Every fall, Medicare searches climb. In October 2025, Americans searched "medicare advantage plans" about 673,000 times, according to Google's Keyword Planner. Eight months later, in June 2026, the same search had fallen to about 165,000 a month.
An agency that sells Medicare plans can't simply turn its ads on when the wave arrives. Google requires a separate certification before it will run ads for Medicare Advantage or Medigap, and the process runs through an outside company that checks licenses state by state. An agency that starts in October is still waiting on approval while enrollment season opens.
This bonus chapter covers what Google requires, when to apply, and the federal Medicare marketing rules that shape the landing page and the phone call behind every ad.
Google Requires Certification for Medicare Advantage and Medigap Ads. Auto, Home and Life Ads Need None.
Google's health insurance policy is direct: "In the United States, you must be certified by Google in order to advertise health and medical insurance coverage." Its list of examples includes individual health insurance, short-term coverage, Medicare Advantage, Medigap and Medicaid.
A few lines sit outside the rule. Google says ads exclusively for dental, vision or travel health insurance aren't restricted. Agencies registered with the federal government to sell ACA marketplace plans need an additional certificate on top of the standard one to bid on ACA-related keywords.
We found no Google certification for auto, home, life or commercial insurance. That's why most of this guide never mentioned one. The catch is the Medicare page on a multi-line agency's site. Our reading is that an agency whose ads or landing pages promote Medicare plans falls under the health insurance policy, even if most of its business is auto and home. Chapter 10 recommended excluding Medicare pages from Performance Max for exactly that reason: an uncertified agency's campaigns shouldn't send traffic to them.
Certification Runs Through a Third-Party Checker First, and It Matches Your Licensed Legal Name, Not Your DBA.
Google doesn't check insurance licenses itself. Its policy page says health insurance advertisers in the US must first be certified with G2RS, an outside verification company, before applying to Google. Google's broader health policy adds that not all health insurance advertisers are eligible and that G2RS charges a fee for processing and monitoring.
G2RS's own page lists individual agents, brokers and agencies among the producers it certifies. Its pricing is a one-time application fee based on how many US jurisdictions you're licensed in, plus an annual subscription. The page doesn't publish the dollar amounts.
One detail trips up agencies that market under a trade name. G2RS says it no longer certifies DBAs, and that the accounts and domains you plan to advertise must clearly state your legal business name as it appears on your health insurance license. If the agency's site and Google Ads account use a brand name that isn't on the license, fix that before applying.
Agencies licensed in several states should expect a higher application fee, since G2RS prices it by the number of jurisdictions. Budget it once, then plan the annual renewal like any other license renewal.
If an outside firm manages the agency's ads, Google's page says it must send documentation of its relationship with the license holder along with the application.
The order, then:
- Confirm the legal name on the license matches the website and the Google Ads account.
- Apply to G2RS and pay its fees.
- Apply to Google for health insurance certification once G2RS approves.
- Only then build the Medicare campaign.
Searches for Medicare Advantage Plans Run Four Times Higher in October Than in June. An Uncertified Agency Misses the Peak.
The Medicare year has a fixed shape, and Keyword Planner shows it clearly. US searches for "medicare advantage plans" ran about 673,000 in October 2025 and about 165,000 in June 2026. "Medicare supplement plans" went from about 165,000 to about 74,000 over the same months.
The federal calendar explains it:
- October 1: Medicare Advantage organizations may begin marketing next year's plans.
- October 15 to December 7: the annual enrollment period, when people can choose or change plans for the coming year.
- January 1 to March 31: a second window when people already in Medicare Advantage can make a change.
In the ads we sampled, advertisers hadn't caught up yet. One week before the 2026 enrollment period opened, only 2 of 464 readable Search ads we pulled from the Ads Transparency Center mentioned Medicare. The pull date, before October 15, may explain part of that. Among the agencies and sites we checked, almost none were advertising Medicare yet.
G2RS says its turnaround is typically 14 calendar days or fewer. Google doesn't publish how long its own review takes, and an agency that finds a name mismatch halfway through has to fix its website and ad account before it can continue. So our rule is to start by summer. June or July leaves room for G2RS, Google's review, the landing page fixes below and a few weeks of low-cost testing before October.
CMS Requires the "We Do Not Offer Every Plan" Disclaimer on Medicare Websites. Three of Five Agency Pages We Checked Lacked It.
Google's certification gets the ads running. The federal Medicare rules decide what the ad and the page can say.
Agencies that market Medicare plans count as third-party marketing organizations under CMS rules, and those that sell for more than one Medicare Advantage organization must carry a disclaimer. When it doesn't sell every plan in the area, the required wording is: "We do not offer every plan available in your area. Currently we represent [insert number of organizations] organizations which offer [insert number of plans] products in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on all of your options."
The rules say where it goes. It must be "prominently displayed on TPMO websites" and included in "any marketing materials." In our sample of agency sites, five independent or Medicare agencies had Medicare pages. Two showed the disclaimer, only one with the organization and plan counts filled in, and three showed none. None of the five described a scope of appointment.
For the ad itself, our reading of the CMS definitions is that an ad mentioning premiums, benefits or "$0" counts as marketing, and a 90-character description can't hold the full disclaimer. Ads limited to something like "Talk to a licensed Medicare agent" are more defensible. Confirm the line with your carriers' compliance teams before launch.
Two more rules shape the copy:
- No "free" for a $0 premium. Chapter 13 covered the rule and how AI Max can trip it.
- No government look. Google's policy on government services can automatically label ads "Not a government website" when people appear to be searching for government services, and Texas requires Medicare ads to say they're "Not connected with or endorsed by the United States government or the federal Medicare program." Avoid "Apply for Medicare" wording, official-looking seals and the Medicare card image.
Every Medicare Sales Call From an Ad Has to Be Recorded and Kept Six Years. Set Up the Recording Before the First Ad Runs.
Medicare sales calls carry their own rules, and they are specific. CMS requires that "all marketing and sales calls" be recorded and kept "for a minimum period of 6 years," with the first three years kept as audio. The requirement used to be ten years; a 2026 rule cut it to six.
That matters for Google Ads in two ways. First, our reading is to treat every call from a Medicare ad or call asset as a sales call, so the agency's phone system should record it from the first ring. Second, Chapter 1 noted that Google leaves its own call recording off by default for businesses it treats as financial services. Plan the agency's recording on its own phone system or call tracker, with retention set to six years, before the first Medicare ad runs.
The call itself has a sequence. The disclaimer comes before any discussion of benefits. A scope of appointment, the beneficiary's agreement about which products the meeting will cover, has to be recorded before a personal marketing appointment. The rule that once required a 48-hour wait between the two was eliminated, effective June 1, 2026.
Forms carry their own rule. If a Medicare lead from your site will be shared with another agency or call center, CMS requires the beneficiary's prior express written consent, listing each company receiving the data. A federal court upheld that requirement in 2025.
Last, the data you send back to Google. Chapter 1 set up sending bound policies to Google so it can learn which clicks pay off. On the Medicare and health side, our reading is to send the sale by click ID only, with no health details in the conversion name or data. Google can learn that a click led to a policy without knowing anything about the person's health.
Next: Every State Farm Agent Ad We Found Ran on State Farm's or a Vendor's Account. The Carrier Writes the Rules.
Medicare's rules come from CMS and Google. Captive agents face another rulebook: their carrier's. Chapter 15 covers what we found about how captive agents' ads actually run. Earlier chapters cover tracking bound policies, AI Max and the word "free" and license-first settings. Every chapter is on the guide's home page.
Our Google Ads management handles certification and Medicare campaign setup for agencies. Doing it yourself? Check whether the name on your health insurance license matches the name on your website.
