Finance11 min read

    Medicare Leads: What They Cost in AEP 2026 and the CMS Rules That Decide Which Pay Off

    Mor Romano, CTO of Growbi
    Insurance agent reviewing Medicare plan options with a senior couple at a kitchen table

    Key Takeaways

    • AEP runs October 15 to December 7, and Medicare Advantage searches in October were four times the June level.
    • CMS caps 2027 first-year Medicare Advantage commission at $725 nationally, so a lead is worth your enrollment rate times $725.
    • Since October 1, 2026, an appointment can follow a recorded Scope of Appointment right away; the 48-hour wait is gone.
    • Unsolicited calls, texts, voicemails and social media messages to beneficiaries are still banned, so every usable lead needs documented consent.

    Medicare leads are contact records of people with Medicare, or about to get it, who asked to hear about plans. In 2026, published prices run from $5 aged records to $70 exclusive web leads and $125 live transfers. Judge each against CMS's 2027 cap of $725 per new Medicare Advantage enrollment.

    Table of Contents

    During AEP every Medicare lead vendor in your inbox says its leads close, and most of them price as if every single lead will enroll.

    This guide prices each lead type against what CMS lets a carrier pay you per enrollment, then covers the rules that changed on October 1, 2026.

    AEP 2026 sets the price of every Medicare lead

    The Annual Enrollment Period runs October 15 to December 7, with coverage starting January 1. Demand and competition peak inside those 54 days.

    Medicare.gov enrollment table showing the Open Enrollment Period from October 15 to December 7 with coverage starting January 1, and the Medicare Advantage Open Enrollment Period from January 1 to March 31
    Medicare.gov's own calendar: requests must reach the plan by December 7 for January 1 coverage. Your lead budget has the same deadline.Source: Medicare.gov, Joining a plan, captured Oct 2026

    Search data shows how sharp that peak is. Google searches for "medicare advantage plans" reached 673,000 in October 2025 and fell to 165,000 in June and July 2026.

    Bar chart of monthly US searches for medicare advantage plans: 673,000 in October 2025, 450,000 in November and December, falling to 165,000 in June, July and September 2026
    October demand is four times the summer level. Source: Google Ads keyword data via DataForSEO, Oct 2026.

    InsureLeads notes that its AEP pricing varies with demand, and a lead bought in late November has the fewest selling days left.

    Under 42 CFR 422.2263, marketing for 2027 plans opened October 1, the day the new CMS rules below took effect.

    Six kinds of Medicare leads

    Medicare Advantage and Medicare Supplement leads come in six formats. They differ in price, in who else gets the same person, and in the consent attached.

    Medicare lead types compared
    Lead typeHow it reaches youWho else gets itBest use
    Aged leadsInquiries 30 or more days oldUsually resoldEmail nurture, dialer practice
    Shared web leadsReal-time form sold to several agents2 or more agentsTeams that call in minutes
    Exclusive web leadsReal-time form, one buyerOnly youAgents with fast follow-up
    Live transfersScreened caller patched to your phoneOne agent per callClosers with open AEP calendars
    T65 direct mailReply cards from people turning 65Varies by vendorPipeline outside AEP
    Your own campaignsSearch, Meta, Google Business Profile, eventsOnly youBuilding a book you own

    A T65 lead is someone approaching 65. Medicare.gov describes their Initial Enrollment Period as 7 months, starting 3 months before the 65th birthday month and ending 3 months after it.

    What Medicare leads cost in 2026

    Few Medicare lead generation companies publish a rate card for insurance agents. Most vendor pages we checked show no prices at all.

    InsureLeads Medicare pricing table: aged leads from $5, exclusive web leads $70, interest-verified live transfers $125 per call
    One of the few published Medicare rate cards: $5, $70 and $125 per lead depending on format, with a note that AEP pricing varies.Source: InsureLeads Medicare leads page, captured Oct 2026

    InsureLeads' Medicare page, last updated August 1, 2026, lists aged leads from $5 (its summary line says $0.75 to $5 by record age), exclusive web leads at $70 and interest-verified live transfers at $125 per connected call.

    Google's AI Overview for "medicare leads" quotes $35 to $75 for exclusive web leads without naming a source. Ask any vendor for a written price, minimum order and return terms.

    The ceiling: what CMS lets a carrier pay you

    Medicare Advantage commission is capped by CMS, so the most any lead is worth is known before you buy it. Few other insurance lines give you that ceiling.

    CMS's June 1, 2026 compensation memo sets the 2027 fair market value amounts carriers may pay independent agents and brokers:

    CMS maximum agent and broker compensation for 2027
    Plan type and areaInitial yearRenewal years
    Medicare Advantage, national$725$363
    Medicare Advantage, CT, PA, DC$816$408
    Medicare Advantage, CA and NJ$902$451
    Part D plan (PDP)$130$65

    These are maximums, and a carrier can pay less. Referral payments are capped as well: $100 for a referral into a Medicare Advantage plan and $25 for a PDP, under 42 CFR 422.2274.

    The same rule sets the second limit, rapid disenrollment. If a member changes plans within the first three months of enrollment, the carrier must recover the compensation it paid.

    That hits AEP sales hardest. An enrollment effective January 1 that switches during the January to March Medicare Advantage Open Enrollment Period falls inside those three months, so a poorly matched sale can cost you the whole commission.

    Cost per enrollment decides whether to buy or build

    The break-even price for a Medicare lead is your enrollment rate times the commission. At 10% enrollment and the $725 national cap, that is $72.50 per lead.

    Here is that math across lead types, using the published prices above. The enrollment rates are our assumptions for illustration, not measured results, so swap in your own numbers before deciding.

    Illustrative cost per Medicare Advantage enrollment. Prices: InsureLeads and Google Ads data. Enrollment rates are assumptions.
    Source and priceEnrolls (assumed)Cost per enrollmentvs $725 cap
    Aged lead, $51%$500Under
    Exclusive web lead, $7010%$700Barely under
    Exclusive web lead, $70, slow callback5%$1,400Nearly double
    Live transfer, $125 per call25%$500Under
    Own search campaign, $88 per lead20%$439Under

    The own-campaign row uses the $13.17 average US click cost for "medicare agent near me" and assumes 15% of clicks become a call or form. You can measure both inputs in the first week.

    Bar chart of illustrative cost per enrollment: own search campaign $439, live transfer $500, aged lead $500, exclusive web lead at 10% $700, CMS first-year cap $725, exclusive web lead at 5% $1,400
    Same $70 lead, two outcomes: $700 or $1,400 per enrollment, depending on how many enroll. Illustrative math with assumed enrollment rates. Sources: InsureLeads prices, Google Ads CPC via DataForSEO, CMS 2027 compensation memo.

    Two points hold whatever rates you plug in. Follow-up speed alone can turn the same $70 lead from profit to loss, and a member who stays earns renewals of up to $363 a year.

    This is the argument behind Growbi's CPL vs CPA press release. In the Predire Champlain med spa case study, 392 leads at $16 each turned into 163 arrivals at $38.48 per arrival, and the second figure is the one that runs a business.

    If you buy from more than one source, tag every lead and record when it books, shows and enrolls. Our guide to tracking cost per booked appointment walks through that setup step by step.

    CMS marketing rules that changed on October 1, 2026

    CMS published its 2027 Medicare Advantage and Part D rule on April 6, 2026, and its marketing changes apply to all 2027 materials from October 1, 2026.

    The CMS partner tip sheet lists six changes. These touch Medicare leads, checked against the old and current federal text:

    Medicare marketing rules before and after October 1, 2026
    RuleBeforeFrom October 1, 2026
    Scope of Appointment timingAt least 48 hours before the appointment, with exceptionsAppointment any time after the SOA is recorded
    SOA forms at educational eventsNot allowedAllowed
    Marketing event after an educational eventNot within 12 hours in the same buildingRight after, if attendees are told and can leave
    TPMO disclaimer on sales callsWithin the first minuteBefore any benefits are discussed
    Resources named in the disclaimerIncluded SHIPsMedicare.gov and 1-800-MEDICARE only
    Sales call recordingsKept 10 yearsKept 6 years, transcripts allowed in years 4 to 6

    For lead generation the first two rows matter most. A same-day appointment from a fresh lead is allowed once the SOA is recorded, so speed to contact is no longer capped by a waiting period.

    The SOA still sets the boundaries. It must be in writing for in-person appointments, it limits the meeting to the products the beneficiary agreed to discuss, and it stays valid for 12 months, per 42 CFR 422.2264.

    The TPMO disclaimer, word for word

    Sell plans for more than one carrier and you are a third-party marketing organization (TPMO). For agents who do not sell every plan in the area, the disclaimer reads:

    Under 42 CFR 422.2267 it is said on sales calls before benefits come up, sent in emails and chats, displayed prominently on your website and included in print and TV ads. A landing page is a website, so the disclaimer belongs there too.

    Contact rules that decide whether a lead is usable

    A cheap lead is worthless if you are not allowed to call it. CMS bans unsolicited calls, texts and voicemails to beneficiaries, including calls based on referrals.

    The same section bans door-to-door visits without an appointment, approaching people in parking lots or lobbies, and unsolicited direct messages on social media. Mail and email with an opt-out are allowed.

    A call stops being unsolicited when the beneficiary started the contact or gave consent, such as returning your call or sending back a reply card asking to be contacted. That consent record is the asset you are buying.

    The TCPA adds phone rules. The FCC's one-to-one consent rule never took effect: a court vacated it and the FCC removed it on July 14, 2025.

    Autodialed or prerecorded sales calls and texts still need prior express written consent, and the FCC's October 1, 2026 order keeps the 10-business-day deadline for honoring a revocation.

    Licensing is the last filter. CMS requires agents licensed in the state and appointed by the carrier, so a lead from a state where you lack either is a refund request.

    None of this is legal advice. Your carriers' compliance teams and your counsel have the final word on scripts and consent language.

    Generating your own Medicare leads on Meta and Google

    Running your own digital marketing means the leads, consent records and call recordings belong to you. Two platform rules shape every campaign.

    On Meta, health insurance and every other insurance line falls under the "Financial products and services" special ad category, required for US advertisers since January 21, 2025.

    Meta Business Help Center article stating that financial products and services ads include those promoting insurance, bank accounts, investment services and payment services
    Meta names insurance as a financial product, so Medicare ads run with limited audience tools.Source: Meta Business Help Center, captured Oct 2026

    In that category, Meta limits or removes age, gender, ZIP code, lookalike and saved audiences. You cannot target 65-year-olds by age, so the copy does the targeting: "Turning 65 this winter?" filters better than any interest.

    Meta Ad Library exact-phrase search for medicare advantage showing about 17,000 active US ads, including HealthSpring and Aetna ads that started running in August and September 2026
    About 17,000 active US ads use the exact phrase "medicare advantage", and carriers like HealthSpring and Aetna started theirs before AEP.Source: Meta Ad Library, captured Oct 2026

    Google search is the higher-intent channel. "Medicare agent near me" averaged 8,100 US searches a month at a $13.17 average click cost, and reached 18,100 in October 2025.

    Google results for medicare agent near me in Tampa, Florida: a map pack with three local Medicare agencies rated 4.8 to 4.9 stars with 275, 434 and 7,900 reviews
    A Tampa search for "medicare agent near me": the map pack is all local agencies, ranked with hundreds to thousands of reviews.Source: Google Search, Tampa FL, captured Oct 2026 via DataForSEO

    Those listings carry 275 to 7,900 reviews. A Google Business Profile with steady reviews is the cheapest lead source an agent controls.

    Google's financial services verification does not block a US campaign today. Its country list covers 42 locations, and the United States was not one of them in October 2026.

    Every ad, form and landing page you run as a TPMO carries the disclaimer. Write it into the creative brief before anyone drafts an ad; that is step one of our finance campaign management process.

    Questions to ask any Medicare lead vendor

    Before you buy a single AEP lead, get written answers to five questions. A vendor that dodges any of them is pricing its risk into your budget.

    • Show me the consent. The form wording, timestamp, page URL and verified contact information for each lead.
    • Who else gets it? Exclusive should mean one buyer, never resold later as an aged record.
    • Which subcontractors touched it? CMS requires TPMOs to disclose subcontracted lead generation relationships to the plans.
    • What is the return policy? Wrong numbers, out-of-state and already-enrolled leads should earn credit by a written deadline.
    • Are transfer calls recorded? You need every sales call kept 6 years, the first 3 in audio.

    Then test small: one batch, every lead called within 5 minutes, and enrollments counted at 90 days before you scale.

    It is the method from our guide to roofing lead generation costs: judge each source on the outcome you are paid for.

    A 90-day plan from AEP to T65 leads

    AEP lasts 54 days. The agencies that come out ahead treat it as the start of a year-round pipeline, not a sprint.

    The order we would follow from mid-October.

    1. Now to December 7: work AEP intent

      Fund search, inbound calls and transfers that come with consent records. Book same-day appointments once the SOA is recorded.

    2. Every sale: protect the commission

      Check doctors and drugs before enrolling. A member who switches between January and March triggers rapid disenrollment recovery.

    3. January 1 to March 31: respect the MA OEP

      CMS bars knowingly sending unsolicited marketing to members during the Medicare Advantage Open Enrollment Period. Shift budget to age-ins.

    4. Year-round: build T65 flow

      Run Meta and search ads for people turning 65, plus reply-card mail. Each prospect has a 7-month window.

    5. Weekly: judge enrollments, not leads

      Track cost per enrollment by source and cut any source that stays above your commission.

    FAQs

    What is a T65 Medicare lead?

    A T65 lead is a person turning 65 who asked for Medicare information. Their Initial Enrollment Period lasts 7 months, starting 3 months before the 65th birthday month, which makes T65 the main lead source outside AEP.

    Which Medicare lead vendors are the best?

    The one whose leads enroll and stay enrolled past 90 days at a cost below your commission. Ask for consent records, exclusivity terms and a written return policy, then test small.

    How do I get Medicare leads?

    Buy them as aged, web, direct mail or live transfer leads, or generate your own through Google search, Meta ads, a Google Business Profile, referrals and educational events. Since October 1, 2026, you can collect Scope of Appointment forms at educational events.

    Conclusion

    Medicare leads are one of the few insurance leads with a known ceiling. CMS caps 2027 first-year Medicare Advantage commission at $725 nationally, so every source can be priced in advance: enrollment rate times the cap.

    Use AEP to buy what converts, call it within minutes and document every SOA and disclaimer. Then build your own T65, search and referral flow, so next October starts with a pipeline instead of a vendor invoice.

    Want that math before next AEP? Book a free 15-minute call. We will price each of your lead sources against the $725 cap and show where your own campaigns would beat buying.

    Add us as preferred source on Google →

    About the author

    Mor Romano, CTO of Growbi, who wrote and reviewed this article

    Mor Romano

    CTO, Growbi

    Written and fact checked by Mor Romano, published .

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