How to Get ACA Leads: Sources, Timing, and Consent Rules

ACA leads come from three places: inquiries you generate yourself, HealthCare.gov's Find Local Help listing and CMS's Help On Demand referral system, and leads you buy (real-time, aged, or live transfer) from vendors whose consent records name you. Work them hardest during Open Enrollment, which runs November 1 to January 15 for 2027 coverage, and all year through Special Enrollment Periods.

A lead is only worth something if you can legally contact the person and legally help them enroll. This guide covers where leads come from, when to work them, the consent rules for calling and texting, and the separate Marketplace consent you need before you start an application.

Key takeaways

• The main ACA lead sources are your own inbound marketing, Find Local Help and Help On Demand, and purchased leads. Buy leads only in states where you hold a valid license.
• Finish Marketplace registration and training, and enter your individual NPN correctly, before you help anyone enroll through the Marketplace. A wrong NPN can cost you compensation.
• Open Enrollment for 2027 coverage runs November 1 to January 15. Enroll by December 15 for coverage that starts January 1.
• Outside Open Enrollment, a person needs a Special Enrollment Period. Most life-event windows are 60 days, and losing Medicaid or CHIP may qualify within 90 days.
• The FCC's one-to-one consent rule never took effect. If you're required to use the National Do Not Call Registry, sync with an updated version at least every 31 days, and CTIA's industry guidelines say not to text from opt-in lists that were rented, sold, or shared.
• Permission to call isn't Marketplace consent. If you enroll through HealthCare.gov (the Federally-facilitated Exchange), document consent and application review under 45 CFR 155.220(j) and keep both for at least 10 years. If your state runs its own Marketplace, check with that Exchange for its agent rules.

Where do licensed agents get ACA marketplace leads?

Leads you generate yourself

Self-generated leads give you control over consent, which is their biggest advantage. Here's what that looks like in practice:

• A website form that asks, in plain words, for permission for you, by name, to call and text the number entered
• Being known locally through community events, local partners, and a local phone number
• Asking current clients for referrals, then letting the referred person contact you

CTIA tells senders to build and vet their own opt-in lists rather than use lists that were rented, sold, or shared. Our client retention and referrals playbook covers how to ask for referrals. If you use LeadGPT, your Profile Page also lists you on the MeetBrokers.com agent directory.

Should you buy ACA leads or generate your own?

You don't have to choose one. Purchased leads can add volume during Open Enrollment, but the quality of their consent varies by vendor. Your own leads take longer to build, and the consent records are yours. If you buy, vet every vendor using the questions later in this guide.

What do you need before an ACA lead is worth anything?

A license in each lead's state

HHS may immediately terminate an agent's FFE agreement for cause if the agent doesn't keep a valid state license in every state where they actively help consumers enroll in QHPs or apply for APTC or CSRs through the FFE (45 CFR 155.220(g)(3)(ii)). Set state filters with every vendor, and buy leads only in states where you're licensed.

Marketplace registration and training

Under 45 CFR 155.220(d), an agent who enrolls people through the Exchange must register with the Exchange before assisting, receive training, and comply with the Exchange's privacy and security standards. CMS's plan year 2026 guide for new agents lists the steps below. These are CMS's plan year 2026 steps for new agents registering with the Federally-facilitated Marketplace (FFM). If your state runs its own Marketplace, check with that Exchange for its registration steps. Returning agents and plan year 2027 registration may differ, so check CMS's current registration page.

1. Create a CMS Enterprise Portal account.
2. Request the FFM Agent Broker role.
3. Complete identity proofing.
4. Complete your MLMS profile.
5. Complete training through the MLMS or an HHS-approved vendor.
6. Sign the Marketplace Agreements.
7. Confirm your registration status and print your certificate.

For plan year 2027 steps, see our FFM registration guide.

Your NPN, entered correctly

CMS warns that entering an inaccurate individual NPN, or copying it into the business fields, may lead issuers to deny compensation or credit for an enrollment. After you register, it can take 1 to 2 business days to appear on the Registration Completion List (RCL). If your NPN isn't on the RCL, CMS says to email FFMProducer-AssisterHelpDesk@cms.hhs.gov.

Carrier requirements

Ask each carrier or your upline what they require before you can write their plans and get paid. Do that before you spend money on leads.

How do you get listed on Find Local Help and join Help On Demand?

CMS says the information in your MLMS profile populates both Find Local Help and Help On Demand. Once you finish registering, it can take up to 3 business days for you to appear on Find Local Help. Check your profile details carefully, because consumers use them to decide whether to contact you.

Help On Demand is a CMS-contracted referral system that connects consumers with Marketplace-registered, state-licensed agents in their area. Only agents who have completed Marketplace training and registration can participate. Check the CMS page for how to opt in.

As advice, treat these referrals like your hottest leads. Someone who asked for help is often comparing options, so call back right away and keep your availability up to date in Open Enrollment.

When is Open Enrollment for 2027 coverage?

These dates come from HealthCare.gov. Some broker pages show different dates, so use HealthCare.gov's. If your state runs its own Marketplace, check that Exchange's dates.

As advice, schedule appointments for the plan preview period and work December 15 as your main deadline. Our ACA Open Enrollment preparation guide covers the rest of your setup.

How do you find ACA clients after Open Enrollment?

Special Enrollment Periods keep leads coming in all year. HealthCare.gov lists these triggers on its Special Enrollment Periods page:

Applicants may have to submit documents confirming the loss of coverage. Tell them early so a missing letter doesn't hold up coverage.

As advice, build off-season lead sources around these events: referral partners who see people losing coverage, past inquiries who expected a job change, and clients' family members turning 26.

Can you call and text ACA leads?

Yes, if you have the consent each rule requires and you honor every opt-out. Several rule sets apply at once.

Is the FCC one-to-one consent rule still in effect?

No. The FCC's revised one-to-one consent rule never took effect. The Eleventh Circuit vacated it, the court's mandate issued April 30, 2025, and an FCC order effective August 29, 2025 restored the prior version of 47 CFR 64.1200(f)(9). Pages that describe one-to-one consent as current law are out of date.

What prior express written consent requires

Under the reinstated rule, prior express written consent is a signed written agreement authorizing the seller to deliver telemarketing using an autodialer or an artificial or prerecorded voice to a specified number. It must clearly and conspicuously disclose that signing authorizes the seller to deliver telemarketing calls using an autodialer or an artificial or prerecorded voice, and that signing isn't a condition of purchase. Electronic signatures count where they're valid under law. Ask your compliance team how this applies to your dialer and your texting.

Do Not Call scrubbing and established business relationships

The FTC's DNC Q&A explains these Telemarketing Sales Rule requirements:

• If you're required to use the registry, sync your call lists with an updated version at least every 31 days.
• An inquiry or application creates an established business relationship that lets the company call for three months. A purchase or transaction allows calls for up to 18 months.
• Either way, honor any request not to be called. Keep your own do-not-call list so every request sticks.
• Written permission to call a registered number must be the consumer's express written agreement to receive calls from or on behalf of a specific seller, including the number and the consumer's signature.
• Sellers can't place prerecorded calls to consumers whose information came from third parties.
• Every seller needs its own registry subscription and Subscription Account Number. A telemarketer can't buy the list and share it with clients who haven't paid. There's no fee for five or fewer area codes.

The FTC's DNC Q&A explains that violations can bring civil penalties for each call. Check the FTC page for the current maximum.

Texting standards from CTIA

CTIA treats texts from an agent acting for a business as Non-Consumer messaging. Senders are expected to get consent for messages, get express written consent for marketing texts, and let consumers revoke consent. CTIA says an opt-in should not be transferred or assigned, and that it applies only to the sender and campaign it was collected for.

Record each opt-in's timestamp, how consent was collected, the language shown, the campaign, the IP address, the phone number, and who consented. Honor STOP, END, UNSUBSCRIBE, CANCEL, and QUIT, send one confirmation, and send nothing after that. Ask your texting provider how it handles carrier registration for business texting. For wording ideas, see our follow-up text templates.

Does TCPA consent cover a Marketplace application?

No. Permission to call or text a lead is one thing. Permission to help with their Marketplace application is a separate requirement under 45 CFR 155.220. The requirements below apply when you help with enrollment through the Federally-facilitated Exchange (HealthCare.gov) or with APTC/CSR applications for plans sold there. If your state runs its own Marketplace, check with that Exchange for its rules.

• Consent before you assist (155.220(j)(2)(iii)). Before you help with FFE enrollment or an APTC/CSR application, get and document the consumer's consent. The consumer must take an action that produces a record, and the record must state the scope, purpose, and duration of the consent, the date, the consumer's name, and your name or your agency's.
• Application review before you submit (155.220(j)(2)(ii)). Document that the consumer reviewed the eligibility application and confirmed it's accurate. Include the date reviewed, the consumer's name, an explanation of the attestations, and your name.
• Retention. Keep both records for at least 10 years.
• Starting with plan years beginning on or after January 1, 2028, consent must come from the consumer taking an action to execute an HHS-approved and HHS-created consent form. A typed signature or filled-in check box alone won't show proper consent.

A vendor's contact-consent form usually won't contain these elements or name you for enrollment help, so don't rely on it as Marketplace consent. Our ACA consent documentation guide covers each record in detail.

How do you vet an ACA lead vendor?

Ask these questions before you buy (advice):

• Does the consent language name me or my agency as the seller, and show the phone number and the consumer's signature or e-signature?
• Can you send proof of consent for any lead: timestamp, the exact language shown, the page, the IP address?
• Is the lead exclusive to me, or sold to other agents? If shared, how many, and are we each named?
• Can you filter by state so I only get leads where I'm licensed?
• Is it real-time or aged, and what's the original inquiry date?
• Are numbers scrubbed against the DNC Registry, and when? (Scrub them yourself as well, under your own subscription.)
• For live transfers, how did the caller agree to be connected to me?
• What's your return policy for bad numbers, out-of-state leads, or missing consent?

If a vendor can't show you consent that names you, don't buy.

How should you work a new ACA lead?

1. Check before you dial. Confirm the state, the consent record, and the DNC status.
2. Contact fast. Inquiries cool quickly. Our speed to lead playbook covers a first-five-minutes routine.
3. Identify yourself and confirm permission. Use your name, your agency, and the reason for the call.
4. Qualify for Open Enrollment or an SEP. Find the qualifying event and its date.
5. Collect Marketplace consent before you assist, and document the application review before you submit.
6. Log the call and next step, including any opt-out request.
7. Follow up during the calling hours your compliance team approves, and stop the moment someone opts out.

A first-call script you can adapt:

"Hi, this is [name], a licensed health insurance agent with [agency]. You asked about Marketplace coverage on [date/source], and I'm calling about that. Is now still a good time? Great. If you'd ever like me to stop calling or texting, just tell me. First, which state and county do you live in? Are you looking for coverage during Open Enrollment, or has something changed recently, like losing coverage, moving, or a new baby? What date did that happen? Before I help with any application, I'll ask you to give consent in a way that creates a record, and we'll review the application together before anything is submitted."

Be accurate and complete on every call. 45 CFR 155.220(j)(2)(i) requires agents to give consumers correct information without leaving out material facts, and to avoid misleading, coercive, or discriminatory conduct.

Common mistakes with ACA leads

• Treating a vendor's consent form as Marketplace consent under 155.220(j).
• Calling numbers that weren't scrubbed against the DNC Registry in the last 31 days.
• Texting purchased or shared opt-in lists.
• Working leads in states where you aren't licensed.
• Entering the wrong NPN, or your individual NPN in the business fields.
• Quoting Open Enrollment dates from a broker page instead of HealthCare.gov.
• Telling a client who dropped COBRA voluntarily that they qualify for an SEP.

Where LeadGPT fits

LeadGPT's CSV import maps a vendor file's columns to lead fields, including your own custom fields for consent date and vendor. When a lead texts STOP, LeadGPT blocks every text to that number from every part of the app and sets the lead to Dead, and Drip Campaigns stop as soon as a lead texts back. The Profile Page request form includes a consent checkbox that names you. LeadGPT doesn't handle consent for you, so confirm your process with your compliance team. See the features overview or the interactive demo.

What to do next

1. Confirm your licenses, registration, and NPN are on the RCL before November 1.
2. Review your MLMS profile for Find Local Help and Help On Demand.
3. Rewrite your own web form consent so it names you, and send the vendor checklist to every vendor.
4. Set up a 31-day DNC scrub and an internal do-not-call list.
5. If you enroll through HealthCare.gov (the Federally-facilitated Exchange), build your consent and application review records under 45 CFR 155.220(j) and keep them for at least 10 years. If your state runs its own Marketplace, check that Exchange's rules.

This guide is general information, not legal or compliance advice. Confirm each rule with CMS, the FCC and FTC, your state insurance department, your carriers or upline, and your compliance team. You'll find more guides in our insurance sales and compliance categories, and our editorial policy explains how we research them.