Health Insurance Leads: What to Check Before You Buy

October 22, 20269 min read

Health insurance leads are the line item that often decides whether an independent ACA agent has a profitable open enrollment or an expensive one. Buy the wrong ones and you pay for disconnected numbers, people who never asked to hear from you, and households that five other agents called before lunch.

This guide is for agents deciding whether to buy health insurance leads, from whom, and how to work them without compliance exposure. You'll get a vendor vetting checklist built from CMS guidance, the consent fields to keep on file, calling rules for purchased lists, a simple qualification framework, and a way to compare buying leads with building your own source.

Why health insurance leads matter more in a smaller market

According to KFF's analysis of individual market enrollment through mid-2026 (opens in a new tab), individual market enrollment fell 18% between June 2025 and June 2026, from 25.2 million to 20.5 million people, a KFF estimate. KFF also notes that the decline coincides with the expiration of the enhanced premium tax credits.

Fewer shoppers means more agents competing for each household. When demand shrinks, every dollar you spend on leads has to earn its keep in enrollments, and it pays to be stricter about what you buy and from whom.

Decision rule: if you can't trace a lead back to a specific ad, a specific form and a consent record, don't buy it at any price.

Types of health insurance leads for agents

Vendors package leads in a handful of ways. Each has a different cost, freshness and level of competition, so know which one you're being quoted before you compare prices.

Real-time shared leads: delivered within minutes but sold to several agents at once. Cheaper per lead, crowded on the phone.
Real-time exclusive leads: sold to one agent. Higher price per lead, fewer competing calls, still worth verifying.
Aged leads: days to months old. Cheap, but contact info goes stale, many households have already enrolled, and consent may not name you.
Live transfers: the consumer is already on the line. Highest cost per contact; ask exactly how the call was generated.
Self-generated leads: from your own ads and quote page. You control the creative, the form, the consent wording and the data.

For a deeper look at how the per-lead price compares with what you actually pay per enrollment, see exclusive vs shared health insurance leads.

Before you buy health insurance leads, vet the vendor

In its Marketplace compliance presentation for agents and brokers (opens in a new tab), dated August 28, 2025, CMS strongly encourages agents working with lead generators to understand how the company generates leads, review its creative materials so they don't mislead or confuse consumers, and understand how leads are priced and sold so you don't buy one sold to multiple agents or brokers. The same presentation warns that you can face enforcement action for non-compliant practices when you use a third party.

This section and the next two are general information, not legal advice. Confirm the specifics with your compliance resources, your carriers and your state insurance department.

Use these questions on every sales call with a lead vendor. A vendor that won't answer them in writing has answered them anyway.

Questions to ask every lead vendor

Where does your traffic come from, and can I see the actual ads running now?
Can I see the form and the exact consent language the consumer agreed to?
Does the consent name me or my agency, or a generic list of partners?
How many agents receive each lead, and is it ever resold later as aged inventory?
How old is the lead at delivery, and is every record timestamped?
Will you provide the consent record for any lead on request, including date, form version and the consumer's name?
What happens when a number is disconnected or the consumer says they never asked for a quote?

Why recycled leads carry enrollment risk

A CMS statement republished by the Arizona Department of Insurance and Financial Institutions (opens in a new tab) reports that CMS received 134,368 complaints of unauthorized enrollments and 73,884 complaints of unauthorized plan switches in the first six months of 2024. According to that statement, starting July 19, 2024, CMS blocks agents from changing a consumer's FFM enrollment unless they are already associated with it; unassociated agents must hold a three-way call with the consumer and the Marketplace Call Center or direct the consumer to an approved Classic DE or EDE partner website.

In practice, a consumer who doesn't remember asking for you, or who is already enrolled with another agent, is a problem lead, not just a cold one. Ask about current coverage and current agent in the first minute of every call.

The same CMS presentation says that when you use information bought from lead generating companies, you must obtain and document consent from the consumer and keep a record of that consent for a minimum of 10 years. At a minimum, CMS says the documentation must include:

The scope of the consent
The purpose of the consent
The duration of the consent
The date consent was given
The consumer's name
The name of the agent, broker or agency being granted consent

A vendor's permission to contact a consumer is not the same as the consumer's permission for you to act on their Marketplace application. Get that second consent directly from the consumer, in writing, before you touch the application, and keep the two records separate so each one is clear about what it covers.

Test your filing this week: pick any client and see whether you can pull up their consent record by name in under a minute.

Calling purchased leads without TSR trouble

The FTC's Q&A on the Do Not Call provisions of the Telemarketing Sales Rule (opens in a new tab) says that if you're required to use the National Do Not Call Registry, you must sync your calling lists with an updated version at least every 31 days. It also says a consumer's inquiry permits calls for three months unless they ask you to stop, and that calling again after a do-not-call request may bring a fine of up to $53,088.

Scrub every purchased list before the first dial, and rescrub on a fixed schedule.
Keep an internal do-not-call list and honor requests immediately, across every number you call from.
Record the inquiry date on every lead so you know when the inquiry window closes.
Don't use autodialers, texts or prerecorded messages without the specific consent the TCPA requires; check the wording with your compliance resource.
Transmit accurate caller ID on every call.
Check your state's calling-hour, registration and telemarketing rules, which can be stricter than federal ones.

How to work and qualify health insurance leads

Speed matters because the consumer's memory of the quote request fades fast, and on shared leads other agents are dialing too. Set a rule: new leads get a call the same hour during business hours, then a text or email if consent covers it, then a second call the next day.

HubSpot's guide to sales qualification (opens in a new tab) describes BANT (Budget, Authority, Need, Timeline) as suited to early-stage qualification and transactional sales with shorter cycles, and advises discussing budget early. Here's how it maps to an ACA call:

Budget: what monthly premium works after the tax credit. Quote net, not gross.
Authority: who decides, and who belongs on the application as part of the household.
Need: current coverage, current agent of record, doctors and prescriptions that must be in network.
Timeline: open enrollment, or a qualifying life event that opens a Special Enrollment Period.

Opening script: Hi, this is [your name], a licensed health insurance agent. You asked for a Marketplace quote on [site name] today. Do you have five minutes to look at plans for your county? Then ask right away: Are you enrolled in a Marketplace plan now, and do you already work with an agent? Those two answers tell you whether to keep going.

Buy health insurance leads or build your own source

Compare every option on cost per enrollment. Hypothetical example: 100 leads at $30 each costs $3,000. If you reach 40 people and enroll 8 households, you paid $375 per enrollment. A cheaper lead that enrolls half as often is not cheaper.

Building your own source has real costs too. WordStream's 2025 Facebook ads benchmarks (opens in a new tab) put the average cost per lead for Facebook leads campaigns at $27.66 across all industries, up from $22.87 the year before, and found Finance and Insurance had one of the lowest click-through rates (0.98%) and the highest cost per click ($1.22) in traffic campaigns. Those are cross-industry ad benchmarks, not ACA figures; your results will vary by state, season, creative and landing page.

What you get for that spend is control. You write the ad, so you know what the consumer was promised. You write the form and the consent, so it names you. And the lead goes to you alone. Showing real plans priced with the tax credit tends to filter out casual clicks; see why in ACA landing page: what converts, and how to run the traffic in Facebook ads for health insurance agents.

If you'd rather not assemble the pieces yourself, FastTrack builds a branded quote funnel on your own domain under your NPN, captures permission to contact and permission to act on the Marketplace separately as signed PDFs, writes every lead into a GoHighLevel CRM configured for ACA, opens HealthSherpa prefilled for each quoted household, and runs Meta ads on your own ad account. Ad spend is billed by Meta directly, and your leads are never resold or shared.

Make your next lead dollar count

This week, send the vendor questions to anyone you buy from, audit your consent records against the CMS fields, confirm your DNC scrub schedule, and calculate cost per enrollment for each source you used last season. Cut the sources you can't trace.

If you want a lead source you own instead of rent, set up your FastTrack ACA lead system online, with no sales call.

Frequently asked questions

Where can I buy compliant health insurance leads?

No vendor is compliant just because it says so, and you stay responsible for how you use the leads. Ask how leads are generated, review the ads and consent language, and confirm how many agents receive each lead. This is general information, so confirm requirements with your compliance resources.

Are exclusive health insurance leads better than shared leads?

Exclusive leads usually cost more per lead but mean fewer competing calls, while shared leads are cheaper and more crowded. Neither is automatically better. Track both on cost per enrollment over a few weeks and keep the one that wins in your market.

Do I need my own consent if the lead vendor already collected it?

Yes. CMS expects agents using purchased information to obtain and document consent from the consumer, and a vendor's permission to contact is not permission to act on a Marketplace application. Get the consumer's consent for that yourself and keep it with the required fields.

Are aged health insurance leads worth buying?

They're cheap, but contact info goes stale, many households have already enrolled, and the consent may not name you. If you test them, buy a small batch, confirm the inquiry date and consent record, and measure cost per enrollment before buying more.

How fast should I call a new health insurance lead?

As fast as you can, ideally within the same hour during business hours, while the consumer still remembers the request. Scrub against Do Not Call lists first and log the inquiry date, since federal and state rules limit how long an inquiry permits calls.

Should I use Facebook instant forms or a landing page for ACA leads?

Instant forms tend to produce more volume with less intent, because submitting takes a tap or two. A quote-first landing page adds friction but shows real plans, filters casual clicks, and lets you control the consent wording. Many agents test both and keep the one with the lower cost per enrollment.