Chapter13On a sunny fall afternoon, a silver-haired woman at her curbside mailbox holds a thick stack of glossy Medicare mailers, the top one reading $0 PREMIUM PLANS, while two more slip toward the lawn
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Google Ads for Insurance Agencies · Chapter 13 of 16 · All chapters

Medicare Rules Bar Calling a $0 Premium "Free." AI Max Writes From Your Site and Can Add That Word to an Ad.

CMS bars calling a $0 Medicare premium free, and AI Max writes ads from your site. Here's why agencies turn it on last, with 25 banned words in place.

David SmaniaFounder, BrandRocket9 min read · October 9, 2026

Picture an agency's Medicare page that says "$0 premium plans available." Google could read that page and write a headline from it. "Free Medicare Plans Near You" is 28 characters, fits in a headline, and is the kind of shortcut a machine can take. The rules Medicare sets for its private plans bar them from saying it.

That's the risk in AI Max, Google's newest layer of automation for Search campaigns. It matches searches you didn't choose and writes ads you didn't write, using your website as its source.

Below: the three things AI Max switches on at once, why an agency account saves it for the very end, and the banned words and written rules that keep a generated insurance ad from saying what CMS or a state forbids.

Chapter 13 of 16

CMS Bars Medicare Advantage Plans From Calling a $0 Premium "Free," and the Agents Who Sell Them Answer to the Same Rule.

Medicare's marketing rules list things a Medicare Advantage organization may not do. One of them, in 42 CFR 422.2262, reads: "Use the term 'free' to describe a $0 premium, any type of reduction in premium, reduction in deductibles or cost sharing..." The clause goes on to cover low-income subsidies and cost sharing for people eligible for both Medicare and Medicaid.

That rule is written for the plans. Agents are bound through them. The next section of the same rules says plans "must oversee" the agents and brokers who sell for them "to ensure agents and brokers abide by all applicable State and Federal laws, regulations, and requirements." Another part of the same section makes the plan responsible for making sure the marketing organizations selling for it follow the rules that apply to the plan. That puts the carrier on the hook for what its agents advertise.

Agency websites often carry the raw material for that mistake. Of the five independent and Medicare agencies in our sample with Medicare pages, one advertised "-0- premium, -0- copays, -0- deductibles." That's accurate language for some plans. It's also the kind of line a writing tool can turn into "free."

Captive agents have one more reviewer. Texas requires an agent to file any ad that names an insurer with that insurer's home office for written approval before use, and the insurance department in North Carolina tells agents to submit advertising to their appointed companies first. The same department adds that many agents' carrier contracts require it. A headline Google writes on its own, at auction time, never passes through that approval. For a captive agent, that alone can be a reason to keep text customization off for good, whatever the guardrails.

Medicare isn't the only line with a word problem. Chapter 9 covered the states that restrict "free" and "no cost" in insurance ads, mostly for life and health: Texas, Florida, Ohio and New York. An agency selling those lines has more than one rulebook watching its headlines.

"Free" is a five-letter word a machine can add to any headline. For a Medicare ad, it's the one word the rules spell out by name.

AI Max Is Broad Match With a Copywriter Attached. It Matches Searches You Didn't Pick and Writes Headlines From Your Pages.

AI Max bundles three features into one campaign setting:

Put together, AI Max is broad match with a copywriter attached. Every control this guide built so far, exact keywords in Chapter 6, headlines from reviews in Chapter 8, a page for every line in Chapter 4, is loosened at once.

And as Chapter 9 showed, Google switches it on by default when you build a new Search campaign. An agency that clicks through setup without looking has AI Max running from the first day.

AI Max Learns From Conversions. An Agency Account Turns It On Last, After Exact Match, Broad Match and Performance Max.

Google's own setup page is clear about what AI Max needs. Its matching, writing and page-picking features, Google says, only work properly when the campaign bids on conversions through Smart Bidding. A second page is blunter about budget: AI Max won't be effective if the campaign is limited by budget.

A new agency account has neither. It starts on manual bids in Isolation, the exact-match campaign, precisely because it has no conversion history. Turning on a feature that writes ads and widens matching, in an account with nothing to learn from, gives Google the widest possible room with the least possible guidance.

So AI Max sits at the very end of our order:

AI Max needs what an exact-match launch campaign doesn't have yet: months of conversions and room in the budget.

Twenty-Five Excluded Terms and Forty Rules Narrow What AI Max Can Write in an Insurance Ad.

When an agency is ready to test AI Max, Google offers a set of controls called text guidelines. Google labels them an experimental beta with some limitations, so treat them as a filter that narrows what AI Max writes, not a guarantee. Text guidelines do nothing unless text customization is switched on, since they only govern what Google writes. There are two:

One limit is worth knowing before you write the list. Google's own page warns that excluding the "$" sign won't stop generated text from quoting prices; it points to a messaging restriction such as "Don't generate assets with prices" instead, and suggests adding an example to each restriction. For an agency, that might read "Avoid mention of any premiums, e.g. $0 or $45 a month."

A starter set for an insurance agency:

Then fix the source. Read your own line pages the way a machine would, looking for any phrase that could be shortened into a forbidden claim: a "$0" a machine might shorten to "free," a "saved our clients thousands" it might turn into a savings figure, a strip of carrier logos it might read as a comparison. Rewrite those lines in plain terms before AI Max ever sees them. Text customization reads your site, so the cleanest guardrail is a Medicare page that never says "free" or treats "$0" as the selling point in the first place. And keep the "we do not offer every plan" disclaimer on every Medicare page, since CMS requires it of agents who sell for several carriers; Chapter 14 covers where it has to appear.

AI Max Doesn't Get an Agency's Budget on Day One. It Runs as an Experiment Against the Campaign Already Writing Policies.

Google builds experiments into AI Max, so an agency doesn't have to switch a working campaign over and hope. Run AI Max as an experiment against the campaign as it is, and compare them on the number that matters: bound policies sent back to Google by the route Chapter 1 laid out, not clicks or quote requests.

Give the experiment long enough to collect bound policies on both sides. In our experience that means weeks, not days, because a quote request can take a while to turn into a signed policy. While the experiment runs, read three reports:

The experiment keeps the old campaign as the yardstick. If AI Max can't beat what's already binding policies, it doesn't get the budget.

A generated headline that converts well but breaks a rule is still a broken headline. Remove it, add the word or claim that caused it to the guardrails, and note it for the next campaign. The guardrail list should grow the same way Chapter 5's negative keyword list does, one bad example at a time.

If AI Max wins, roll it out one campaign at a time, with its guardrails copied over. If it doesn't, turn it off and leave the exact and broad match campaigns doing what they already do well.

Next: Google Won't Run a Medicare Ad From an Agency It Hasn't Certified. Get Certified Before Enrollment Season.

Medicare ads have one more gate before any of this applies: Google's own certification for health insurance advertisers. Chapter 14 covers it. Earlier chapters cover license-first settings, Performance Max and headlines from reviews. Every chapter is on the guide's home page.

Our Google Ads management tests AI Max for agencies with guardrails in place. Doing it yourself? Open your newest Search campaign's settings and check whether AI Max is on.

Google Ads for Insurance Agencies

Carriers Can Outbid You on Every Search. Customers Still Review the Agent, Not the Carrier.

We've run paid ads for 25+ years and seen just about every way a budget goes sideways. Get on the phone with someone who does this every day. Bring your questions, your numbers and your skepticism. You'll hang up knowing what we'd do, whether you hire us or not.

David Smania · Founder, BrandRocket

25+ years running paid media for small businesses, and a low tolerance for agency theater.

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