1.	With regard to our November 30th Response to Comment 1, you asked us to clarify how we recorded the income tax effects relating to our 1.625% Notes, and also to provide the related authoritative guidance.

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With regard to our November 30th Response to Comment 2, you asked us to clarify our disclosures for the 3Rs. Specifically, you requested that we add verbiage regarding the use of the ultimate premium to determine revenue amounts recorded for the permanent risk adjustment program and the temporary risk corridor program. Additionally, you requested that we disclose how we record and report reinsurance premiums in our consolidated statements of income.

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Permanent risk adjustment program: Under this permanent program, our health plans' risk scores are compared to the overall average risk score for the relevant state and market pool. Generally, our health plans will pay into the pool if their risk scores are below the average risk score, and will receive funds from the pool if their risk scores are above the average risk score. We estimate our ultimate premium based on insurance policy year-to-date experience, We and recognize estimates estimated premiums relating to the risk adjustment program as an adjustment to premium revenue in our consolidated statements of income.

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Transitional reinsurance program: This program is designed to provide reimbursement to insurers for high cost members. Our health plans pay an annual contribution on a per-member basis, and are eligible for recoveries if claims for individual members exceed a specified threshold, up to a maximum amount. This three-year program will end in on December 31, 2016. We recognize the assessments to fund the transitional reinsurance program as a reduction to premium revenue in our consolidated statements of income. We recognize recoveries under the reinsurance program as a reduction to medical care costs in our consolidated statements of income.

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Temporary risk corridor program: This program is intended to limit gains and losses of insurers by comparing allowable costs to a target amount as defined by the U.S. Department of Health and Human Services (HHS). Variances from the target amount exceeding certain thresholds may result in amounts due to or receivable due from HHS. This three-year program will end in on December 31, 2016. Due to uncertainties as to the amount of federal funding available to support the risk corridor program, we have not recognized amounts receivable under this program. All liabilities are recognized as incurred. We estimate our ultimate premium based on insurance policy year-to-date experience, We and recognize estimates estimated premiums relating to the risk corridor program as an adjustment to premium revenue in our consolidated statements of income.

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•	The Company is responsible for the adequacy and accuracy of the disclosure in the filings;

•	Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and

•	The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.