How should agencies buy ACA Open Enrollment leads?

Marketplace Open Enrollment starts November 1; deadlines and coverage timing vary by Marketplace and applicable rules. Verify the current calendar for each state you serve before approving advertising or scheduling delivery. Do not reuse an old national deadline across every jurisdiction.

Outside Open Enrollment, Special Enrollment Period eligibility is circumstance-specific. A person’s interest in coverage does not by itself establish a qualifying event or permission to submit an application.

Ask whether the advertisement offered Marketplace help, another health product, or a broad comparison service. Confirm how the consumer described their need. Under-65 health interest is not automatically an ACA-specific inquiry, and a generic payload can conceal a product-expectation mismatch.

Review advertisements for unsupported promises about eligibility, savings, or government payments. Agents should not have to undo a misleading offer before they can begin a useful conversation.

Before launch, ask a supervisor and an agent to walk through this step using a realistic sample. Record the decision they would make, the information they would need, and the condition that would stop the workflow. Resolve conflicting interpretations in the written procedure rather than leaving each agent to improvise during a consumer conversation.

Review applicable Marketplace agent and broker requirements for documenting consumer consent and confirming application information. Permission to receive a marketing call is not the same as authorization to take every application action. Make each step clear and preserve the required documentation under the applicable process.

Do not change an application, agent association, plan selection, or contact information merely because a lead was delivered. Establish consumer identity and authorization through your approved workflow before accessing or modifying sensitive information.

For live transfers, inspect screening and handoff language. For inbound calls, trace the originating advertisement and routing path. Require recordings, subject to applicable requirements, and ensure agents can identify their actual agency rather than presenting themselves as the Marketplace or another government office.

Route only to state-licensed, verified buyers and appropriately authorized agents. Check relevant Marketplace registration and other requirements for the work being performed instead of relying only on a vendor’s approved-buyer label.

Treat vendor answers as preliminary routing information. Confirm relevant household, coverage, location, and eligibility facts through the authorized application process. Do not encourage agents to adjust facts to match an advertisement or to produce a desired eligibility result.

Collect sensitive details only when needed and through approved systems. A lead vendor does not need unrestricted access to application information to resolve an ordinary delivery dispute.

Use a clearly named disposition for unresolved information. Do not force uncertain records into either a successful or defective category merely to simplify reporting. An unresolved item should have an owner, a next action, and a documented reason for any later change. This makes source feedback more useful and prevents assumptions from becoming permanent consumer facts.

Track source recognition, product mismatch, unsupported eligibility promises, permission gaps, and destination errors. Keep these separate from ordinary consumer decisions not to enroll. Review disputed records against the agreed specification and the actual source journey.

Pause sources that create confusion about government affiliation or application authority. Before scaling, confirm that supervisors can retrieve evidence, investigate complaints, and stop delivery without waiting for the next campaign cycle.

Require consent record text, timestamp, page URL, and IP address when applicable to the collection method. Keep source identifiers and version history so the delivered record can be traced to the actual consumer experience. These evidence fields support review; they are not a guarantee that every proposed use is lawful.

For call-based inventory, require accessible recordings with practices reviewed against applicable recording, privacy, and program requirements. Verify state-licensed buyers before routing. Keep opt-outs and incident handling operationally separate from commercial credit requests. This guide is not legal advice and does not imply government affiliation or endorsement.