From Friction to Function: Reforming California’s Long-Term Care Insurance System
Executive Summary
California’s long-term-care (LTC) financing challenge is no longer prospective—it is immediate. Rapid population aging, unusually high care costs, and a Medi-Cal program already under strain are converging to increase demand for long-term services and supports (LTSS). In this environment, a functioning private LTC insurance market—including both standalone policies and hybrid or linked-benefit life/LTC products—is not optional. It is a necessary complement to public financing, helping households manage risk, preserve assets, and reduce long-term pressure on state budgets.
Section I shows that California faces a widening financing gap. LTC needs are common and often prolonged, costs in California exceed national averages, and Medi-Cal operates primarily as a safety net rather than a comprehensive solution for middle-income households. At the same time, the state’s primary public-private bridge—the Partnership for Long-Term Care—is no longer functioning as intended, and overall private coverage has declined.
Section II examines how California administers LTC insurance regulation. The state relies on a fragmented prior-approval system that combines extensive substantive requirements with divided review authority and limited coordination. Compared to national trends toward standardized and centralized review, California’s approach produces greater variability, longer timelines, and less predictable outcomes. Evidence from national data and carrier surveys suggests that these differences reflect institutional design, not simply stronger consumer protection.
Section III analyzes the operational consequences of that system. Review timelines in California routinely extend into years rather than months, filing fees are among the highest in the country, and overlapping review authority—especially for hybrid products—introduces delay and inconsistency. These frictions raise the cost of participation, discourage product entry, and create a sequencing problem in which products can become outdated before they reach the market.
Section IV shows how these delays translate into consumer harm. LTC insurance depends on timing: consumers typically purchase coverage during a midlife window when premiums are lower and underwriting is more permissive. Prolonged review narrows that window, reduces product choice, and limits access to newer product designs that have gained traction nationally. As a result, households are more likely to rely on savings drawdowns or unpaid caregiving. Over time, these dynamics shift costs onto families and increase the likelihood of eventual reliance on Medi-Cal. Regulatory delay is therefore not just an administrative issue—it is a consumer-welfare and fiscal-policy problem.
Using a law & economics framework, the brief shows that California’s outcomes diverge from those in other states with similarly strong consumer-protection regimes. The evidence is more consistent with institutional friction—rather than substantive regulatory stringency alone—as the primary driver of market weakness.
Section v outlines a set of practical reforms to restore market function without weakening consumer protection. These include establishing timeline accountability and escalation protocols, consolidating review authority for hybrid products, rationalizing filing fees, creating a pathway for limited-duration LTC coverage, and evaluating participation in interstate review mechanisms. Taken together, these reforms would reduce avoidable delay, improve regulatory predictability, and expand the range of products available to California consumers.
For a state confronting rapid demographic change and rising care costs, improving the administration of LTC insurance regulation is not a marginal adjustment. It is a necessary step toward a more sustainable long-term-care financing system.
I. California’s Widening Long-Term Care Financing Gap
California is entering a new demographic era—one that will place sustained pressure on how the state finances long-term care. By 2040, the share of Californians age 65 and older will rise from 14% in 2020 to 22%. Over the same period, the old-age dependency ratio will increase from 24 to 38 older adults per 100 working-age adults. This shift will drive demand for long-term services and supports (LTSS), even as the working-age population that finances much of the system grows only modestly.[1]
FIGURE 1: California’s Aging Pressure, 2020–2040
SOURCE: PPIC
*Old-age dependency ratio is the number of adults 65+ per 100 working adults.
LTSS needs are common, not exceptional. Federal estimates indicate that a person turning 65 today has nearly a 70% chance of needing some form of LTSS, and 20% will require care for more than five years. Microsimulation estimates reinforce this point: 48% of older adults will receive paid LTSS over their lifetimes, and 24% will receive paid care for more than two years. Long-term-care risk is therefore not a tail event affecting a small minority of households. It is a predictable feature of aging.[2]
California’s cost structure makes that risk especially acute. AHIP’s 2025 state report, using 2024 data, estimates annual costs of about $86,944 for homemaker services, $89,232 for home health aide services, $88,200 for assisted living, $140,343 for a semi-private nursing-home room, and $182,135 for a private room. Each figure exceeds the national benchmark. Even relatively short care episodes can impose significant financial strain, particularly on middle-income households without substantial liquid assets.[3]
FIGURE 2: California v. United States Annual Care Costs by Setting
SOURCE: AHIP
Public programs cannot absorb this growing burden on their own. In 2025–26, the budget for Medi-Cal—California’s Medicaid program—is estimated at $197 billion, making it the largest program in the state budget on a total-funds basis. LTSS obligations within Medi-Cal are already expanding. From 2017 to 2022, the number of Medi-Cal enrollees using LTSS increased by 20%, and more than six times as many enrollees relied on home- and community-based services (HCBS) as experienced long-term-care stays in 2022. These trends show that LTSS financing is already a central fiscal issue—not a distant concern.[4]
Medi-Cal operates as a safety net, not a comprehensive financing solution for middle-income households. The California Department of Health Care Services (DHCS) applies asset limits to people age 65 or older, people with disabilities, nursing-home residents, and certain other non-MAGI enrollees. The current limit is $130,000 for an individual, plus $65,000 for each additional family member. For nursing-home LTSS, DHCS reviews asset transfers made during the prior 30 months, and transfers made on or after Jan. 1, 2026, may trigger penalties that delay eligibility.[5]
These rules have meaningful real-world effects. A 2025 JAMA Network Open study finds that 16.4% of nursing-home residents who initially lacked Medicaid coverage spent down assets and enrolled between 2018 and 2022.[6]
FIGURE 3: Medi-Cal LTSS Growth and Service Mix, 2017–2022
SOURCE: California Health Care Foundation. LTSS totals include overlap because some enrollees use both long-term care stays and home and community-based services (HCBS).
This framework creates a persistent financing gap. Households with assets to protect—but not enough wealth to self-insure—face the greatest exposure. The American Academy of Actuaries identifies long-term-care insurance purchasers as often falling into this category: individuals who would not qualify for Medicaid without reducing assets but who also cannot absorb extended care costs out of pocket.[7]
California’s Partnership for Long-Term Care reflects this logic. DHCS explains that Partnership policies offer Medi-Cal asset protection, allowing policyholders to shield one dollar of assets for every dollar paid in benefits. In principle, this public-private model allows households to avoid unnecessary impoverishment while reducing future pressure on Medi-Cal.[8]
In practice, the model is not functioning. DHCS’s current Partnership website states that no Partnership-approved insurers are selling policies.[9] This breakdown likely reflects both broader actuarial pressures and a structural mismatch between the Partnership program and evolving product design.
The Partnership framework centers on standalone long-term-care policies with specified benefit structures and consumer protections.[10] Newer asset-based and hybrid products—typically life insurance or annuities with long-term-care riders—do not fit this structure. Hybrid life insurance policies with LTC riders generally do not qualify for the California Partnership program,[11] and state law requires disclosures stating that they are not Partnership policies.[12] As hybrid and linked-benefit products gain traction nationally, California’s flagship public-private program remains tied to a narrower legacy model.
This disconnect both reflects and contributes to a broader contraction in private coverage. AHIP data show that total private LTC coverage in California declined from 750,963 covered lives in 2021 to 735,901 in 2024. Standalone coverage fell from 605,488 to 572,215 over the same period, and growth in extended-benefit and acceleration products did not offset the decline. California has therefore experienced both contraction in traditional LTC insurance and insufficient expansion in alternative products.[13]
This deterioration does not mean private financing is unavailable. Nationally, the standalone LTC insurance market has faced sustained pressure. Milliman reports that policy terminations have exceeded new policy issuances by roughly 127,000 individuals per year over the past decade. The market, however, has evolved. The American Academy of Actuaries reports that hybrid products now play a significant role, and short-term-care products offering up to 12 months of coverage appear to be growing.[14]
FIGURE 4: California Private LTC Coverage by Product Type, 2021 v. 2024
SOURCE: AHIP
For California, the key policy question is not whether national headwinds exist—they do. The question is whether the state allows sufficient flexibility for product redesign and private financing options to reach households exposed to catastrophic care costs.
California is already evaluating broader LTSS financing options. DHCS notes that the state commissioned feasibility and actuarial work for a public LTC option under the Budget Act of 2019, while a California Department of Insurance (CDI) task force advanced a separate feasibility report under Assembly Bill 567.[15] Regardless of the path chosen for public financing, California will still require a functioning private market—particularly for households unlikely to qualify for Medi-Cal until after significant asset depletion.
A durable strategy should treat private financing not as a substitute for public programs, but as a necessary complement.
Taken together, these trends point to a widening financing gap. California faces rapid population aging, high care costs, and a Medi-Cal program that is already fiscally significant. At the same time, the private market that could help households pool risk and protect savings has weakened. Later sections examine whether state-specific regulatory frictions have compounded national market pressures. Absent a more balanced financing strategy, more middle-income households will face delayed planning, asset depletion, and eventual reliance on Medi-Cal.[16]
II. Administrative Frictions in California’s LTC Insurance System
California’s LTC insurance market is best understood by separating substantive consumer-protection rules from the administrative machinery that implements them. The state regulates LTC insurance through parallel prior-approval tracks. The California Department of Insurance (CDI) reviews policy forms and related materials before products reach the market, while the Insurance Code separately requires prior approval of both initial premium schedules and subsequent premium increases. This framework also applies to LTC benefits embedded in life insurance policies or annuity contracts.[17]
FIGURE 5: California LTC Insurance Prior-Approval Structure
CDI guidance highlights the administrative demands of this system. LTC filings typically require detailed review of policy labels, outlines of coverage, benefit triggers, inflation protection, nonforfeiture provisions, replacement notices, required coverages, prohibited terms, and other disclosure and suitability protections. Given that these products are often purchased by older consumers and designed to remain in force for decades, that scrutiny is justified. It carries a tradeoff, though. Outcomes depend not only on legal standards, but also on timely review, clear objections, and predictable resolution. When those elements break down, even well-designed rules can produce inefficient results.[18]
Institutional design amplifies these administrative pressures. Within CDI, review authority is divided by product type. Health-insurance units generally review standalone LTC policies, while hybrid life/LTC products often require review by both life and health divisions. In practice, this structure tends to produce sequential—not parallel—review, repeated requests for clarification, and inconsistent interpretations across bureaus. Each iteration can reset or extend approval timelines, increasing uncertainty for insurers and delaying product availability.
California’s approach is not unique in imposing substantive regulation, but it stands apart in how it administers that regulation. National practice increasingly relies on shared standards to reduce duplication and improve consistency. NAIC Model Regulation 641 establishes common rules on rates, nonforfeiture, suitability, and marketing. The National Association of Insurance Commissioners’ 2022 Long-Term Care Insurance Multistate Rate Review Framework seeks to streamline and harmonize multistate rate review.[19] The Interstate Insurance Product Regulation Compact—now covering 48 jurisdictions, 40 of which have adopted LTC standards—provides centralized review of individual LTC product standards, including core policy terms and modified rate schedules. California does not participate in the compact.[20]
Comparative evidence suggests that regulatory outcomes vary for reasons beyond underlying cost differences or a uniform commitment to consumer protection. The 2021 NAIC LTC data call, based on submissions from 19 insurers across all 50 states, reported a nationwide average cumulative approved rate increase of 112%, alongside substantial cross-state variation. The same analysis found that nursing-home costs did not appear to be a primary driver of state-level LTC experience. Similarly situated policyholders can therefore face materially different outcomes depending on jurisdiction.[21]
Recent carrier surveys reinforce this pattern. The 2025 Milliman survey, covering 17 companies representing more than 75% of LTC premium volume, reports an average approval time of six months from submission to disposition for 2024 filings, down from seven months in the 2021 survey. In both years, carriers identified California as one of the most resource-intensive jurisdictions, alongside Florida, New Jersey, New York, and Texas. The same survey finds that the most common reason for reduced approvals or disapprovals is a political cap or other nonactuarial factors. Administrative practices continue to diverge across states, even within a national market.[22]
California’s institutional structure introduces another source of variability. The insurance commissioner is elected.[23] Jessica Liu and Weiling Liu, analyzing identical insurer requests submitted simultaneously across states, find that approval rates increase by 13% and approved amounts rise by 4% in the period following an election year. As elections approach, commissioners approve fewer requests, approve them less frequently, and grant smaller increases.[24]
Figure 6 illustrates this dynamic through New York Life Insurance Co.’s experience. After seeking roughly 20% premium increases in 2013 for LTC policies sold nationwide, the company received divergent outcomes: a 30% increase in New Hampshire, but outright denials in California, Connecticut, Rhode Island, and Vermont.[25]
FIGURE 6: Average Rate Increase Granted to NY Life Insurance
SOURCE: Liu & Liu
Because California vests rate-review authority in an elected office, these findings are directly relevant—even if they do not isolate a California-specific effect. They underscore how political incentives can shape regulatory outcomes.
CDI itself has acknowledged concerns about administrative capacity and review timelines. In Bulletin 2024-7, Commissioner Ricardo Lara states that the department’s rate-application review process exceeded statutory timelines for multiple reasons and announces reforms to improve speed, transparency, and certainty. The bulletin addresses property-casualty insurance rather than LTC specifically, but it reflects a broader issue: prior-approval systems can become slower and less predictable than intended.[26]
Taken together, the evidence points to institutional friction—not simply “strong regulation”—as the key explanatory factor. California combines extensive substantive requirements, an elected regulator, and nonparticipation in a major interstate review mechanism, all within a national market that increasingly relies on shared standards and coordinated processes. These features do not make current outcomes inevitable. They make them contingent—and therefore open to reform.[27]
III. Delay, Cost, and Product Obsolescence in California’s LTC Market
Section I documented contraction in California’s private long-term-care (LTC) insurance market. This section examines a plausible institutional explanation: the cost and duration of product review. The claim is not that every carrier exit or product non-entry stems from a single regulatory decision. It is that California combines long review periods, high filing fees, and a sequencing problem that can leave products outdated before they reach the market.[28]
In a line of insurance where firms can reallocate capital, product-development staff, and distribution across jurisdictions, these frictions carry real economic consequences.
A. Review Timelines
Public benchmarks suggest that California’s timing problem does not simply reflect the complexity of LTC insurance. New York’s life-insurance SERFF guidance illustrates a different model. Under its “deemer” procedure, the department generally has 90 days to act, with additional 45-day response periods if objections arise. These benchmarks are not perfectly comparable to California LTC form review, but they show that multi-year review is not inherent to the product.[29]
Survey evidence reinforces this point. A 2024 member survey by the Association of California Life and Health Insurance Companies (ACLHIC) finds that average review times for LTC products in California approach or exceed 600 days, making the state a clear outlier.[30] Comparable filings in other states typically receive approval in fewer than 85 days.[31] California’s timelines are roughly seven times longer than the national average and, in some cases, exceed peer-state timelines by more than an order of magnitude.
FIGURE 7: California LTC SERFF Filings by Type, 2020–2025
SOURCE: Authors analysis of California SERFF LTC03I/03G filings.
We examined 368 product filings submitted in California between 2020 and 2025 using NAIC System for Electronic Rate and Form Filing (SERFF) data for LTC03I/03G filings (individual LTC insurance).[32] LTC03I accounts for 93%–95% of filings and provides a representative sample. Of the 368 filings, 255 were marketing-related and another 70 involved minor requests, such as form variations.[33]
The remaining 43 filings were substantive. Average time to disposition was 905 days for rate filings, 951 days for form filings, and 957 days for combined rate/form filings. Fourteen of the 43 filings—nearly one-third—took more than three years to reach final disposition.[34]
The distribution of review times underscores the severity of the delay. Multi-month review is common in complex insurance lines. California routinely subjects LTC filings to timelines measured in years. Some filings remain pending for more than four years.[35] These delays persist even when products are not novel, have already been approved in other states, and rely on familiar actuarial assumptions and policy structures.
FIGURE 8: Avg. Days to Disposition for Substantive California LTC Filings
SOURCES: Authors analysis of California SERFF LTC03I/03G filings; Milliman.
Comparison with other states highlights the gap. Connecticut—identified in the 2024 Society of Actuaries survey as a high-effort jurisdiction[36]—received 69 LTC rate-increase requests between 2020 and 2022. It approved 16 as submitted and 42 at reduced levels, rejecting only six.[37]
These differences are too large to attribute solely to case mix. A process measured in roughly 2.5 years rather than six months reflects a qualitatively different administrative environment. The relevant question is not whether delay is justified in some cases. It is whether California’s system has shifted from scrutiny to bottleneck.
Approval data from 2020 to 2022 illustrate that bottleneck. Between Jan. 1, 2020, and Feb. 21, 2022, CDI reportedly approved only two new LTC policy forms that included application materials.[38] One filing remained under review for 1,741 days—nearly five years—before approval.[39] For most insurers, a timeline of that length is functionally equivalent to a denial, given the opportunity cost of capital and the pace of product development elsewhere.
B. Filing Fees
California also imposes some of the highest filing fees in the United States for LTC products. Depending on the submission, fees for policy forms, riders, and related materials range from roughly $5,000 to $50,000 per filing.[40] Insurers incur these costs regardless of whether a filing receives timely approval, undergoes repeated review cycles, or remains pending.
Under Title 10, Section 2202 of the California Code of Regulations, LTC filings are assessed by document category. Posted fees include $4,960 for a policy, $2,480 for a certificate, $1,110 for a rider or insert page, $1,540 for an application, $1,110 for new-issue rates, and $2,600 for rate changes. Separate charges apply to advertising and certain compliance documents. Life-insurance or annuity products with LTC benefits—such as accelerated death benefits or enhanced annuity features—face similarly substantial document-specific fees.[41]
These charges make even routine submissions expensive before regulators reach the merits. A standalone LTC filing with one policy, one application, and three riders generates $9,830 in posted California fees, excluding any separate rate filing. Texas, by comparison, charges $100 for a filing with one policy, three riders, and an application, and $100 for an LTC rate filing. The comparison is not exhaustive, but the direction is clear: California converts product review into a significantly larger fixed-cost commitment than at least some peer states.[42]
Because these costs are fixed rather than usage-based, they matter most at the margin—where firms decide whether to test a niche product, update an existing form, or allocate development resources to a jurisdiction. Larger insurers may absorb these costs more easily than smaller or specialized firms. Even for large carriers, though, high fees combined with multi-year review periods materially reduce the expected return on filing in California.
C. Pending Filings and Product Obsolescence
Delay also creates dynamic costs. California’s Checklist for Long-Term Care Insurance Policies, revised in May 2025, applies to both standalone LTC policies and LTC benefits embedded in life-insurance or annuity products. When review stretches into years, routine updates to disclosure requirements, form standards, or supporting materials can force insurers to revise pending filings before launch.[43]
The result is product lag. When a review cycle outlasts a product-development cycle, regulators are no longer evaluating the market frontier. They are evaluating an earlier version of it. Approval may arrive only after a carrier has redesigned the product, updated materials, or shifted distribution elsewhere. At that point, approval has limited commercial value. It authorizes a stale filing rather than enabling timely market entry. This dynamic helps explain why prolonged delay can deter participation even without formal denial.
FIGURE 9: How Delay Can Turn Review into Product Lag
The evidence in this section points to a consistent conclusion. California’s LTC regime is not problematic simply because it is protective. It is problematic because, in practice, it is slower and more costly than necessary. These administrative frictions deter entry, discourage product redesign, and reduce sustained participation. This does not prove that regulation alone drives market contraction. It does show that California has made participation materially more burdensome than in faster-moving jurisdictions.[44]
IV. The Consumer Costs of Regulatory Delay
Section III shows that regulatory delay imposes real and compounding costs on California consumers. Those costs extend beyond administrative timelines. They shape household finances and public budgets, as individuals make long-term decisions with fewer—and often inferior—options.[45]
Long-term-care (LTC) insurance is not a commodity purchase that households can defer indefinitely. Timing is part of the product. Consumers typically purchase coverage while they remain insurable, before premiums rise materially, and before product design evolves again. When a state slows product entry and redesign, the result is not simply fewer offerings. Delay narrows options during the key purchase window, limits access to newer products, and increases the likelihood that households will rely on savings drawdowns or unpaid caregiving.[46]
A. Reduced Product Choice
California consumers face a narrower—and increasingly outdated—set of LTC insurance options. Traditional standalone policies are scarce, and hybrid or linked-benefit products remain limited, even as they dominate new sales elsewhere. Some of this reflects national retrenchment: the number of companies writing new LTC business fell from more than 100 in 2000 to fewer than a quarter of that total.[47] California nonetheless stands out. As of 2022, much-smaller Virginia reported 13 companies writing new LTC business,[48] while California had just eight.[49]
Limited choice weakens competition, reduces pressure on premiums, and discourages product differentiation.[50] These effects are especially costly in a heterogeneous market, where consumers differ widely in income, health status, and care preferences.
California has also lagged in the transition to newer product forms. AHIP data show that total private LTC coverage in California fell from 750,963 covered lives in 2021 to 735,901 in 2024. Over the same period, combined extended-benefit and acceleration coverage rose from 145,475 to 163,686—an increase of about 12.5%. Nationally, those categories grew from 799,313 to 1,121,800, an increase of roughly 40.4%. The national market evolved. California adopted those changes more slowly.[51]
Faster review of new forms and new-issue rates would reduce the risk that products reach market with stale pricing assumptions. That concern is particularly acute for hybrid or asset-based LTC products. These products combine life-insurance or annuity value with LTC benefits, often preserve a death benefit if care is never needed, and are frequently sold on a single-premium basis with greater price certainty than traditional coverage.[52] Their appeal depends on locking in value and pricing at issue, rather than returning later for class-wide increases.
FIGURE 10: California Lags Shift Toward New LTC Product Forms
SOURCE: AHIP
Multi-year review delays do more than postpone access. They erode the usefulness of the approved pricing itself. Even for those guaranteed-renewable products that can later seek rate adjustments, a multi-year process risks approving rates that no longer reflect current market conditions.
That lag matters because newer product forms are no longer marginal. The American Academy of Actuaries reports that hybrid products now play a significant role in the LTC market, and the American Association for Long-Term Care Insurance (AALTCI) reports that linked-benefit policies now outsell traditional standalone coverage. For California consumers, delay means not just fewer policies, but reduced access to the forms of coverage gaining traction elsewhere.[53]
Delay is especially costly because the purchase window is concentrated in midlife. AALTCI reports that 55% of traditional LTC buyers are between ages 55 and 65, while only 18% are age 66 or older. Another AALTCI summary finds that more than 76% of new buyers fall between ages 50 and 69 and identifies ages 55 to 65 as the “sweet spot,” when underwriting is easier and premiums are more affordable.[54]
FIGURE 11: The Premium Cost of Waiting to Buy LTC Insurance
SOURCE: AALTCI. Rates shown are the organization’s Illinois benchmark and are not California-specific
Missing that window carries financial and medical consequences. AALTCI’s 2025 price index shows that an illustrative couple purchasing traditional coverage with a $165,000 initial benefit pool for each insured and 3% annual growth would pay about $5,050 at age 55, $5,800 at age 60, and $7,150 at age 65, based on Illinois benchmark rates. Underwriting also tightens with age. About 38.2% of applicants ages 65 to 69 are declined, and 47% of applicants ages 70 to 75 are either declined or deferred. Delay does not simply postpone purchase—it pushes consumers into a market that is more expensive and harder to enter.[55]
B. Product Modernization and Service Innovation
Regulatory delay also limits access to product modernization. The American Academy of Actuaries’ 2025 issue brief reports that hybrid products combining life or annuity benefits with LTC coverage now play a significant role in the market. It also notes growth in short-term-care products offering up to 12 months of coverage and increased insurer investment in data analytics and policyholder engagement for claims and pre-claim management. The NAIC likewise reports efforts to facilitate innovative product offerings.[56]
Modern LTC products increasingly compete on features that matter directly to consumers: financing structure, benefit flexibility, access to home- and community-based care, and claims-support models. NAIC guidance notes that LTC policies may cover home health care, respite care, hospice care, personal care in the home, assisted living, and adult day care. The relevant question is no longer whether policies include noninstitutional benefits. It is whether consumers can access newer combinations of benefits, funding structures, and support features while those products remain current.[57]
When review cycles stretch into years, California risks approving products that no longer reflect current market design. That harms consumers even when approval issues, because the approved form may no longer align with insurer strategy or with more responsive products available elsewhere. Delay thus converts regulatory caution into product obsolescence.
FIGURE 12: How Regulatory Delay Becomes Consumer Harm
These harms extend beyond individual applicants. When households cannot secure timely private coverage, costs shift to spouses, adult children, and other unpaid caregivers. AARP’s 2021 caregiver-cost study finds that family caregivers spend an average of $7,242 annually out of pocket. AARP’s 2026 caregiving valuation report estimates that family caregivers of adults provide 49.5 billion hours of care annually, valued at about $1.01 trillion. Regulatory delay is therefore not merely an administrative issue. It is a household-welfare problem that shifts cost and risk from the insurance market back onto families.[58]
V. Practical Reforms for California’s LTC Insurance Market
The preceding sections point to a clear conclusion: California needs a practical reform agenda. The state’s LTC insurance problem is not excessive consumer protection. It is that administrative friction, fragmented review paths, and high filing costs have become structural barriers to product entry and modernization.
Reform should focus on how review is organized, managed, and measured. If California can reduce avoidable delay without weakening substantive protections, it can expand product availability while preserving the consumer-protection commitments that justify prior approval.
A. Establish Timeline Accountability and Escalation
California lacks a management framework for aging filings. CDI does not need rigid statutory deadlines, which could encourage superficial review. It does need internal benchmarks that distinguish routine processing from abnormal delay.
Graduated targets—such as 90 days for routine filings, 120–180 days for complex or novel products, and mandatory escalation beyond those ranges—would function as management tools rather than legal mandates. A workable system would define standard review windows and require supervisory escalation when filings exceed them.
FIGURE 13: Proposed Timeline Accountability and Escalation Framework
In August 2024, CDI acknowledged the need to improve speed, transparency, and certainty in other insurance lines.[59] The same logic applies here. When filings exceed internal benchmarks, responsibility should shift from individual reviewers to supervisory or cross-functional teams empowered to resolve disputes, consolidate requests, and narrow the scope of review. Without escalation, filings stall due to staff turnover, shifting priorities, or risk aversion.
Escalation matters because it changes how organizations handle delay. A filing pending for hundreds of days should not remain with the original examiner without intervention. It should move to a higher level where managers can consolidate issues, narrow disagreements, and determine whether continued review improves consumer protection or simply prolongs uncertainty.
California should also report aggregate timing data for LTC filings, including average and median days to disposition, counts of pending filings by age bucket, and the share exceeding defined thresholds. Transparency changes incentives. It turns delay into a measurable outcome rather than a default condition.
B. Consolidate Review Authority for Hybrid Products
Hybrid life/LTC and annuity/LTC products present a structural challenge. Because they combine long-duration life or annuity features with LTC benefits, review often fragments across units with different expertise and interpretive approaches. California’s checklist confirms that LTC rules apply to benefits embedded in life insurance or annuities. That breadth is defensible. Diffuse ownership is not.[60]
FIGURE 14: Consolidating Review Authority for Hybrid Life/LTC Products
California should designate a lead bureau for hybrid products, supported by targeted consultation from LTC specialists. The goal is not to reduce expertise, but to eliminate predictable inefficiencies when no single unit owns a filing from intake through disposition. A lead-bureau model would improve accountability, reduce handoffs, and make it easier to identify where and why a filing has stalled.
Consolidating authority within the CDI Life Bureau—consistent with practice in many states—would reduce these inefficiencies while preserving substantive oversight. The Life Bureau already has expertise in long-duration contracts, guaranteed benefits, actuarial pricing, and solvency analysis. Existing LTC protections can remain fully intact within a unified structure.
C. Rationalize Filing Fees
Filing fees are a core barrier to market access. California’s PRAB I fee schedule imposes substantial document-specific charges. A filing with one policy, one application, and three riders generates $9,830 in fees before any rate filing; a standalone rate filing adds another $2,600. Texas, by comparison, charges $100 for a comparable submission and $100 for an LTC rate filing.[61]
These differences matter because filing fees are fixed costs. Insurers must incur them before knowing whether a filing will move quickly, undergo multiple review cycles, or remain pending. California need not eliminate fees. It should align them more closely with actual review effort.
A more rational structure would distinguish among routine amendments, standardized forms, novel products, and actuarially intensive filings. In a system already burdened by delay, lower and more proportional fees would make incremental product improvement materially easier.
D. Consider Adopting the Limited LTC Insurance Model Act
California should consider adopting the NAIC’s 2018 Limited Long-Term Care Insurance Model Act and Model Regulation. The Model Act defines limited LTC insurance as coverage providing less than 12 consecutive months of benefits and aims to promote availability, flexibility, and consumer understanding alongside traditional protections.[62]
The Model Regulation includes disclosure requirements, standards for home- and community-based benefits where offered, inflation protection, application and replacement rules, marketing standards, and suitability requirements. It offers a tailored, consumer-protective framework for shorter-duration products.[63]
The strategic value is straightforward. The current market is thin, comprehensive coverage remains expensive, and many households will not purchase traditional policies even when available. A limited-LTC framework would create a pathway for lower-cost, shorter-duration products that expand awareness and provide an entry point for consumers. It would not solve the financing gap, but it would expand supply and engagement.
E. Evaluate Joining the Interstate Compact
California could further reduce friction by joining the Interstate Insurance Product Regulation Compact (IIPRC). The Compact is an operational system with 48 member jurisdictions and a centralized filing process for life insurance, annuities, disability income, and LTC insurance.[64]
It already includes a developed LTC framework, adopted by 40 compact members, that covers core policy terms, application requirements, benefit features, advertising, and multiple rate-filing approaches. Participation would reduce duplicative state-by-state review while requiring California to operate within standardized product-form rules.[65]
FIGURE 15: IIPRC Average Business Days to Approval (2021-2025)
SOURCE: IIPRC
Historically, the Compact has delivered faster review. It reports average review times of 25 days in 2018, 33 days in 2019, 21 days in 2020, and 27 days in both 2021 and 2022—well below its 60-day rule. Turnaround times increased in 2025 due to higher volume and complexity, but the system remains faster and more standardized than California’s current approach.[66]
Compact participation does not require deregulation or surrender of state authority. California would retain control over rates, market conduct, and enforcement. The Compact governs product-form review, not pricing or substantive consumer-protection policy. It offers administrative efficiency without sacrificing state authority.
From a fiscal perspective, improved access to private LTC insurance supports earlier planning and risk pooling, reducing long-term pressure on Medi-Cal. As demographic aging accelerates, the Compact offers a practical tool to stabilize the market while protecting consumers and public finances.
F. Strengthen Legislative Oversight and Pilot Authority
The Legislature should make these reforms measurable. Reporting requirements for LTC filings would make delay visible and create an external check on administrative drift. Informational hearings focused on filing age, disposition patterns, staffing, and backlog reduction would shift the default from passive tolerance to active oversight.
FIGURE 16: Reform Pathways and Expected Effects
The Legislature should also authorize targeted pilots. California does not need to redesign its approval system all at once. It can test reforms incrementally—expedited review for standardized filings, a lead-bureau model for hybrid products, or a limited-LTC pathway based on the NAIC framework. Well-designed pilots would generate evidence on whether faster review and strong consumer protection can coexist.
Taken together, these reforms operate as a governance package rather than isolated fixes. Timeline accountability improves discipline. Consolidated review improves ownership. Fee reform improves incentives. Limited-LTC legislation and Compact participation expand product pathways. California does not need to weaken consumer protection to restore a functioning LTC insurance market. It needs to administer that protection in a way that is timely, coherent, and compatible with modern product development.
VI. Conclusion
California’s long-term-care challenge is no longer prospective—it is present. The population is aging rapidly, care costs are unusually high, and Medi-Cal already finances a large and growing share of long-term services and supports. In this environment, a functioning private LTC insurance market is not optional. It is a necessary complement to public financing if California aims to reduce household asset depletion and limit future pressure on public budgets.
The preceding sections show that California’s weak private LTC market does not stem solely from national actuarial headwinds. Insurers have adapted elsewhere by redesigning products, expanding hybrid and linked-benefit offerings, and introducing shorter-duration coverage. California has taken a different path. It combines extensive substantive requirements with prolonged review periods, high filing costs, fragmented oversight of hybrid products, and limited administrative accountability. The result is predictable: slower product entry, narrower consumer choice, and delayed access to innovation.
These outcomes impose tangible costs. For consumers, delay compresses the window when coverage is most affordable and underwriting is least restrictive. For families, it shifts risk to unpaid caregiving and self-financing. For the state, it increases the likelihood that households will spend down into Medi-Cal rather than plan through private risk pooling. Regulatory delay is not merely administrative. It directly affects consumer welfare and fiscal outcomes.
California does not need to weaken consumer protection to improve these outcomes. It needs a regulatory system that implements those protections in a timely, disciplined, and transparent way. The reforms outlined in this paper—timeline accountability, clearer ownership of hybrid-product review, more proportional filing fees, a pathway for limited-LTC products, and serious consideration of interstate coordination—will not resolve the LTC financing gap on their own. They will, however, remove avoidable barriers that constrain supply and delay access.
For a state confronting rapid population aging and rising care costs, removing those barriers is not a marginal improvement. It is a necessary condition for a more sustainable long-term-care strategy.
[1] Hans Johnson et al., California’s Aging Population 1 (Pub. Pol’y Inst. of Cal. Jan. 2025), https://ppic.org/wp-content/uploads/policy-brief-californias-aging-population.pdf.
[2] See How Much Care Will You Need?, Admin. for Cmty. Living, U.S. Dep’t of Health & Hum. Servs., https://acl.gov/ltc/basic-needs/how-much-care-will-you-need (last visited Apr. 20, 2026); see also Off. of the Assistant Sec’y for Plan. & Evaluation, U.S. Dep’t of Health & Hum. Servs., What Is the Lifetime Risk of Needing and Receiving Long-Term Services and Supports? 1 (Apr. 3, 2019), https://aspe.hhs.gov/reports/what-lifetime-risk-needing-receiving-long-term-services-supports.
[3] AHIP, Long-Term Care Insurance Coverage: State-to-State 2025 3, 8 (Nov. 2025), https://ahiporg-production.s3.amazonaws.com/documents/202511-AHIP_LTCStateData.pdf.
[4] See Legis. Analyst’s Off., Considering Medi-Cal in the Midst of a Changing Fiscal and Policy Landscape 1 (Oct. 24, 2025), https://lao.ca.gov/Publications/Report/5083; see also Cal. Health Care Found., Long-Term Care in California: 2024 Edition 1, 4 (Dec. 2024), https://www.chcf.org/wp-content/uploads/2024/12/LongTermCareAlmanac2024.pdf.
[5] Asset Limit Frequently Asked Questions, Cal. Dep’t of Health Care Servs., https://www.dhcs.ca.gov/Medi-Cal/Pages/Help/asset-limits-faqs.aspx (last visited Apr. 20, 2026).
[6] Gabriella Aboulafia, Amanda C. Chen & David C. Grabowski, Asset Spend-Down and Medicaid Enrollment in Nursing Homes, 8 JAMA Network Open e2546876 (2025), https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2842303.
[7] Am. Acad. of Actuaries, The State of Long-Term Care Insurance—2025 2 (Feb. 2025), https://www.actuary.org/wp-content/uploads/2025/03/health-brief-2025-stateofltc.pdf.
[8] See The California Partnership for Long-Term Care, Cal. Dep’t of Health Care Servs., https://www.dhcs.ca.gov/services/ltc/Pages/CPLTC.aspx (last visited Apr. 20, 2026); see also Partnership Policies, Cal. Dep’t of Health Care Servs., https://www.dhcs.ca.gov/individuals/rureadyca/Pages/Partnership-Policies.aspx (last visited Apr. 20, 2026); see also Cal. Dep’t of Health Care Servs., Before You Buy 3, 5, https://www.dhcs.ca.gov/individuals/rureadyca/Documents/Before-You-Buy.pdf (last visited Apr. 20, 2026).
[9] Partnership Certified Companies, Cal. Dep’t of Health Care Servs., https://www.dhcs.ca.gov/individuals/rureadyca/Pages/Partnership-Certified-Companies.aspx (last visited Apr. 23, 2026).
[10] See Partnership Policies, Cal. Dep’t of Health Care Servs., https://www.dhcs.ca.gov/individuals/rureadyca/Pages/Partnership-Policies.aspx (last visited Apr. 23, 2026); see also Cal. Code Regs. tit. 22, §§ 58050, 58059 (2026).
[11] Traditional Long-Term Care Insurance vs. Hybrid Policies, ACSIA Partners, https://acsiapartners.com/traditional-long-term-care-insurance-vs-hybrid-policies (last visited Apr. 23, 2026).
[12] See Cal. Dep’t of Ins., Checklist for Long-Term Care Insurance Policies 1 (rev. May 2025), https://www.insurance.ca.gov/0250-insurers/0300-insurers/0100-applications/pab/upload/long-term-care-checklist-updated.pdf; see also Cal. Ins. Code §§ 10295, 10295.11 (2026).
[13] See AHIP, Long-Term Care Insurance Coverage: State-to-State 2023 8 (Nov. 2023), https://ahiporg-production.s3.amazonaws.com/documents/AHIP_LTC_State_Data_Report.pdf; see also AHIP, supra note 3, at 8.
[14] See Sam Smetek, Annie Gunnlaugsson, Christopher Giese & Quentin Clemens, The Long-Term Care Insurance Industry Through 2024: Summary Statistics and Observations from the Experience Reporting Forms, Milliman (Dec. 31, 2025), https://www.milliman.com/en/insight/ltci-2024-statistics-experience-reporting-forms; see also Am. Acad. of Actuaries, supra note 7, at 1.
[15] Cal. Dep’t of Health Care Servs., Long-Term Services and Supports Feasibility Study, https://www.dhcs.ca.gov/provgovpart/Pages/LTSS-Feasibility-Study.aspx (last visited Apr. 20, 2026).
[16] See Johnson et al., supra note 1, at 1–2; see also AHIP, supra note 3, at 8; see also Legis. Analyst’s Off., supra note 4, at 1; see also Smetek et al., supra note 14.
[17] See Cal. Ins. Code §§ 10236.11, 10236.13 (2025); see also Cal. Dep’t of Ins., Policy Regulation & Approval Bureau I, https://www.insurance.ca.gov (last visited Apr. 20, 2026); see also Cal. Dep’t of Ins., Guideline for California Long-Term Care Insurance Policies 1 (June 27, 2017).
[18] See Cal. Dep’t of Ins., supra note 17, at 1–3; see also Cal. Dep’t of Ins., Long Term Care Insurance Outlines of Coverage, https://www.insurance.ca.gov (last visited Apr. 20, 2026).
[19] See Long-Term Care Insurance Model Regulation § 1, Nat’l Ass’n of Ins. Comm’rs Model No. 641 (2017); see also Nat’l Ass’n of Ins. Comm’rs, NAIC Membership Adopts Framework to Address Long-Term Care Insurance Rate Approvals (Apr. 19, 2022).
[20] See Membership, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org (last visited Apr. 20, 2026); see also Interstate Ins. Prod. Regul. Comm’n, Core Standards for Individual Long-Term Care Insurance Policies (effective Oct. 10, 2017); see also Interstate Ins. Prod. Regul. Comm’n, Rate Filing Standards for Individual Long-Term Care Insurance—Modified Rate Schedules (effective Oct. 10, 2017).
[21] Matt Morton & Kirill Grin, NAIC LTC Data Call Workstream #6: Suggested Public Presentation 3–6, 15–18 (June 25, 2021).
[22] See Mike Bergerson, Andrew Duxbury & Courtney Williamson, Long-Term Care Rate Increase Survey 3–5, Milliman (Apr. 2025); see also Mike Hebig & Jeff Johnson, Highlights from a Rate Increase Survey, Soc’y of Actuaries Long-Term Care News (Feb. 2022); see also Cassi Noel & Courtney Williamson, LTC Rate Increase Landscape Update, Soc’y of Actuaries Long-Term Care News (Apr. 2025).
[23] Cal. Ins. Code § 12900 (2025).
[24] Jessica Liu & Weiling Liu, The Effect of Political Frictions on the Pricing and Supply of Insurance, 37 Rev. Fin. Stud. 1149, 1149–50 (2024).
[25] Id.
[26] See Ricardo Lara, Bulletin 2024-7: Revisions to Department Review of Complete Rate Applications 2–3, Cal. Dep’t of Ins. (Aug. 9, 2024); see also Cal. Dep’t of Ins., Commissioner Lara Moves to Implement New Insurance Rate Review Reforms (Aug. 9, 2024).
[27] See Long-Term Care Insurance Multistate Rate Review, Nat’l Ass’n of Ins. Comm’rs, https://content.naic.org (last visited Apr. 20, 2026); see also Interstate Ins. Prod. Regul. Comm’n, Membership, supra note 20; see also Bergerson et al., supra note 22, at 4–5.
[28] See generally Section I, supra; see also Cassi Noel & Courtney Williamson, LTC Rate Increase Landscape Update, Soc’y of Actuaries Long-Term Care News (Apr. 2025), https://www.soa.org/sections/long-term-care/long-term-care-newsletter/2025/ltc-2025-04-noel-williamson.
[29] See Noel & Williamson, supra note 22; see also Mike Hebig, Highlights from a Rate Increase Survey, Soc’y of Actuaries Long-Term Care News (Feb. 2022), https://www.soa.org/sections/long-term-care/long-term-care-newsletter/2022/february/ltc-2022-02-hebig; see also N.Y. Dep’t of Fin. Servs., Life Insurers: General SERFF Guidelines for Form Filings, https://www.dfs.ny.gov/apps_and_licensing/life_insurers/general_serff_guidelines_for_form_filings (last visited Apr. 21, 2026).
[30] Ass’n of Cal. Life & Health Ins. Cos., Long-Term Care Filing Experiences in California (Sept. 23, 2024).
[31] Id.
[32] State of Cal., System for Electronic Rate and Form Filing (SERFF), rate filings submitted between Jan. 1, 2020 and Dec. 31, 2025 for product types LTC03I and LTC03G, https://filingaccess.serff.com (last visited Feb. 3, 2026).
[33] Id.
[34] Id.
[35] Id.
[36] Noel & Williamson, supra note 22.
[37] Alex Reger, Long-Term Care Rate Request Data, 2010–2023, Conn. Off. of Legis. Rsch. (Sept. 27, 2023), https://www.cga.ct.gov/2023/rpt/pdf/2023-R-0226.pdf.
[38] Ass’n of Cal. Life & Health Ins. Cos., supra note 30.
[39] Id.
[40] Id.
[41] 10 Cal. Code Regs. § 2202(a)(5), (b) n.3 (2026).
[42] Life and Health Lines Office Filing Fees, Tex. Dep’t of Ins., https://www.tdi.texas.gov/life/lhfee.html (last visited Apr. 21, 2026).
[43] Cal. Dep’t of Ins., supra note 12.
[44] See Noel & Williamson, supra note 22; see also N.Y. Dep’t of Fin. Servs., supra note 29; see also SERFF, supra note 32; see also 10 Cal. Code Regs. § 2202; see also Tex. Dep’t of Ins., supra note 42; see also Cal. Dep’t of Ins., supra note 12.
[45] See Cass R. Sunstein, The Cost-Benefit Revolution 31–34 (MIT Press 2019); see also Council of Econ. Advisers, The Economic Effects of Federal Deregulation Since January 2017 (June 2019), https://trumpwhitehouse.archives.gov/wp-content/uploads/2019/06/The-Economic-Effects-of-Federal-Deregulation-Interim-Report.pdf.
[46] Ari Houser, Long-Term Services and Supports Are Becoming Even More Unaffordable for Middle-Class Americans, AARP Pub. Pol’y Inst. (Mar. 12, 2026), https://doi.org/10.26419/ppi.00400.001.
[47] Paul E. Forte, Writing Long-Term Care in a Short-Term World, Contingencies (Mar./Apr. 2024), https://actuary.org/article/writing-long-term-care-in-a-short-term-world.
[48] Scott A. White, Report Regarding Long-Term Care Insurance Premium Rate Cap Legislation, Va. State Corp. Comm’n (Nov. 1, 2023), https://rga.lis.virginia.gov/Published/2023/RD596/PDF.
[49] Long-Term Care Insurance Rate History, Cal. Dep’t of Ins., https://www.insurance.ca.gov/01-consumers/105-type/95-guides/05-health/01-ltc/rate-history.cfm (last visited Feb. 3, 2026).
[50] See Kate Bundorf, The Effects of Offering Health Plan Choice Within Employment-Based Purchasing Groups (NBER Working Paper No. w9996, Sept. 2003), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=450897; see also Liran Einav & Jonathan Levin, Managed Competition in Health Insurance, 13 J. Eur. Econ. Ass’n 998, 998–1021 (Dec. 2015).
[51] See AHIP, supra note 13, at 3, 8; see also AHIP, supra note 3, at 3, 8.
[52] Hans Scheil, Long-Term Care Insurance: Traditional vs. Hybrid—What You Need to Know Before It’s Too Late, Cardinal Guide (Apr. 15, 2025), https://cardinalguide.com/posts/long-term-care-insurance-traditional-vs-hybrid-what-you-need-to-know-before-its-too-late.
[53] See Am. Acad. of Actuaries, supra note 7, at 1; see also Am. Ass’n for Long-Term Care Ins., 2022 Linked Benefit Long-Term Care Insurance Price Index Released (Apr. 4, 2022), https://www.aaltci.org/news/long-term-care-insurance-association-news/2022-linked-benefit-long-term-care-insurance-price-index-released.
[54] See Am. Ass’n for Long-Term Care Ins., Buyers Ages for LTC Insurance Reported (Nov. 6, 2020), https://www.aaltci.org/news/long-term-care-insurance-association-news/buyers-ages-for-ltc-insurance-reported; see also Am. Ass’n for Long-Term Care Ins., Most Long-Term Care Insurance Buyers Between 50 and 69 (Dec. 18, 2019), https://www.aaltci.org/news/long-term-care-insurance-news/most-long-term-care-insurance-buyers-between-50-and-69.
[55] See Am. Ass’n for Long-Term Care Ins., 2025 Long-Term Care Insurance Facts, Data, Prices and Statistics—2025 Reports, https://www.aaltci.org/long-term-care-insurance/learning-center/ltcfacts-2025.php (last visited Apr. 21, 2026); see also Am. Ass’n for Long-Term Care Ins., Nearly Half of Oldest Long-Term Care Insurance Applicants Declined (July 15, 2022), https://www.aaltci.org/news/long-term-care-insurance-association-news/applicants-declined.
[56] See Am. Acad. of Actuaries, supra note 7, at 1; see also Nat’l Ass’n of Ins. Comm’rs, Insurance Topics | Long-Term Care Insurance (updated Feb. 24, 2025), https://content.naic.org/insurance-topics/long-term-care-insurance.
[57] Nat’l Ass’n of Ins. Comm’rs, supra note 56.
[58] See Laura Skufca & Gerard “Chuck” Rainville, 2021 Caregiving Out-of-Pocket Costs Study, AARP Pub. Pol’y Inst. (June 29, 2021), https://www.aarp.org/pri/topics/ltss/family-caregiving/family-caregivers-cost-survey; see also Ari Houser, Selena Caldera, Brendan Flinn & Rita Choula, Valuing the Invaluable 2026: Family Caregivers’ Contribution Reaches $1 Trillion, AARP Pub. Pol’y Inst. (Mar. 26, 2026), https://doi.org/10.26419/ppi.00402.001.
[59] Cal. Dep’t of Ins., supra note 26.
[60] Cal. Dep’t of Ins., supra note 12.
[61] See Cal. Dep’t of Ins., Filing Fees for Documents Approved in Filings Submitted to Policy Regulation and Approval Bureau I, https://www.insurance.ca.gov/0250-insurers/0300-insurers/0100-applications/pab/FilingFeesPAB.cfm (last visited Apr. 21, 2026); see also 10 Cal. Code Regs. § 2202 (2026); see also Tex. Dep’t of Ins., supra note 42.
[62] Nat’l Ass’n of Ins. Comm’rs, Limited Long-Term Care Insurance Model Act §§ 1, 4, Model No. 642 (2018), https://content.naic.org/sites/default/files/model-law-642.pdf.
[63] Nat’l Ass’n of Ins. Comm’rs, Limited Long-Term Care Insurance Model Regulation §§ 8, 12–14, 22–23, Model No. 643 (2018), https://content.naic.org/sites/default/files/inline-files/MDL-643.pdf.
[64] See About, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org/about (last visited Apr. 21, 2026); see also Membership, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org/regulator-resources/membership (last visited Apr. 21, 2026); see also FAQ, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org/about/faq (last visited Apr. 21, 2026).
[65] See Core Standards for Individual Long-Term Care Insurance Policies, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org/standards/record-adopted-standards/core-standards-individual-long-term-care-insurance-policies (last visited Apr. 21, 2026); see also Individual Long-Term Care Insurance Application Standards, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org/standards/record-adopted-standards/individual-long-term-care-insurance-application-standards (last visited Apr. 21, 2026); see also Standards for Long-Term Care Insurance Benefit Features, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org/standards/record-adopted-standards/standards-long-term-care-insurance-benefit-features (last visited Apr. 21, 2026); see also Rate Filing Standards for Individual Long-Term Care Insurance—Modified Rate Schedules, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org/standards/record-adopted-standards/rate-filing-standards-individual-long-term-care-insurance (last visited Apr. 21, 2026); see also Rate Filing Standards for Individual Long-Term Care Insurance—Issue Age Rate Schedules, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org/standards/record-adopted-standards/rate-filing-standards-individual-long-term-care-insurance-issue (last visited Apr. 21, 2026); see also Standards for Filing Revisions to In-Force Rate Filing Schedules for Individual Long-Term Care Insurance, Interstate Ins. Prod. Regul. Comm’n, https://www.insurancecompact.org/standards/record-adopted-standards/standards-filing-revisions-force-rate-filing-schedules (last visited Apr. 21, 2026).
[66] See Interstate Ins. Prod. Regul. Comm’n, 2022 Annual Report 16–17, https://www.insurancecompact.org/sites/default/files/2023-03/2022-annual-report.pdf; see also Interstate Ins. Prod. Regul. Comm’n, 2021 Annual Report 14–15, https://www.insurancecompact.org/sites/default/files/2022-11/annual_report_2021.pdf; see also Interstate Ins. Prod. Regul. Comm’n, Turnaround Times (Feb. 20, 2025), https://www.insurancecompact.org/news-events/news/turnaround-times.