Consumers searching for health coverage online are being aggressively routed toward limited benefit products and away from ACA marketplace plans, according to a secret shopper study from Georgetown University published Aug. 13.
The study comes as marketplace enrollment has declined 12% nationally to 19.2 million enrollees following the expiration of enhanced premium tax credits at the end of 2025.
The researchers characterized current enforcement around misleading or fraudulent health plan marketing as a “whack-a-mole” approach, noting that previously sanctioned companies have reorganized under new names.
“Agents and brokers capitalized on health system upheaval and intense affordability challenges, reeling in consumers with promises of affordable and comprehensive coverage options as an alternative to the marketplace,” the researchers wrote.
Seven notes:
1. The researchers posed as two fictional consumers in West Virginia and fielded 20 sales calls over three days in May. One profile was 30 years old and subsidy-eligible, and the other was 55 with Type 2 diabetes and had an income just above the subsidy cliff. Researchers searched Google using four common terms like “cheap health insurance” and “ACA enroll,” entered each profile’s information into the top results, and took calls from the representatives who followed up.
2. Every single website that appeared in the search results was a lead generator, not an ACA marketplace, even though the sites had names implying official affiliation with state or federal exchanges and displayed logos of major insurers. Entering contact information triggered what researchers described as hundreds of solicitation calls and texts.
3. All but three of the 20 representatives pushed both consumer profiles toward non-ACA products, including the subsidy-eligible profile, who qualified for a $0 per month bronze plan and a $184 per month silver plan.
4. Representatives used a uniform framing that framed the ACA marketplace as a coverage option for sick people. They consistently referred to ACA plans as the “public market” and non-ACA products like fixed indemnity and short term plans as the “private market,” urging both profiles to avoid the marketplace if possible.
5. Marketplace options for the 55-year-old profile started at $1,000 per month for a catastrophic plan with a $9,000 to $10,000 deductible. Representatives used those price tags to steer her toward limited benefit plans that would likely exclude coverage for her diabetes.
6. Representatives described limited benefit products in terms that obscured how they actually work, such as fixed indemnity plans being pitched as having PPO networks, first-dollar coverage and no deductibles. Several representatives refused to provide written plan details until the consumer gave a credit card number.
7. The fine print of one fixed indemnity product included a 12-month waiting period for pre-existing conditions, which was not disclosed in any marketing material. Prescription drug benefits were also overstated, with one product’s brochure showing the plan would pay a flat $10 for generics and $40 for brand-name drugs, with total annual drug payments capped at $800.
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