AEP and Medicare Pay-Per-Call: What I Change Every October
The Annual Enrollment Period isn't just a busier version of the same program. Treat it that way and you'll pay for it in January.
Medicare's Annual Enrollment Period opens on October 15 and closes on December 7, and the plan changes made during it take effect on January 1. Marketing for the new plan year can start on October 1. If you buy Medicare inbound calls or live transfers, those seven or so weeks set your results for the year.
I've run Medicare programs through several of these seasons. The buyers who do well don't just add budget. They re-plan. Here are the five things I change before October 15.
1. I lock in supply before the rush.
Every carrier, FMO and agency scales up at once, so demand jumps faster than clean supply does. A publisher with properly consented sources can't double overnight. That means some of the "new" volume showing up in mid-October comes from sources I would turn down in July. So I agree volume, caps and pricing with proven publishers in September and audit any new source before it goes live. I don't audit it after.
2. I re-check the billable duration.
CMS requires third-party marketing organizations to read a standardized disclaimer within the first minute of a sales call and to record sales and enrollment calls in full. That disclaimer takes real time. A buffer set for a year-round program can pay out before the agent has qualified anyone. During AEP I prefer a longer buffer paired with a simple qualification event, such as the caller confirming Medicare Parts A and B.
3. I staff to real capacity, not hoped-for capacity.
An unanswered call is the most expensive call there is. Agents need a license in the caller's state and certification for the new plan year with each carrier. I match state targeting to the licensed footprint I actually have, and I set concurrency caps for the agents who will really be on the floor.
4. I review every source's creative and consent.
Complaints, carrier reviews and audits peak in AEP. Before buying, I ask each publisher for the real ads and landing pages, the traffic type (search, social, TV, IVR or outbound-generated) and how any consent was captured. Anything that implies a government affiliation or promises benefits a plan may not offer is out.
5. I measure cost per retained enrollment.
When a member disenrolls in the first three months, the agent's commission is recovered. An enrollment that doesn't stick can cost more than the call that produced it. I track each source through enrollment and past that window, and I share the results with publishers. The good ones welcome it.
After December 7
The market contracts but doesn't stop. The Medicare Advantage Open Enrollment Period (January 1 to March 31), Special Enrollment Periods and people turning 65 keep demand going all year. Each of these needs different qualification questions and often different pricing. I agree the December 8 and January 1 changes with publishers before AEP ends, so the best sources stay with me.
AEP is the most profitable season in Medicare pay-per-call, and the least forgiving. The preparation happens in September.
General industry commentary, not legal or compliance advice. Confirm current CMS requirements with your compliance team.
A longer version of this piece is published on ZW Global Group.
Wali Zuberi — BPO · Contact Centers · AI. Rawalpindi-based operator with 17+ years in sales, BPO and pay-per-call contact centers. Leads Alrehman Communication LLC and ARC LLC Technologies within the ZW Global Group ecosystem.