpayment-settlements-continues-to-grow" } ``` ```json { "@context" : "http://schema.org", "@type" : "BlogPosting", "abstract" : "On December 9, 2025, the Fifth Circuit (Case 24-10934) overturned the Northern District of Texas decision in Baylor All Saints Medical Center v. Becerra, reinstating CMS’s “Exclusion Rule” at 42 CFR §412.106(b)(4)(iii).", "author" : { "@type" : "Person", "name" : "Chris Cusimano" }, "dateModified" : "July 30, 2026 3 PM", "datePublished" : "July 30, 2026 3 PM", "headline" : "Public Record of 340B MA Underpayment Settlements Continues to Grow", "image" : "https://21378692.fs1.hubspotusercontent-na1.net/hubfs/21378692/Midsection%20of%20businesswoman%20with%20binders%20at%20office.jpeg", "inLanguage" : "en", "keywords" : "[340B]", "mainEntityOfPage" : { "@type" : "WebPage" }, "name" : "Public Record of 340B MA Underpayment Settlements Continues to Grow", "publisher" : { "@type" : "Organization", "logo" : { "@type" : "ImageObject", "url" : "" }, "name" : "" }, "text" : "The public record of Medicare Advantage 340B underpayment settlements continues to grow, with at least three additional cases now appearing to have reached settlement since our blog just three weeks ago. The latest matters include: Norton Hospitals v. Aetna (Case No. 3:24-cv-683) UF Health Jacksonville (Shands Jacksonville) v. Aetna (Case No. 2024 CA 003472) University Health Systems of Eastern Carolina v. Humana (Case No. 4:25-cv-122) While each matter has its own factual and procedural history, together they reinforce a growing trend: Medicare Advantage 340B underpayment disputes continue to resolve before trial with notable frequency. The Public Record Likely Represents Only a Fraction of Actual Settlements: Many provider claims begin in arbitration rather than litigation, and arbitration proceedings are generally confidential. Even settlements from lawsuits often result in little more than a dismissal or notice of resolution. The publicly documented matters now span: Multiple Medicare Advantage organizations, including Aetna, Humana and UnitedHealthcare. Health systems across numerous states in both federal and state courts. Public disclosure of settlement terms remains the exception rather than the rule. GDS Continues to See Similar Trends: GDS has prepared hundreds of Medicare Advantage 340B damages analyses supporting arbitration and litigation matters involving alleged underpayments. In our experience, many disputes have been resolved shortly before expert reports, damages submissions, depositions, or other significant litigation milestones. As nationally recognized law firms continue pursuing these claims, the expanding public record increasingly reflects trends long observed outside public view. The growing body of publicly documented settlements does not establish liability or predict outcomes for additional providers. It does, however, demonstrate that these claims continue to be actively pursued and frequently resolved.", "url" : "https://public.govdataservices.com/the-scoop/public-record-of-340b-ma-underpayment-settlements-continues-to-grow", "wordCount" : "358" } ``` ```json { "@context" : "https://schema.org", "@type" : "BlogPosting", "author" : { "@type" : "Person", "name" : "Chris Cusimano", "url" : "https://public.govdataservices.com/the-scoop/author/chris-cusimano" }, "dateModified" : "2026-07-30T15:55:38.131Z", "datePublished" : "2026-07-30T15:45:14.000Z", "headline" : "Public Record of 340B MA Underpayment Settlements Continues to Grow", "image" : [ "https://public.govdataservices.com/hubfs/Midsection%20of%20businesswoman%20with%20binders%20at%20office.jpeg" ], "mainEntityOfPage" : { "@id" : "https://public.govdataservices.com/the-scoop/public-record-of-340b-ma-underpayment-settlements-continues-to-grow", "@type" : "WebPage" }, "publisher" : { "@type" : "Organization", "logo" : { "@type" : "ImageObject" } } } ```