Quick answer: This Annual Enrollment Period, which runs October 15 to December 7, is going to produce some of the highest-intent Medicare call volume the category has seen in years. Not because more people are curious about their coverage. Because millions of them are being forced to shop rather than choosing to, on a deadline, having lost the plan they had.
A consumer who has to act is a better consumer than one who is browsing. That is the opportunity.
The catch is that capturing it is harder than it looks, and it is harder this year than last. Buyers cannot expand phone capacity as fast as they can approve budget. Plan economics are moving underneath everyone mid-window. And a displacement event this well publicized pulls in supply that has never run the vertical before.
So this is a year that rewards experience and judgment over budget. Which sources you buy from, and which network is placing your calls, is the decision that settles your season.
Why this AEP produces unusually good Medicare calls
Start with the consumer, because everything else follows from what they are doing.
Most Medicare beneficiaries in any given year do nothing. They auto-renew. The plan is fine, the paperwork is annoying, and inertia wins. That is the default state of this market and it is why AEP marketing is hard in a normal year.
This is not a normal year. A large and growing number of people are having the decision made for them.
Carriers have been retreating from unprofitable Medicare Advantage business for two enrollment cycles. Roughly 2.6 million people in individual Medicare Advantage prescription drug plans were in a plan that was terminated for the 2026 plan year, up from nearly 1.3 million the year before, according to KFF. It doubled in a year. It has not stopped: for 2027, Humana alone is exiting plans covering about 600,000 members, with non-renewal letters landing in early October, days before AEP opens.
Now think about what that letter does to the person who opens it.
They cannot auto-renew, because there is nothing to renew into. They have a hard deadline of December 7. They gain a guaranteed-issue right to a Medigap policy they did not have before, exercisable within 63 days, which is a genuinely consequential decision most people will not want to make alone. And comparing Medicare plans is hard enough that a large share of them will want to talk to a human being.
That is not a lead. That is somebody who has to transact, inside a window, with a reason to pick up the phone.
And it is observable that these people move rather than disappear. During the last enrollment period, one national carrier's Medicare Advantage membership fell about 9% and another's fell 14%, while Humana added more than a million members and regional plans posted record gains. Displacement did not shrink the market. It reshuffled it, at scale, in eight weeks.
The judgment I would offer is this. The Medicare plan market getting smaller and the Medicare call opportunity getting better are not contradictory. They are the same fact viewed from two seats. Every plan exit converts a passive renewer into an active shopper, and active shoppers are what pay-per-call is for. The contraction that is bad news for a carrier's membership line is the single best demand generator this channel has.
Why most buyers will underconvert it
The mistake is treating a demand surge as a budget question. It is a handling question, and it always has been.
During AEP, a buyer's binding constraint is capacity to answer the phone. Not spend authorization, not consumer demand. Watch what buyers actually do heading into October: they hire seasonal call center staff and licensed Medicare sales agents specifically for the window, extend daily hours into overtime, and open weekends that are otherwise closed or skeleton-staffed. Every one of those levers takes weeks, and two of them run through licensing and appointment requirements that no budget shortens.
A buyer can approve more spend on Tuesday. They cannot have a trained, licensed, seasoned agent by Friday.
The arithmetic that follows is what most buyers get wrong. Outside AEP, a bad call costs you what you paid for it. During AEP, a bad call costs you what you paid for it plus the good call the occupied agent could not take. Capacity is the scarce input, and a junk call consumes the scarce input. When the consumers on the other end are forced shoppers with a deadline, the call you displaced was worth real money.
Which inverts the instinct almost everyone has. The urge during a volume surge is to loosen quality standards to get more at-bats. In this channel, in this season, quality tolerance should tighten exactly when capacity tightens.
Telling a capacity problem from a quality problem
Both failure modes arrive wearing the same sentence: these calls aren't converting. That is why so many AEP post-mortems reach the wrong conclusion in December.
Capacity failure shows up as calls that do not connect, long hold times, and ringing that goes on and on. Quality failure shows up as connected calls that go nowhere. And the two are frequently tangled, because bad actors flood volume into a buyer's system in precisely the window when it has the least slack, clogging the queue and consuming the capacity that exists. That buyer now has a capacity problem caused by a quality problem and a dashboard showing neither.
Separating them means looking at handling rather than outcomes: connect rates and hold times by source and by hour, dispositions rather than conversions alone, and whether the weakness tracks the phone room's schedule or tracks a particular source. If it follows your staffing shape, it is capacity. If it follows a source, it is quality.
This is also the clearest reason to work through a network rather than assembling supply yourself. We are sitting on both sides of the transaction at once. We can see that a buyer's conversion dipped on Thursday afternoon across every source, which is a staffing signal, or that it dipped on one source across every hour, which is not. A single-sided vendor cannot see the first pattern and a buyer looking only at their own dashboard often cannot see the second.
Why most affiliates will misplay it
The sell-side version of the same mistake is chasing the headline.
A displacement event this visible gets written about everywhere, and a lot of marketers will read those headlines and decide Medicare is where the money is this quarter. Some of them have never run the vertical. Many will try to get to volume fast, and the fastest way to add volume is to buy it from somebody else.
That is where most of the problems we see originate: marketers rebrokering to other affiliates they have neither vetted properly nor can optimize. You have inserted a layer between yourself and traffic whose quality you are accountable for, and you cannot see into it. When the buyer's numbers go soft in November you will not be able to explain why, and you will not be able to fix it.
The mistake is more expensive this year than usual. When buyers are margin-constrained, the first supplier they cut is the one whose quality cannot be explained. Publishers who focus on what they actually know how to do, and who can account for every call they send, will still be running in December.
Mid-window volatility is a supply-structure problem
Plan this season assuming that what you sell on October 15 is what you will sell on December 7, and this is the year that assumption breaks.
During the last enrollment period, carriers pulled broker commissions on specific plans days or weeks after the window opened, in at least one reported case because a plan was growing faster than the carrier wanted. Separately, Medicare Advantage plans have long had the authority under 42 CFR § 422.254 to cap enrollment, and CMS set out how that works operationally in its CY2027 Enrollment and Disenrollment Guidance released in August. The authority is not new. The likelihood of plans using it is.
When a commission gets pulled, the buyer selling that plan does not taper. They stop. Calls worth full price on Monday are worth nothing on Tuesday, and the affiliate driving them finds out when the cap goes to zero.
Most people treat that as a pricing risk. It is a structural one, and the structure is where it gets solved.
If you are an affiliate sending calls to one buyer running one plan, a mid-window commission pull ends your quarter and there is nothing to do about it. If your calls are being placed across a vetted set of buyers, the volume redirects and you keep earning. If you are a buyer whose supply is concentrated in two sources that need a long runway to change direction, you cannot reallocate quickly when a plan closes. If your supply is a vetted set that can be throttled and redirected the same day, you can.
That is not an abstract argument for using a network. It is the specific reason a network earns its place in a volatile year: the ability to move volume between pre-vetted counterparties without a new diligence cycle in the middle of the busiest eight weeks of the year. Assembling that during AEP is not realistic. Having it already is the whole point.
What you cannot buy in October
The work that decides your enrollment season happened in months when there was no commercial reason to do it.
A buyer needs a deeply vetted and optimized set of suppliers. Building one takes time and volume, and the only place to get both is the off-season. Which is why, despite the non-AEP months being slow, Medicare agencies should be maintaining relationships with their top vendors year-round rather than rebuilding a supply set every September.
Consider what nobody can learn about a partner in four weeks:
- Churn on the policies their calls produce. A call that converts to a policy that lapses in ninety days was not a good call. You will not know in November.
- How they handle callbacks. When a consumer calls back a second or third time, does that partner make sure the consumer reaches the same buyer who paid for the original lead, or does the callback get resold? This is where a vendor's short-term and long-term interests diverge most sharply. Rerouting a callback captures margin for the vendor today and destroys the buyer's economics on a consumer they already paid for.
- Whether they optimize for your bottom line or their margin. Every vendor says the former. Quarters of behavior demonstrate it.
This is the part of the business that does not show up on a rate card, and it is the part we have spent years accumulating. Knowing which sources handle callbacks honestly and which ones produce policies that stick is not information a buyer can purchase in October at any price. It is the product of having watched the same partners through multiple enrollment periods.
What we ask a buyer before we answer
When a buyer tells us they want to be at volume for October 15, we do not start with volume. We start with handling, because handling is the ceiling.
How many agents, and what are the hours? This is the capacity envelope and it caps everything downstream. Hours matter as much as headcount, because AEP demand does not politely arrive between nine and five.
What is the target CPA? Not aspirational. The number the economics require, and the tolerance around it.
How are the calls being handled? What happens between the phone ringing and a licensed agent speaking to a qualified consumer is where most recoverable performance lives.
What do you need from us beyond volume? For some buyers the answer is a qualification layer on our side: our own front-line agents screening calls and warm-transferring qualified consumers directly to the buyer's licensed sales agents. In a season where licensed capacity is the scarce input, moving the screening upstream of that capacity is worth more than a lower price per call. For others it is creative, lining up assets and clearing CMS marketing guidelines, which is a process that has to start before summer does to leave room for the ordinary delays of CMS review.
And this year: which of the plans you are selling could see a commission change or hit an enrollment cap, and where does that volume go if one of them closes in week three?
Lock by now: capacity envelope, approved creative, the supply sources you intend to scale, the CPA your economics require.
Keep flexible into November: allocation across already-vetted sources, bids, hour-level pacing, how hard you lean on any one source.
And the part buyers do not want to hear: if you are arriving today without a vetted supply set and without approved creative, do not scale. Run this AEP small and deliberately, treat it as the season you build partner history, and spend the money on learning. Scaling into unvetted supply at peak agent cost is the most expensive way to buy information I know of.
What actually earns budget on the sell side
If you already have history with a network in this vertical, this is the year it is worth the most. Tighter buyer economics do not spread budget evenly. They concentrate it, because a buyer with less room for error stops paying for experiments. The affiliates who spent the slow months proving their traffic are the ones whose calls get placed in October, and the gap between them and everyone else widens in exactly these conditions.
If you are new to Medicare, the picture is harder and I would rather say so. You should already have been spending money and tuning messaging, creative and targeting ahead of September. Doing that confidently at this time of year means accepting that you are losing money now in anticipation of making it during AEP. There are really no exceptions.
To have a campaign ready to scale, you have to understand what your data will do when volume arrives. You can be strong on click-through and conversion rate and still be underwater because cost is too high and ROAS is negative. The October volume is what turns that around, and betting on it is a real bet.
Networks like ours lean on historical partnerships, our own internal media, and affiliates who spent months priming campaigns for this window. Coming in now and asking for budget means being ready to risk your own bottom line in the short term. What earns it is not volume. It is a track record, transparency about what your traffic actually is, and evidence you are willing to sacrifice something to prove you can perform.
The two objections
"I'll just buy more calls in October when I can see what's working."
Partly right. October can be a buyer's market and there is real option value in waiting, and there will likely be more supply available this year than last.
Where it breaks: how fast can you actually tell that the traffic you are buying produces good leads, and past that, how those leads behave as they become sold policies and what those policies are worth? Multiple parties sit inside that sequence and it takes the time it takes. Going into October without existing confidence in your sources means carrying a large amount of unpriced risk, and in a year with more untested supply entering the category that risk is bigger than it was last year.
"Medicare is locked up by the operators who do it every year."
Incumbency is real and it exists for the reasons above. The response is still straightforward: put something out there and test your traffic, accepting that you may spend a little into the negative to feel it out. What that buys is the trust of a network that can allocate budget when AEP arrives, on evidence that you did the hard work, that you are honest about your traffic, and that you were willing to sacrifice to prove it.
What to do this week
AEP opens in under a month, so this is the last useful week for either of these.
If you are buying calls: audit your supply set on the two things you cannot see in a month, which are policy churn and callback handling. Then list which of your plans could lose commission or hit an enrollment cap, and decide now where that volume goes if one does.
If you are selling calls: get something live and measured at whatever scale you can afford to lose money on, and be fully transparent with your network about what the traffic is. Volume without a track record does not get allocated. A track record without much volume often does.
The forced shoppers are coming either way. Whether they reach an agent who can help them, through a source that will still be worth buying from in December, is decided by who you are working with before October 15.
If you are buying or selling Medicare pay per call and want a straight read on your supply set or your traffic before the window opens, talk to our team. We will tell you if we think you should sit this one out.
FAQ
When is the Medicare Annual Enrollment Period in 2026? October 15 through December 7. It sells the 2027 plan year, and it is the window in which most Medicare beneficiaries can change plans.
Why is this AEP a bigger opportunity for Medicare pay per call? Because more consumers are being forced to shop rather than choosing to. About 2.6 million people in individual Medicare Advantage prescription drug plans had their plan terminated for the 2026 plan year, roughly double the prior year, and further exits are landing for 2027. Someone who loses their plan cannot auto-renew, has a December 7 deadline, and is far more likely to call.
Is a smaller Medicare plan market bad for call volume? Not for call volume. It is difficult for carriers and it tightens buyer margins, but every plan exit converts a passive renewer into an active shopper. Displaced members move between carriers rather than leaving the market.
Is the AEP constraint budget or capacity? Capacity. Buyers can approve spend far faster than they can hire, license, train and season licensed Medicare sales agents. Handling is the ceiling, not budget.
Why does a bad call cost more during AEP? Outside AEP it costs what you paid for it. During AEP it also costs the good call the occupied agent could not take. Capacity is the scarce input and a low-quality call consumes it, so quality tolerance should tighten as capacity tightens.
What happens if a carrier pulls commission mid-AEP? The buyer selling that plan generally stops buying calls for it immediately rather than tapering. Plans can also cap enrollment and close mid-window. The mitigation is structural: a vetted set of buyers means volume redirects instead of stopping.
Can an affiliate start running Medicare calls from a standing start now? Realistically you are preparing for the following AEP. The shortest path is to run small now, accept negative ROAS as the cost of learning, build a real track record, and be transparent about your traffic.