TL;DR: No, they are not.

In Livestock Gross Margin for Cattle Basic Provisions, we find several definitions relevant to this question:

Target marketings – Your determination as to the number of cattle you elect to insure in each month during the insurance period. You can only report the number of cattle in which you have a share.

Tracing further, how is “cattle” defined?

Cattle – Any species of domesticated mammal of the family Bos Taurus or Bos Indicus commonly grown for beef production. Also referred to as steer or heifer or cow.

The definition of cattle would seem to allow the inclusion of cows. Coverage under LGM-Cattle is available for Yearling Finishing Operations and Calf Finishing Operations, defined as:

Calf finishing operation – A type of farm operation that purchases calves and feeds them until slaughter.

Yearling finishing operation – A type of farm operation that purchases yearling steers and heifers and feeds them until slaughter.

Neither type contemplates cows. Further, the margin formula for both type explicitly includes “Target feeder Cattle weight” – a concept that would not be meaningful for cows.

In conclusion, open or cull cows are not insurable under LGM-Cattle policy as it stands today. Dairy cull cows become insurable under LRP with RY2026, but only under 13 weeks-long endorsements. Our current 508(h) modification submissions contemplate expanding coverage for up to 52 weeks for dairy cull cows, and allowing beef cull cows to be covered under 13 to 26 weeks long endorsements. If approved, these changes will most likely be implemented for RY2027 (though the Oct/Nov 2025 shutdown has really put that timeline in jeopardy).