POLICYHOLDER INTELLIGENCE

Long-Term Care Insurance Companies with the Most Complaints — NAIC Records and AM Best Ratings

Published · By The Editorial Team
Abstract editorial data visualization: five vertical bars at varying heights on a navy background, one bar in muted gold standing dramatically taller, representing complaint ratio disparity among LTC insurance carriers

One number cuts through the marketing materials faster than anything else a policyholder can pull: Transamerica Life Insurance Company's NAIC complaint index sat at 3.86 in the most recent available data — meaning it generated complaints at nearly four times the industry average relative to its premium volume. The industry average is 1.0. A competitor like MassMutual posted an index of 0.11 in the same period.

A second number matters just as much for anyone considering a new policy: Genworth Life Insurance Company holds a C++ (Marginal) financial strength rating from AM Best, affirmed as recently as September 2025. Every other major LTC carrier in this analysis rates A or above. Genworth's in-force policyholders are already locked into that risk profile; buyers can still choose a carrier with a stronger balance sheet.

Neither number is an opinion. Both are public regulatory data. For long-term care insurance, where the policy may sit in a drawer for twenty years before a claim is needed, tracking these metrics is part of managing an expensive, high-stakes contract.

This site is not a licensed insurance agent or financial advisor. The data below identifies complaint records and financial ratings from public sources. It is not a recommendation to purchase, lapse, reduce, or replace any insurance policy. Decisions about existing long-term care policies involve complex tax, Medicaid, and health-underwriting factors — consult a licensed professional before taking any action on an in-force policy.

The two questions buyers and policyholders ask differently

The "worst" LTC carrier for a buyer and the "worst" for an existing policyholder are often different entities, because they're asking different questions.

Buyers ask: Will this company be solvent and paying claims in twenty years when I need it? The relevant signal is AM Best financial strength — the carrier's capacity to meet long-term obligations. A buyer who chooses a financially marginal carrier today locks in that risk for decades.

Existing policyholders ask: How has this carrier treated its in-force block? The relevant signals are NAIC complaint records (a proxy for claims-administration friction) and the rate-hike history that state DOI filings document in granular detail. A policyholder cannot un-buy their policy based on these signals — but they can use them to calibrate expectations, prepare for the next rate-increase letter, and understand what their five options are when it arrives.

AM Best financial strength — for buyers

AM Best's financial strength rating is the standard measure of an insurer's ability to meet ongoing policyholder obligations. The full scale runs from A++ (Superior) through D (Poor) and includes an E (Under Regulatory Supervision) category. For a policy with a 20-to-30-year claim horizon, rating trajectory matters as much as current standing.

Carrier AM Best Rating Outlook / Notes As of
MassMutual A++ (Superior) Stable Oct 2025
New York Life A++ (Superior) Stable Jul 2026
Mutual of Omaha A+ (Superior) Stable Apr 2026
John Hancock A+ (Superior) Stable Dec 2025
Transamerica A (Excellent) Stable Sep 2026
Brighthouse A (Excellent) Under review — negative implications Jul 2026
Genworth Life C++ (Marginal) Significant gap vs. peers Sep 2025

Genworth's C++ rating reflects the isolated financial position of its life insurance subsidiary, which carries the legacy LTC block. It does not mean claims will go unpaid — state guaranty associations provide a backstop of up to $300,000 per policyholder in most states — but it signals meaningfully weaker claims-paying capacity than any competitor. The question of what the C++ rating means for existing policyholders is addressed in more depth in our analysis of Genworth's financial position.

Brighthouse's "under review — negative implications" flag reflects the pending acquisition by Aquarian Capital announced in July 2026, which this site covered in detail at the time. The review does not indicate immediate financial deterioration; it signals that AM Best is evaluating what the new ownership structure means for the combined entity's capitalization.

NAIC complaint index — for policyholders

The NAIC complaint index is calculated as a carrier's share of consumer complaints divided by its share of total premiums written — normalized to the industry, where 1.0 equals average. A score above 1.0 means the carrier attracted more complaints per premium dollar than a typical company of its size.

One critical limitation applies specifically to LTC insurance: carriers that closed their blocks to new enrollees years ago have a shrinking premium base (fewer new policies, existing policies lapsing) while their policyholder population ages into the claim phase and generates more complaints. This structural effect can inflate the index of closed-block carriers independent of any change in claims-handling quality. Interpret these figures with that context, and treat them as signals of relative friction — not definitive rulings on carrier conduct.

Carrier NAIC Complaint Index vs. Industry Avg (1.0) Period
Transamerica 3.86 3.86× average Aug 2026
Mutual of Omaha 0.51 Below average Sep 2026
John Hancock 0.33 Below average 2024/2025
New York Life 0.20 Below average Apr 2023
MassMutual 0.11 Well below average Aug 2026
Genworth Not available
Brighthouse Not available

Transamerica's 3.86 is the outlier across all verified carriers. Much of its complaint volume traces to claims-administration friction: Transamerica transferred processing of its in-force LTC block to LTCG (now operating as Illumifin) in 2019, introducing a third-party administrator layer between policyholders and the entity that holds the financial obligation. Policyholders who receive a claim denial or face delays often direct complaints to state insurance departments under Transamerica's name, even when the operational friction originates with the TPA. If you hold a Transamerica LTC policy, documenting claims communications carefully and escalating disputes to your state DOI are disproportionately valuable given this track record. Our Transamerica rate history analysis provides additional context on the block's trajectory.

Documented rate-hike records — per-form, per-state

Rate increase histories are not averages across a carrier — they are filed, reviewed, and approved on a state-by-state, policy-form-by-policy-form basis. Citing "Carrier X raised rates by Z% on average" collapses real variation that can only be accurately described at the form level. The figures below come from specific state DOI SERFF filings, each citing a particular policy form in a particular state. Your policy's history depends on your form number and state, not these specific examples — but the filings illustrate the magnitude of increases that major carriers have obtained.

Genworth Life — Pennsylvania, Form 7035 (Choice Series)
A December 2020 Pennsylvania DOI approval (SERFF: GEFA-132644872) documented a 222% cumulative increase for lifetime-benefit provisions and a 157% cumulative increase for limited-benefit variants, applied to policies issued on or after September 16, 2002. These are the cumulative percentages over the full life of the form from issuance — not annual rate changes. This is among the most extensively documented cumulative increase histories in any public state filing. For a broader view of Genworth's multi-state rate action history, see our Genworth rate filing analysis.

Transamerica Life — Maryland, FTQ policy forms
The Maryland Insurance Administration approved a 32.25% increase for Transamerica's FTQ (tax-qualified) policy series in September 2024 (SERFF: AEGB-133941051), phased as two 15% annual adjustments for policyholders under issue age 75. This follows prior phased increases on the same form series. See our Transamerica LTC rate history for the broader state filing record.

MassMutual — Pennsylvania, 200-500 series
A 2021 Pennsylvania filing (SERFF: MILL-132937942) referenced an average 47.3% cumulative prior increase on the 200-500 policy series, with individual policy increases ranging from 0.0% to 52.1% depending on attained age and form variant. See our Mutual of Omaha rate history for comparison benchmarks on a carrier with a different rate trajectory.

John Hancock has implemented significant rate increases on legacy forms — see our dedicated John Hancock LTC rate history — but no single public SERFF filing with a verified cumulative total was located for inclusion in this table. Absence from this list reflects a data-availability gap, not an absence of increases.

What to do with this information

Three practical applications emerge from the data above, all of them short of the drastic step of lapsing a policy:

If you are a buyer: AM Best financial strength is the most durable signal available. The gap between Genworth's C++ and any other carrier in this analysis is wide enough to be a meaningful selection factor. New York Life and MassMutual at A++ offer the strongest financial floor available in the current market, though their policy availability varies by state and is limited compared to hybrid-product offerings from carriers like Mutual of Omaha.

If you hold a Transamerica policy: A 3.86 complaint index does not mean your claim will be denied. It means administrative friction is above average and disputes are more common relative to the carrier's size. Keep documentation of every interaction with Illumifin (the TPA), request everything in writing, and know your state DOI's complaint process before you need it.

If you hold a Genworth policy: The C++ rating reflects the financial position of the entity backing your claim. The relevant state guaranty association is your secondary backstop — determine your state's coverage limit now, not at claim time. The guaranty association typically provides continuous coverage up to the state cap if a licensed insurer fails. If you are weighing a benefit reduction or policy change, the decision to drop or modify involves factors beyond the financial rating alone.

Model your options with the LTC Calculator

Frequently asked questions

What does the NAIC complaint index measure for insurance companies?

The NAIC complaint index compares a company's share of total complaints to its share of total premiums written. An index of 1.0 equals the industry average; an index above 1.0 means the company generated more complaints per premium dollar than average. Because LTC carriers that stopped selling new policies have shrinking premium bases, their indices can rise over time even without any change in absolute complaint volume — a structural limitation to keep in mind when comparing carriers across open and closed blocks. Current data is available through the NAIC Consumer Insurance Search.

Is Genworth still paying long-term care insurance claims?

Yes. A C++ (Marginal) AM Best rating, affirmed September 2025, signals that Genworth's claims-paying capacity is weaker than its competitors — not that claims are being denied. State guaranty associations provide a secondary backstop typically covering up to $300,000 in LTC benefits per policyholder if a licensed insurer becomes insolvent. Genworth has continued to pay claims throughout the period that the C++ rating has been in place. More context in our analysis of Genworth's financial position.

Which long-term care insurance carrier has the best financial strength rating?

MassMutual and New York Life both hold A++ (Superior) from AM Best. Mutual of Omaha and John Hancock hold A+ (Superior). Transamerica holds A (Excellent). Brighthouse holds A (Excellent) but is under review with negative implications as of July 2026. Genworth Life Insurance holds C++ (Marginal) — the weakest of any major in-force LTC carrier.

What happens to my LTC policy if my carrier becomes insolvent?

State guaranty associations step in to cover benefits up to state-defined limits — most states protect LTC policy benefits up to $300,000 per policyholder, though limits vary. The guaranty association in your state of residence at the time of insolvency applies. Coverage continues under the guaranty fund while regulators arrange a transfer to a solvent carrier or wind down the block. The NAIC Life and Health Guaranty Association Model Act governs these protections at the state level.

Sources

  1. NAIC Consumer Insurance Search — Complaint Index by Company. eapps.naic.org/cis/
  2. AM Best Financial Strength Rating — Genworth Life Insurance Company (C++, Marginal), affirmed September 2025. ambest.com
  3. AM Best Financial Strength Ratings — Transamerica (A), Mutual of Omaha (A+), John Hancock (A+), MassMutual (A++), New York Life (A++), Brighthouse (A, under review negative implications July 2026). ambest.com
  4. Pennsylvania Department of Insurance SERFF Filing GEFA-132644872 — Genworth Life Insurance Company, Form 7035 Choice Series, 222% cumulative increase (lifetime benefits), approved December 2020. insurance.pa.gov
  5. Maryland Insurance Administration — Transamerica Life Insurance Company, FTQ policy forms, SERFF AEGB-133941051, 32.25% increase approved September 2024. insurance.maryland.gov
  6. Pennsylvania Department of Insurance SERFF Filing MILL-132937942 — Massachusetts Mutual Life Insurance Company, 200-500 series, 47.3% average cumulative increase, referenced November 2021 filing. insurance.pa.gov
  7. NAIC Life and Health Guaranty Association Model Act (#520). content.naic.org