Health Insurance Leads During ACA Open Enrollment: What a Billable Call Should Prove Before January 15

Buy health insurance leads for ACA Open Enrollment only if the call can reach an enrollment your agent is allowed to complete. That takes four things: a state license that covers the caller, an agent registered with the right exchange, documented consumer consent, and a caller who can enroll in that part of the season. Write your billable definition around those four, not around call length alone. For plan year 2027, Open Enrollment on HealthCare.gov runs from 1 November 2026 to 15 January 2027.

What dates does a 2027 Open Enrollment call have to respect?

HealthCare.gov sets the federal calendar. A caller who enrolls by 15 December gets coverage starting 1 January. Enrollments from 16 December to 15 January start coverage on 1 February. After 15 January, a caller can enroll only through a special enrollment period with a qualifying life event. State-based exchanges can set their own dates, so check each state you buy.

Those dates change three things on the call.

• The script. Tell every caller the coverage start date that applies on the day of the call. A caller reached on 20 December who expects 1 January coverage has the wrong expectation, and that call is a likely dispute.
• Caps and staffing. The 15 December and 15 January deadlines are the dates most likely to change caller behaviour, so plan daily caps and staffed hours for the days before each one and adjust them from your own call data.
• Budget flex. Open Enrollment brings a surge in the first weeks, so we flex ACA budgets around 1 November and again after 15 January. The ACA and other verticals page sets out the calendar for each line.

Is health insurance lead demand only an Open Enrollment spike?

Google Trends for US web search gives relative interest on a 0 to 100 scale, not a volume count. Over the last 12 months, "health insurance leads" averaged 40, while "aca leads" averaged 1 and shows only single spikes. The top related query for "health insurance leads" is "health insurance leads for agents", which points at agents buying leads rather than consumers searching for coverage.

The five-year view shows small November and December bumps in most years. Its highest week was the week of 22 February 2026, so demand does not stop when Open Enrollment ends. The weeks from 21 December to 2 January read 0 every year. Zero weeks in Trends usually mean sparse data, not zero demand, so do not size a budget from that stretch.

Read this as agents searching all year, with a bump near Open Enrollment. It does not show that Open Enrollment causes your calls, and it gives no volume. Check the 12-month view and the five-year view, then compare them with your own call data for the same weeks.

Is the agent allowed to enroll on that exchange?

The exchange registration and training rules sit in 45 CFR 155.220(d). An agent not registered with the exchange for that state cannot complete an application there, so a call routed to that agent is not billable, whatever its length.

Plan year 2027 also has a registration pause to check. A CMS interim final rule, effective 22 September 2026, paused plan year 2027 registration on the Federally-facilitated Exchanges for agents without a plan year 2026 agreement. It does not apply to state-based exchanges, and it was scheduled to end on 1 February 2027. Healthcare Dive reported on 6 November 2026 that a Maryland federal court preliminarily enjoined the moratorium on 5 November 2026, and the litigation continues. Confirm the status with CMS and your compliance team before you buy and before you route calls.

What should your ads and landing pages promise before the click?

Ads and landing pages make the first promise to a caller. The rules in 45 CFR 155.220(j)(3)(iii) bar cash or gift-card inducements, falsely suggesting that consumers will always qualify for a zero-dollar premium, government logo facsimiles, and miscommunicated deadlines. Our verticals page adds one more ACA rule we build to: ads and landing pages must not imply government affiliation.

The zero-dollar premium is the claim that causes the most trouble. A "$0 plan" headline draws callers who expect a free plan. Many will not qualify once income and household details are screened, so the call fails at the screen. It still costs media, and it still counts as a call if your rule is length only. Write the headline around the enrollment process and the dates instead.

Medicare searches are a common leak. People searching for Medicare land on ACA pages, and so do callers who are too young for the marketplace or already covered elsewhere. Fix this with separate campaigns and ad groups for each vertical, with copy and landing pages that set expectations before the call. The Medicare Advantage call buying post covers the Medicare side.

What should the call screen exclude, and what goes in writing?

Agree these rules with your buyer before the first call, and get the answers in writing.

| Rule | Why it matters in Open Enrollment | What to ask your seller or media buyer | |---|---|---| | Licensed in the caller's state | The agent can enroll only callers in states where they hold a license | Which state licenses does each agent hold, and who checks them? | | Registered with the caller's exchange | An agent not registered with that exchange cannot complete the application | Which exchange is each agent registered with, and since when? | | On Medicare | Medicare callers do not fit an ACA pitch | Are Medicare callers screened out, and do they count as billable? | | Employer coverage | Some callers have employer coverage and are not shopping for a marketplace plan | Is employer-covered excluded at the screen, and is it billable? | | Medicaid only | Callers who qualify only for Medicaid take a different path | Is Medicaid-only excluded, and how is it asked? | | Qualifying event after 15 January | Without a life event, the caller cannot enroll after 15 January | Which event is recorded, and is its date checked? | | Duplicate window | A repeat caller inside the payout window is not a second sale | How long is the window, and what resets it? | | Staffed hours and minimum duration | A call that reaches no agent cannot become an enrollment | Which hours are staffed, and what minimum duration counts? |

What has to be on the consent record?

Before an agent helps with an application, the consumer's consent must be obtained and documented. Under 45 CFR 155.220(j)(2)(iii), the record covers the scope, purpose and duration of the consent, the date, the names involved, and how the consumer can rescind it. For plan years ending before 1 January 2028, the rule accepts examples such as a signature, a recorded verbal confirmation, or a response to a communication. Keep the record for 10 years. From plan years beginning on or after 1 January 2028, consent must use a form created by HHS.

A special enrollment request also needs the consumer's authorization and awareness of the triggering event under 155.220(j)(2)(viii). Ask your buyer whether the recording captures the consent statement, who keeps it, and for how long. Agree those answers with your compliance team. This is a checklist for that conversation, not legal advice.

What happens to a call after it ends?

A billable call is only as good as its record. For each call you pay for, ask for the call ID, duration, caller state, agent name, exchange, consent reference and outcome. Agree the dispute window and the return reasons before the first invoice. A call with no consent record, an agent without registration on that exchange, or a post-15-January call with no life event should each be a listed return reason.

Report profit per billable call every week, not clicks, split by state and by part of the season. Our weekly numbers come from the automation in the media ROI automation case study. It pulls ad spend from Google Ads, TikTok Ads and Facebook Ads, pulls call revenue from Ringba every 15 minutes, and posts ROI to Slack. The case study says it replaced about three hours a day of manual reporting.

What does one disputed call do to cost per enrollment?

HYPOTHETICAL: invented numbers. Not client data. Not vendor pricing.

Say a buyer pays $60 per call for 200 calls from 16 December to 15 January, billed on length alone. The total is $12,000, and 6 enrollments are reported from those calls. On the length-only reading, cost per enrollment is $12,000 ÷ 6 = $2,000.

Now suppose 40 of the 200 calls went to an agent not registered on that exchange, or had no consent record. None of those 40 produced an enrollment, because no enrollment could be completed. Under the rule in this post they are not billable. If the seller accepts the dispute, $60 × 40 = $2,400 comes back. The net cost is $9,600 for 160 billable calls, the 6 enrollments are unchanged, and cost per enrollment is $9,600 ÷ 6 = $1,600.

Cost per call looks the same on both readings. What differs is whether those 40 calls were paid for at all. If the seller refuses the dispute, cost per enrollment stays at $2,000.

To review your ACA screen, consent record and dispute terms before the 15 December cutoff, book a campaign review call. Commercial details are discussed on that call.

Frequently asked questions

Can a call on 20 December still lead to 1 January coverage?

Not on HealthCare.gov. Enrollment from 16 December to 15 January starts coverage on 1 February, so tell the caller that date. State-based exchanges can differ.

Is passing the screen enough to make a call billable?

No. The screen removes callers who cannot enroll in a marketplace plan. The call also needs an agent registered with that exchange, a consent record, and a caller eligible for that part of the season.

Does the moratorium on agent registration still apply?

A Maryland federal court preliminarily enjoined it, according to Healthcare Dive's report of 6 November 2026, and the litigation continues. Confirm the current status with CMS and your compliance team before each buy.

Do state-based exchanges follow the same rules?

Not always. State-based exchanges can set their own Open Enrollment dates, and the September 2026 registration pause did not apply to them. Check the calendar and registration rules for each state-based exchange you buy calls in.

Sources and dates

• HealthCare.gov, dates and deadlines for plan year 2027, checked 11 Nov 2026: https://www.healthcare.gov/quick-guide/dates-and-deadlines/
• eCFR, 45 CFR 155.220 (exchange registration, training and consumer consent), checked 11 Nov 2026: https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-B/part-155/subpart-C/section-155.220
• Federal Register, temporary moratoria on certain agent and broker registration (published 23 Sep 2026), checked 11 Nov 2026: https://www.federalregister.gov/documents/2026/09/23/2026-19493/patient-protection-and-affordable-care-act-temporary-moratoria-on-certain-agent-and-broker
• Healthcare Dive, judge sides with ACA brokers and lifts moratorium on new registrations, published 6 Nov 2026, checked 11 Nov 2026: https://www.healthcaredive.com/news/judge-sides-with-aca-brokers-lifts-moratorium-on-new-registrations/873994/
• Google Trends, US web search, "health insurance leads" and related queries over 12 months, checked 11 Nov 2026: https://trends.google.com/trends/explore?date=today%2012-m&geo=US&q=final%20expense%20leads,health%20insurance%20leads,life%20insurance%20leads,aca%20leads,medicare%20leads&hl=en-US
• Google Trends, US web search, "health insurance leads" over 5 years, checked 11 Nov 2026: https://trends.google.com/trends/explore?date=today%205-y&geo=US&q=final%20expense%20leads,health%20insurance%20leads,aca%20leads&hl=en-US
• Jamil Global insurance verticals, media buying and the media ROI automation case study, checked 11 Nov 2026