Medicare beneficiaries face many choices when entering the program and during the annual open enrollment period. They can elect to enroll in the traditional Medicare program, dozens of Medicare Advantage (MA) and Prescription Drug Plans, or 10 standardized Medigap supplemental coverage plans. Research suggests that beneficiaries struggle to make decisions when faced with so many choices, and that many Medicare enrollees cannot determine which coverage options would minimize their costs. Many beneficiaries, therefore, seek assistance from health insurance agents, brokers, and other resources when evaluating their options. However, previous research has indicated that the marketing and enrollment efforts of the growing MA sales industry may steer beneficiaries into MA even when other options may better meet their needs.

Why This Matters

MA enrollment has grown rapidly over the past decade, from 31 percent of Medicare enrollment in 2014 to 54 percent in 2024. This growth was fueled by MA overpayment that often led to heavy investment in marketing. A recent report from Senate Finance Committee Ranking Member Ron Wyden found that MA insurers spent a combined $6.9 billion on agent and broker commissions in 2023, up from $2.4 billion in 2018, suggesting rapid growth in the MA sales industry. In 2024 and 2025, however, newspaper articles and data tracking suggest that MA margins have tightened, leading some insurers to stop offering commissions altogether for some plans or to exit markets in some states. Nevertheless, the size of incentives for agents and brokers remains a matter of concern, and MA plans continue to have strong incentives to compete for MA enrollment through investments in sales and marketing strategies that may not serve beneficiaries or taxpayers well.

How We Did It

To explore how agents and brokers may influence Medicare enrollment and identify any gaps in oversight of agents, brokers, and marketers, we conducted a literature review and interviewed 19 representatives from agent and broker trade associations, field marketing organizations, agencies and brokerages, state departments of insurance, health plan associations, beneficiary advocacy organizations, and the Centers for Medicare & Medicaid Services (CMS).

What We Found

• Beneficiaries struggle to make Medicare enrollment decisions, and our interviewees said that the educational and decision support resources provided by CMS are inadequate to meet beneficiaries’ needs.
• Agents and brokers are an important resource for beneficiaries, but their financial incentives are sometimes misaligned with the needs of the beneficiaries they serve.
  • CMS sets maximum commissions in the MA market, and these have grown rapidly in recent years and appear higher than commissions in other insurance markets.
  • CMS does not have the authority to regulate other administrative fees that may be paid to agents, brokers, and other sales organizations, limiting its ability to create a level playing field among MA plans or between MA and traditional Medicare products.
  • MA commissions and fees paid to agents, brokers, and other sales organizations add to the program’s administrative costs and may not only steer beneficiaries into MA, but also encourage more spending on buying Medicare sales leads.
• Despite growing concerns about MA sales and marketing practices, the regulatory environment for agents, brokers, marketing organizations, and lead generators is patchy.
  • Interviewees said that direct regulation and oversight of agents, brokers, marketing organizations, and lead generators is limited and complicated by state and federal overlaps.
  • Interviewees expressed significant concerns that organizations that generate sales leads for agents and brokers may engage in misleading marketing and overwhelm beneficiaries with many phone calls.
• The MA sales industry, fueled by Medicare overpayment and years of high insurer profit margins in MA, spends billions of taxpayer dollars annually and continues to grow as MA enrollment increases, though this growth has shown signs of slowing in 2025. MA’s overall marketing and enrollment costs may represent a significant, understudied target for reducing MA overspending.

Our interviews and literature review suggest several areas of payment and benefit policy that can be addressed to improve Medicare sustainability, reduce taxpayer burdens, and help beneficiaries navigate Medicare enrollment, including simplifying and strengthening Medicare, tying agent and broker commission increases to inflation and benchmarking them to other insurance markets, reining in MA overpayment, increasing funding for neutral enrollment assistance, and improving transparency, oversight, and enforcement.