RPEC Keeps MP-2021 as 65-Plus Mortality Hits 98.7% of Expected

The Society of Actuaries' Retirement Plans Experience Committee will not replace MP-2021 this year and says a successor built by its traditional method is unlikely before fall 2030. Its 2026 update found mortality at ages 65 and over for July 2025 through June 2026 at 98.7% of the level MP-2021 projects from 2019 rates (SOA Research Institute, October 2026).

Actual deaths at those ages ran above 120% of expected at the height of the pandemic and 100.8% for calendar 2025. February 2026 was the first trailing 12-month reading below 100% since the pandemic began, the committee said.

The finding lands on plan sponsors who added a pandemic load to MP-2021 after 2020. "RPEC does not believe that modified assumptions are inherently better predictors of future U.S. population mortality," the report said, while allowing that actuaries may consider plan-specific adjustments.

Published October 22, the report is the fifth October in a row without a new scale. RPEC issued annual updates to MP-2014 from 2015 through 2021, and MP-2021 reflects experience through 2019, the data year the 2027 IRS tables under Notice 2026-27 still rest on.

Key Takeaways

RPEC will not issue a new scale in 2026 and says one built its traditional way is unlikely before fall 2030.
Mortality at 65 and over ran below the MP-2021 projection for the first time, at 98.7% for July 2025 through June 2026.
Improvement excluding COVID-19 deaths has held near 0.5% a year over 2010 to 2019, 2010 to 2025, and 2010 to 2025 excluding 2020 to 2023.
A pandemic load on MP-2021 now points the wrong way, with the latest year 1.3% below expected against about 1% above in 2024 and 2025.
Social Security's revised population counts alone lifted the calendar 2025 ratio by 0.5 points, so the A/E series moves with exposures as well as deaths.

The A/E path by year and sex

RPEC measures actual deaths from CDC WONDER counts against expected deaths built by projecting 2019 rates forward with MP-2021, using Social Security area population estimates as exposure. Table 3 of the report gives the path for ages 65 and over.

Period	Male	Female	Total
2019 (base)	100.0%	100.0%	100.0%
2020	117.4%	116.1%	116.7%
2021	116.3%	113.1%	114.6%
2022	109.7%	109.6%	109.7%
2023	101.7%	102.8%	102.3%
2024	100.3%	101.9%	101.1%
2025	99.9%	101.6%	100.8%
Jul 2025 to Jun 2026	97.8%	99.5%	98.7%

A/E death rates for ages 65 and over, expected from 2019 rates projected with MP-2021. Source: RPEC 2026 Mortality Improvement Update, Table 3.

Men carried the higher excess from 2020 through 2022 and women have since. The gap in the latest 12 months is 1.7 points, and RPEC said the male ratio has sat nearly 2 points under the female ratio in 2024, 2025 and the period ending June 2026.

COVID-19 is no longer the driver. It was the underlying cause of 0.3% of deaths at 65 and over across the 12 months to June 2026 and 0.1% in June itself, and 2025 COVID-19 deaths came to less than a third of those attributed to influenza and pneumonia. "RPEC no longer believes that COVID-19 should be used as an explicit justification for an adjustment to the MP-2021 scale," the report said.

What a pandemic load does now

Section 5 of the report is written for sponsors who loaded the scale. It sets out the two readings of Table 3. One is a permanent reduction: the latest 12 months sit about 1.3% below expected, and holding that as a lasting adjustment "is equivalent to applying a negative load that would continue into the future," on one volatile year of data.

The other is continued excess of about 1% for 2024 and 2025. RPEC said sponsors taking that view "would need to provide alternative reasoning for why the excess mortality observed during 2025 would be expected to persist," since COVID-19 does not explain it. A load calibrated to the 2024 and 2025 excess now sits more than two points above the most recent year's experience.

RPEC also noted that excess mortality in the pension populations its members see has generally been milder than in the general U.S. population.

Regulatory tables carry a fixed version of the same adjustment. The 2027 funding and lump-sum tables in Notice 2026-27 are built from the improvement rates the regulation incorporates by reference. Mercer describes those rates as MP-2021 with no improvement for 2020 through 2023 and a 0.78% annual cap under the SECURE 2.0 Act. RPEC's footnote puts MP-2021's average improvement at 65 and over at about 0.6% a year, so four zero years compound to roughly 2% heavier mortality than the unmodified scale. Observed mortality now runs 1.3% lighter than that scale.

That gap sits in the funding target, which uses the statutory tables, and not in the PBO, where the sponsor's actuary picks the assumption.

Why the data lag lands on 2030

RPEC builds an MP scale from Medicare death rates, smoothed with third-order Whittaker-Henderson graduation across calendar years, with a two-year step-back to limit edge effects. That structure needs at least five years of post-pandemic experience. Counting from 2024, the fifth year is 2028, and CMS does not release Medicare data for 2028 until 2030.

RPEC said it will test whether an alternative method could work on three or four post-pandemic years. The report footnotes three candidates: assigning zero weight to 2020 through 2023, filling those years with MP-2021 expected values, or keeping them with COVID-19 deaths removed. It will also decide whether post-pandemic experience starts in 2023 or 2024, since the 65-plus ratio was still 102.3% in 2023.

A new scale would also reopen the long-term rate, which a load leaves untouched. MP-2021 assumes a long-term rate of 1.35% to age 62, grading to 1.10% at 80 and 0.40% at 95, fully attained in 2037 (SOA, October 2021). Observed improvement at 65 and over has run about 0.5% a year since 2010. The 2026 Trustees Report assumes 0.73% a year for the age-sex-adjusted death rate under its intermediate case. RPEC said changing the ultimate rates or the transition speed "is best described as the creation of a new scale."

GLP-1 drugs are on the same list. The CMI's Working Paper 212 tells UK actuaries to consider medical advances including GLP-1s in long-term rates; RPEC called it "somewhat premature" to adjust a pension improvement assumption on GLP-1 studies alone.

Other bodies have already taken positions RPEC has not:

The Social Security Administration dropped the explicit COVID-19 load factors of its 2025 report and now fits trends to 2009 through 2019 plus 2024. Its period life expectancy at 65 for 2025 is 18.2 years for men and 20.7 for women, against 18.3 and 20.9 estimated for 2024 a year earlier.
The CMI's model halves excess mortality each year from 2020 under its default H=1 setting; England and Wales mortality in 2025 ran about 2% below 2019.
The Royal Dutch Actuarial Association's AG2026 table makes 25% of 2025 excess mortality permanent and runs the rest off at 5% a year, cutting the provision for an average pension portfolio by 0.9% for men and 1.4% for women (September 2026).

The ratios move with the population counts too

Every A/E figure in the report depends on exposure estimates the SSA revises each year. The 2026 Trustees Report raised the 2019 population aged 65 and over by 0.39% to 54.45 million and trimmed 2025 by 0.07% to 64.62 million. Because 2019 is the base year, the higher 2019 count lowered expected rates in every later year. The calendar 2025 ratio moved from 100.26% on last year's exposures to 100.77% on this year's.

That revision also took the trailing ratio to June 2025 from the 101.3% in last year's report to 101.7%. The latest 98.7% would read 98.1% on the old counts. RPEC's cross-check against Medicare records, finalized only through 2023, runs 0.3 to 0.6 points below the CDC-based ratios in every year since 2020.

The committee noted that uncertainty is greatest in the most recent years and above age 80. The 2027 Trustees Report will revise the counts again, and every ratio in Table 3 with them.