This page is part of our public exclusion list — a transparency tool that shows which companies we screen out and why. It is not investment advice, and it is not an accusation. But it is subject to change as our understanding of the facts evolves.
Humana has a pattern of False Claims Act settlements reflecting systemic issues in its Medicare billing practices. In August 2024, Humana agreed to pay $90 million to the federal government — the largest False Claims Act settlement related to Medicare Part D prescription drug program fraud — to resolve whistleblower allegations that Humana submitted fraudulent bids to CMS for Medicare Part D contracts from 2011 through 2017. The DOJ alleged that Humana kept two sets of books: one set of actuarial projections for bids submitted to the government, and a separate internal set reflecting actual anticipated costs used for all other business dealings including budgeting.
In a separate case, Roche and Humana paid $12.5 million to settle the government's claims of kickback fraud — the first False Claims Act settlement arising from a Medicare Advantage Organization accepting a kickback from a pharmaceutical company. In February 2025, the DOJ filed a complaint against Humana and two other national health insurers alleging unlawful kickbacks and discrimination against disabled Americans in connection with Medicare Advantage marketing practices. The recurring pattern spans fraudulent bidding, pharmaceutical kickbacks, and discriminatory enrollment practices.
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The Naughty List
A digest of changes to our exclusion list — new additions, removals, and the evidence behind them. We review the list continuously as new evidence surfaces.
Companies appear on our exclusion list based on our investment judgment — not because they've done anything illegal. This is a difference of values and opinion, not an accusation of wrongdoing. Exclusion does not constitute a recommendation against investing in any company, and absence from the list does not constitute a recommendation to invest.
This information is provided for educational and transparency purposes only and should not be relied upon as investment advice. Data is drawn from independent watchdogs, NGOs, government registries, and Ethical Capital's ongoing research — see Research Sources for the full list.
Ethical Capital LLC is a state-registered investment adviser in Utah (CRD #316032). Registration does not imply a certain level of skill or training.