Mutual of Omaha's LTC Rate-Filing Posture: The Active-Carrier Story

Most public discussion of long-term care insurance rate-filing activity centers on the closed-block carriers — Genworth, John Hancock (now Manulife's closed block), Lincoln Benefit Life, and others that exited new sales years ago and now run multi-decade repricing programs on their in-force books. Mutual of Omaha is the carrier that gets less attention because the trajectory is less dramatic. It is also one of the few remaining major carriers still actively writing new individual long-term care insurance policies, and its rate-filing posture is structurally distinct from the closed-block carriers in ways that matter to in-force policyholders.

This piece walks through what's verifiable about Mutual of Omaha's recent rate-action history, how the active-carrier posture differs from closed-block carriers like Genworth's $31.8B-NPV trajectory, and what the difference means for in-force policyholders evaluating their options.

Carrier status — actively writing

Mutual of Omaha is currently writing two long-term care insurance products: MutualCare Custom Solution and MutualCare Secure Solution. New-issue age cap is 79 in most states. The carrier is consistently in the top two LTC writers by market share. Effective June 3, 2024, MoO increased the maximum monthly benefit on the MutualCare line from $10,000 to $15,000.

This matters because the structural reality of an active LTC carrier differs meaningfully from a closed-block carrier:

Structural feature	Active carrier (e.g., Mutual of Omaha)	Closed-block carrier (e.g., Genworth)
New premium revenue	Yes — new sales generate ongoing premium income	None since 2019 (Genworth)
Policy mix	Mixed — older in-force policies + new issues	Aging closed block, no new issues
Repricing pressure on in-force	Spread across new business + in-force	Concentrated entirely on in-force
Market signaling	Continued investment in product (e.g., 2024 benefit-cap increase)	Run-off management posture
Recent rate-action magnitude	Moderate (single-digit to mid-twenties percent)	Aggressive (Genworth 2023 weighted avg 51%)

Recent rate-action history — Maryland filing data

Maryland Insurance Administration filings provide a publicly accessible window into Mutual of Omaha's recent rate-action history. Per these filings:

Year	Range of approved increases	Approved average
2023	0% to 38%	26.4%
2024	0% to 38%	23.3%
2025	0% to 13.7%	5.8%

The 2025 average of 5.8% is well below the 2023 and 2024 averages, suggesting either a reduction in filing intensity, a tighter regulatory posture, or a mix of factors specific to the most recent filing cycle. Maryland is one state — the picture across all states will vary — but Maryland publishes more transparent filing data than many states, making it a useful reference window.

For comparison, Genworth's 2023 weighted average approved increase was 51%, with single-state actions like Connecticut's 2022 ~97% average. The active-carrier averages are materially smaller than the closed-block carrier averages — reflecting the structural difference in repricing pressure described above.

Policy form-specific filings

Industry coverage and carrier filings reference specific Mutual of Omaha policy forms with rate-action histories. The LTC13 series in particular has appeared in carrier communications about pre-rate-refresh increases. As with any carrier's in-force book, rate increases on Mutual of Omaha policies are filed by policy form rather than across the entire book at once; the specific increase that applies to any given policyholder depends on which series the policy is issued under, the state of issue, and the cumulative-increase history on that form to date.

The California Department of Insurance publishes a Mutual of Omaha LTC rate-history document that catalogs filed and approved actions by series and effective date — the kind of carrier-specific transparency that's useful for an in-force policyholder evaluating their own policy.

What the active-carrier trajectory means for in-force policyholders

The macro takeaways for someone holding a Mutual of Omaha LTC policy:

1. Rate increases are part of the in-force experience but at smaller magnitudes than the closed-block carriers. The 2025 Maryland average of 5.8% is in a different magnitude band than Genworth's 2023 weighted average of 51%. The headline difference is real and structural.
2. The carrier's continued investment in new product (2024 benefit-cap increase to $15K) is a meaningful market signal. Active carriers spending on product development are signaling longer-horizon commitment to the LTC market than carriers running off closed blocks.
3. The rate-hike letter mechanics still apply. When increases come, the alternatives schedule and §28 contingent nonforfeiture eligibility framework operate the same as for any other carrier. The mechanism of contingent nonforfeiture (NAIC §28) applies on Mutual of Omaha post-2000 policies just as it does on Genworth or Northwestern Mutual policies. The five-options menu on a rate-hike letter is the same shape regardless of carrier — see The LTC Rate-Hike Letter: Five Options Inside the Decision Window.
4. Smaller average increases do not mean no increases. A 5.8% increase compounding over a decade is still a meaningful cumulative repricing. Active-carrier policyholders should expect ongoing increases at moderate-magnitude levels, not zero increases.
5. State variance applies the same as for closed-block carriers. Maryland's 5.8% average for 2025 is one state. California's history shows different specific actions; New York's DFS framework shapes filings differently; states with consumer-friendly methodology reform (per the New York 2023 reform) may produce smaller approved increases over time.

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What this is not

This is not a buyer's review of Mutual of Omaha's products. The MutualCare Custom and MutualCare Secure products have their own coverage, pricing, underwriting, and benefit structures that are evaluated by buyers shopping for new policies. This piece is editorial coverage of the rate-filing posture — relevant for in-force policyholders evaluating their existing Mutual of Omaha policies and for buyers thinking about the carrier-trajectory dimension of a purchase decision (one of the eight mechanisms missing from cost comparisons).

This is also not a carrier-versus-carrier ranking. The structural difference between active and closed-block carriers is descriptive, not prescriptive. Some closed-block carriers have stronger financial positions than some active carriers; some active carriers have product structures that fit specific buyers better than active competitors. The trajectory data is one input among many.

Coverage scope

This is the second carrier-trajectory release in the Long Term Care Desk's Rate Tracker series, following the Genworth carrier hub. Northwestern Mutual, New York Life, and Brighthouse coverage will follow on the same quarterly cadence. Per-state SERFF filing detail across the eight target states is planned alongside.