Every year, the Medicare Annual Enrollment Period (AEP) runs from October 15 to December 7, with plan changes taking effect on January 1. Marketing for the coming plan year can begin on October 1. For anyone buying Medicare inbound calls or live transfers, those dates are not just calendar entries — they redefine supply, price, quality and compliance risk for roughly a quarter of the year.
Having run Medicare programs through several enrollment seasons, I see the same pattern each year: buyers who treat AEP as “the same program, but bigger” overpay, while buyers who re-plan their buying for AEP get more enrollments for less money. Here is what changes, and what to do about it.
1. Demand spikes faster than quality supply
During AEP, every eligible beneficiary can change plans, so carriers, FMOs and agencies scale up at the same time. Demand for calls rises sharply in the first weeks. Supply rises too, but not evenly: publishers with clean, consented sources cannot double overnight, so some of the new volume comes from sources that would not pass scrutiny in July.
What to do: lock in volume with proven publishers before October, agree caps and pricing in writing, and onboard new sources early enough to audit them. Treat any source that appears for the first time in mid-October with extra caution.
2. Your billable duration needs to reflect the TPMO disclaimer
CMS requires third-party marketing organizations (TPMOs) to deliver a standardized disclaimer within the first minute of a sales call, and to record marketing, sales and enrollment calls in their entirety. That disclaimer consumes real time at the start of every conversation.
If your billable threshold was set for a year-round program, it may now be billing before the agent has even started qualifying the caller. What to do: revisit buffers before AEP. Many buyers move to longer billable durations for Medicare inbound during enrollment season, and some pair the duration with a simple qualification event (for example, the caller confirming Medicare Parts A and B) so that a call is paid when it is genuinely sellable.
3. Agent capacity becomes the real constraint
A call you cannot answer is the most expensive call you will buy. Agents must be licensed in the caller’s state and certified for the new plan year with each carrier they represent. If certification or contracting lags, the call routes nowhere useful.
What to do: align state targeting with your actual licensed footprint, set concurrency caps that match the agents you will have on the floor (not the agents you hope to hire), and give publishers hours of operation that reflect real staffing. Hold times during AEP cost you twice: the call is lost and the publisher’s source quality looks worse than it is.
4. Compliance scrutiny rises with volume
CMS has steadily tightened the rules around Medicare marketing: the standardized TPMO disclaimer, full call recording and retention, limits on misleading creative, and the scope-of-appointment waiting period for scheduled personal marketing appointments. AEP is when complaints, audits and carrier reviews peak.
What to do: before you buy, ask each publisher for the actual creative and landing pages behind their calls, the traffic type (search, social, TV, IVR or outbound-generated), and how any consent was captured. Reject creative that implies government affiliation or promises benefits a plan may not offer. Make sure your own agents deliver the disclaimer consistently — buyer-side failures count too.
5. Measure cost per retained enrollment, not cost per call
AEP rewards buyers who look past the call. Under Medicare compensation rules, agent commissions are recovered when a member disenrolls within the first three months, so an enrollment that does not stick can cost more than the call that produced it.
What to do: track every source through to enrollment and to retention past the rapid-disenrollment window. Share those outcomes with publishers. The best publishers welcome the feedback; the ones who resist it are telling you something.
6. Plan for the months after December 7
When AEP closes, the market contracts but does not stop. The Medicare Advantage Open Enrollment Period (January 1 to March 31) lets people already enrolled in Medicare Advantage make one change, and Special Enrollment Periods and newly eligible beneficiaries turning 65 sustain demand through the year. Each of these audiences needs different qualification questions and often different pricing.
What to do: before AEP ends, agree with your publishers how campaigns, qualification scripts and caps will change on December 8 and again on January 1. Programs that transition cleanly keep their best sources; programs that go dark lose them to buyers who stayed.
A short pre-AEP checklist for buyers
- Volume, caps, hours and pricing agreed in writing with each publisher for October 15 – December 7.
- Billable duration and qualification event reviewed against your disclaimer and opening script.
- Licensed and certified agent capacity mapped by state and hour; concurrency caps set to match.
- Creative, landing pages, traffic types and consent capture reviewed for every source.
- Source-level tracking to enrollment and retention, with a feedback loop to publishers.
- A written plan for December 8 and January 1.
AEP is the season when Medicare pay-per-call is most profitable and most unforgiving. The buyers who win it are the ones who prepared in September.
This article is general industry commentary, not legal or compliance advice. Confirm current CMS requirements with your compliance team or counsel.