The best current national benchmark is KFF’s 2024 estimate of $29.79 per member per month for small-group coverage and $10 for large-group coverage. Those figures are not broker commission rates: KFF combines agent and broker fees and commissions with direct-sales salaries and benefits, then divides the expenses by covered member months.
What the published numbers measure
KFF’s U.S. Broker Fees and Direct Sales by Health Insurance Market tool reports these 2024 amounts:
| Market segment | 2024 compensation expense per member per month | What is included |
|---|---|---|
| Small group | $29.79 | Agent and broker fees and commissions, plus direct-sales salaries and benefits |
| Large group | $10 | Agent and broker fees and commissions, plus direct-sales salaries and benefits |
PMPM means “per member per month.” KFF divides the reported compensation expenses by member months, which accounts for covered enrollment over time. The result is a combined distribution-expense measure—not a per-employer invoice or a fee paid by each member.
KFF excludes plans with negative values in relevant reported fields or member months, and insurers classified as Property. Medical-focused mini-med companies are included. These choices define the reported dataset, so the figures should not be treated as a complete accounting of every insurer or distribution arrangement.
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Why the figures are not a broker commission rate
The headline values combine two categories: agent and broker fees and commissions, and the salaries and benefits of direct-sales staff. The latter are carrier employees, not brokers. The NAIC’s 2021 Supplemental Health Care Exhibit report lists direct-sales salaries and benefits separately from agents’ and brokers’ fees and commissions under general and administrative expenses, underscoring that they are distinct cost categories even when a headline measure combines them.
The measure also uses dollars per member per month, not a percentage of premium. Converting between the two requires premium and enrollment data for the same market, year, and population. A PMPM value alone cannot establish what share of a group’s premium went to a broker.
Nor does a national average establish what a particular carrier pays, what an employer’s broker earns, or what services a broker provides. Brokers may help employers select plans, manage enrollment, and administer benefits; carriers may also rely on direct sales. The available figures do not assign a dollar value to those services, brokerage operating costs, or producer productivity.
How broker and direct-sales channels differ
In a plain-language description, the U.S. Bureau of Labor Statistics says that “Agents represent one or more companies to the consumer seeking coverage, while brokers represent consumers seeking coverage.” BLS’s industry description is a useful distinction, though legal definitions and duties can vary by jurisdiction and context.
Direct sales are another channel: an insurer’s employees sell or support coverage without an outside agent or broker receiving the compensation counted in the agent-and-broker category. KFF’s combined measure counts direct-sales salaries and benefits alongside agent and broker compensation, which is why it describes distribution expenses more broadly than broker costs alone.
What the small- and large-group comparison can—and cannot—show
In KFF’s 2024 data, the reported small-group PMPM amount is higher than the large-group amount. That is a descriptive difference, not evidence of its cause. Possible factors to investigate include channel mix, member-month scale, state market structure, and compensation arrangements; KFF’s summary does not identify how much any one factor contributes.
KFF’s state-level figures also vary. State variation is a reason to examine local market composition and conditions, not proof that one specific feature explains the difference. Neither a state figure nor a national average should be used to infer a particular employer’s broker compensation or service quality.
Why older percentage estimates are not directly comparable
A 2011 KFF analysis reported that broker compensation averaged 5% of premiums in small-group markets, noted variation among states, and said initial-sale commissions were generally higher than renewal commissions. That historical percentage is not a current estimate, and it is not directly comparable to KFF’s 2024 PMPM figure: the measures use different units and are from different years. See KFF’s 2011 analysis.
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1Fix the driver behind crashes, sound loss and screen glitches2Repair Windows errors before they cause bigger problems3Scan for outdated or missing drivers - takes under a minuteDistribution expense is only one part of benefit costs
Health benefits are a much broader employer expense than broker or sales compensation. The U.S. Bureau of Labor Statistics reported that health care represented 8.1% of total compensation for civilian workers in March 2026. That is benefit-cost context, not an estimate of distribution expense or broker pay. BLS’s medical-care premiums fact sheet covers that measure.
Why compensation design can raise consumer-protection concerns
Compensation can affect which plans or consumers agents and brokers are encouraged to pursue. CMS’s December 16, 2016 guidance states that an issuer’s commission arrangement or other agent/broker compensation can constitute a prohibited discriminatory marketing practice when it is structured to discourage marketing to or enrolling consumers with significant health needs, citing 45 CFR 147.104(e) and 156.225(b). Read the CMS guidance for its scope. This is not a blanket prohibition on commissions; the concern described is an arrangement that discourages enrollment of people with significant health needs.
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