You received a notice because government records show that you are a member of one or more of the 2017 CSR Subclass, 2018 CSR Subclass, and/or 2019 CSR Subclass (collectively, the “Settlement Classes”) preliminarily certified by the United States Court of Federal Claims in the class action lawsuit Common Ground Healthcare Cooperative v. United States, Case No. 17-cv-00877 C.

The purpose of the notice is to inform you that the parties have resolved the Settlement Classes’ claims against Defendant United States of America for a cash payment pursuant to the terms of the Proposed Settlement Agreement (“Settlement”).  If finally approved, the Settlement will resolve each Class Member’s claims against the Government.

The Settlement ensures a total release of the Settlement Classes’ claims in exchange for and upon payment of the full amount of an award by the United States in the amount set forth for each member of the Settlement Classes as listed in Exhibits A and B of the Settlement Agreement, inclusive of interest with each party to bear its own costs, attorney fees, and expenses. Similarly, the United States, to the extent permitted by law, releases, waives, withdraws, and abandons any and all claims against the Settlement Classes based upon, arising out of, or in any way directly related to CSR reimbursements except (a) any liability arising under Title 26, United States Code (Internal Revenue Code); (b) any criminal liability; and (c) any fraud.

If the settlement becomes final, members of the Settlement Classes will release the United States from liability for any claims directly or indirectly related to any nonpayment by the government of CSR reimbursement amounts from 2017 onward, and will not be able to sue the United States any further about those issues.

No. There is no requirement to opt into the Settlement. If you intend to participate in the Settlement and have no objections, there is nothing you need to do at this time.

Yes. Pursuant to Rule 23(e)(4) of the Court of Federal Claims, you have the opportunity to exclude yourself from the Settlement by withdrawing from the Settlement Classes by the Exclusion Deadline, October 14, 2025; which has passed.. If you withdrew from the Settlement Classes, you will retain your right to continue to sue the United States for your CSR-related claims.

The deadline to exclude yourself from the Settlement passed on October 14, 2025.

The deadline to exclude yourself from the Settlement passed on October 14, 2025.

Class Counsel will apply to the Court for its attorneys’ fees. As fees, Class Counsel intends to seek 5% of the amounts awarded to the Settlement Class members. The Court, in its discretion, may award Class Counsel less than a 5% fee.

The deadline to object to the Settlement passed on October 14, 2025.

The deadline to object to the Settlement passed on October 14, 2025.

Excluding yourself from the Settlement tells the Court you no longer want to be a member of the Settlement Classes. If you excluded yourself, you have no basis to object to the Settlement as you will no longer be a class member.

Objecting is telling the Court you do not like something about the Settlement. You could only object if you are a member of the Settlement Classes. If you objected and the Court grants final approval of the Settlement despite your objection, you will still be bound by the Settlement.

The Court will hold a Fairness Hearing, at which it will consider any timely and properly submitted objections made by class members to the Settlement, at November 6, 2025 at 10:30 a.m. EST. There is no requirement that you attend the Fairness Hearing in order to participate in the Settlement, withdraw from the Settlement Classes, or object to the Settlement. The Court will consider all written objections submitted in a timely fashion according to the procedures set forth above.

Class members who properly submit timely objections may be heard in person or through counsel at the Fairness Hearing to the extent allowed by the Court.

The Settlement will not be final unless and until the Court grants final approval of the Settlement at or after the Fairness Hearing and after any appeals are resolved in favor of the settlement.

If and when the Court grants final approval of the Settlement, Class Counsel will submit the resulting executed and approved settlement agreement to the United States for payment. Once the United States makes that payment, Class Counsel will then ask the Court to authorize immediate distribution of 95% of the amounts paid to the Settlement Class members. The remaining 5% of the funds will be subject to Class Counsel’s fee petition and the Court’s subsequent fee award.

If you have additional questions about this Notice, you may visit the website set up by Class Counsel at www.CSRClassAction.com, or you may contact Class Counsel directly:

Adam B. Wolfson
Quinn Emanuel Urquhart & Sullivan, LLP
865 S. Figueroa Street
Los Angeles, California 90017
(213) 443-3000
adamwolfson@quinnemanuel.com

Please do not contact the United States Court of Federal Claims with questions or requests for information.