Short answer: if you're an independent agent paid commissions on a 1099, the drives between your AEP appointments, seminars and other business stops are business miles, at 76¢ a mile for all of October 15 to December 7, 2026. The drive from home to your first stop and back home at night is the part that depends on your setup: it counts if your home office is your principal place of business, if you also have a regular office elsewhere, or if the stop is outside your metro area. Otherwise those two legs are commuting.
This page is for the independent Medicare agent on the night before the Annual Enrollment Period. Medicare.gov calls it Open Enrollment: October 15 to December 7, when people can join, drop or switch Medicare Advantage and drug plans. For the next eight weeks your calendar is kitchen-table appointments, library seminars, a senior-center table on Thursdays and the occasional drive two counties over for a client who moved. That's a lot of miles in a short season, and the season is the only time most agents think about them. Here's which ones count and what to write down while it's happening.
First: are you on a 1099 or a W-2?
Most agents who are appointed with several carriers through an upline (an FMO or IMO) are independent contractors. Commissions arrive on a 1099-NEC and you report them, and your expenses, on Schedule C. That's who this page is for.
Captive agents and call-center agents are often W-2 employees. If that's you, unreimbursed driving isn't deductible on your federal return, and the 2025 tax law made that permanent. Ask your employer for mileage reimbursement instead, and see which states still allow a deduction. If you're both (a W-2 job plus an independent book of business), keep the two kinds of driving apart in your log.
The leg that decides the number: home to the first stop
IRS Publication 463 treats the trip from home to where you work as commuting, which is never deductible. Driving from one business stop to another is deductible. Three rules from Publication 463 and Revenue Ruling 99-7 decide what happens to the first and last legs of an agent's day:
- Your home office is your principal place of business. Then daily trips between home and any other work location in the same business count. For an agent this usually means a room or a clearly separate space used regularly and only for the business, where you do the quoting, enrollments, carrier portal work and paperwork, and you have no other fixed location where you do that work. The test is in Publication 587. The dining table you also eat at doesn't qualify.
- You have a regular work location somewhere else, such as an agency office you work from most days. Then a drive from home straight to a temporary work location, like a client's home or a one-off seminar venue, counts regardless of distance.
- Neither. Then drives from home to temporary work sites inside your metropolitan area are commuting. A drive to a temporary site outside the metro area counts.
How your home office fares is the biggest swing in an agent's mileage, and it's a claim you have to be able to defend. The same mechanism is worked through for drivers in how a home office turns commuting into business miles.
One AEP Tuesday, three ways
An agent leaves home at 9:30 for a 10:00 educational seminar at the library (14 miles), drives to a kitchen-table appointment (9 miles), then to a second one (11 miles), then home (16 miles). That's 50 miles.
| The agent's setup | Business miles | At 76¢ |
|---|---|---|
| Home office is the principal place of business. Exclusive-use room, all admin done there, no other office. | All 50 | $38.00 |
| Works most days from the agency office, but went straight from home to the library that day. | All 50 | $38.00 |
| No qualifying home office, no regular office, all four stops in the same metro area. | 20 (library to client, client to client) | $15.20 |
Repeat that gap over eight weeks and it's real money. That's why the home-office question is worth settling with a preparer before AEP, not after.
The AEP drives agents forget to log
- Seminar setup. Scouting a venue, dropping flyers at a pharmacy or senior center, picking up the coffee and cookies for an event. Each is a business trip if you made it for the business.
- Return visits. Going back to drop off a document, help a client find their new card, or pick up a missing signature.
- Upline and carrier events. A carrier kickoff, an in-person training, a meeting at the FMO's office.
- Long-distance clients. The client who moved an hour away. Outside your metro area, even the drive from home counts.
- The post office. Mailing paper applications or carrier forms, when that's the reason for the trip.
What doesn't count: stopping for your own lunch, an errand bolted onto a business day (only the detour is personal; see what counts as a business mile), and the drive into the agency office on a day you just sit there.
What to write down, without writing down health information
Publication 463 wants the date, the destination, the business purpose and the miles, recorded at or near the time. Agents have one extra concern: your clients' plans, medications and doctors don't belong in a mileage log, especially one on your phone or in a notebook in the car. Your log doesn't need them. A purpose like this is enough:
- “Kitchen-table plan review, client 1043, SOA on file”
- “Educational seminar, Westside Library”
- “Return visit, client M.R., signature for application”
The details stay in your CRM or wherever your carriers and upline require you to keep them. The paperwork you already keep for compliance also backs up the log: CMS requires a written Scope of Appointment for an in-person marketing appointment, and that form, your calendar and the enrollment confirmation all show a real appointment on that date. Keep them; they're what makes a log believable if it's ever questioned. The fields themselves are in the five things every IRS mileage log needs.
Tip: if your upline or a carrier pays you a marketing allowance or reimburses event costs, find out how it's paid before you file. Miles you were reimbursed for under an arrangement where you accounted for them aren't deducted again. Money that just shows up in your 1099 income is reported as income, and your miles are deducted as usual. Your preparer can tell which you have.
Standard rate or actual expenses
Most agents use the standard mileage rate: 72.5¢ for business miles driven January 1 to June 30, 2026, and 76¢ from July 1, so the whole AEP season is at 76¢. It already covers gas, insurance, repairs and depreciation; parking and tolls on business trips are deducted on top. If this is the first year you're using this car for business, the choice matters more: using actual expenses with certain depreciation in year one can lock the car out of the standard rate later. That's covered in standard mileage vs actual expenses. Miles from January 1, 2027, including any in the Medicare Advantage Open Enrollment Period that follows, use the 2027 rate, which the IRS hasn't announced yet.
Our app: TaxMiles, the app this site is for, records drives in the background on iPhone, so a day of appointments shows up as separate drives you mark Business or Personal. Each trip has a Purpose field and a Client / Project field for a client number or initials. The free plan covers your first 40 business trips in total, which an agent with four or five stops a day uses up in the first couple of weeks of AEP. Pro is $59.99 a year or $7.99 a month; it adds PDF and CSV exports for your preparer, CarPlay, and splitting a drive that mixed business and an errand into two trips. What it doesn't do: decide whether your home office qualifies, or keep your Scopes of Appointment. A paper log in the glovebox with the same four fields works too, if you fill it in every day.
Who this doesn't fit
- W-2 and captive agents. No federal deduction for unreimbursed driving; ask for reimbursement. See above.
- Agents who mostly enroll by phone. If you rarely drive, this isn't where your deductions are. Your phone, internet and home office may matter more; see self-employed tax deductions.
- Anyone asking about CMS marketing rules. This page is about taxes. What you can and can't do at an event or appointment is set by CMS and your carriers' compliance rules, not by anything here.
Frequently asked questions
Can an independent Medicare agent deduct mileage to client appointments?
Yes, if you are self-employed and report your commissions on Schedule C. Drives between appointments, seminars and other business stops are business miles. The first drive from home and the last drive home are the ones that depend on your setup: they count if your home office is your principal place of business, if you also have a regular work location elsewhere, or if the stop is outside your metro area.
What mileage rate applies to AEP driving in 2026?
76 cents a mile. The IRS raised the 2026 business rate from 72.5 cents to 76 cents for miles driven from July 1 through December 31, 2026, so all of the October 15 to December 7 enrollment period falls under 76 cents. Miles driven from January 1, 2027 use the 2027 rate.
Should I put the client's name in my mileage log?
The log needs a business purpose, not health details. Initials or a client number plus the type of appointment, such as “Kitchen-table plan review, client 1043, SOA on file,” is enough to tie the trip to your records. Keep plans, medications and other health information in the systems your carriers and upline approve, not in a mileage app or a notebook in the car.
I'm a captive agent paid on a W-2. Can I deduct my AEP miles?
Not on your federal return. Unreimbursed employee expenses are not deductible for most employees, and the 2025 tax law made that permanent. Ask your employer about mileage reimbursement, and check whether your state still allows a deduction.
Log AEP as it happens, not in March
TaxMiles records each drive between appointments on its own, so you can mark it Business and add a client number the same evening.
Get TaxMilesRelated reading: mileage for real estate agents, another commission job with a home base and a lot of short hops; business miles vs commuting; and the 2026 mileage calculator, which splits miles at July 1 for you.
Sources: IRS Publication 463, Travel, Gift, and Car Expenses (Transportation: temporary work location, no regular place of work, two places of work, office in the home; recordkeeping); IRS Publication 587, Business Use of Your Home (principal place of business); Revenue Ruling 99-7 (daily transportation between home and temporary or regular work locations); IRS standard mileage rates (72.5¢ Jan. 1–June 30, 2026, IR-2025-128; 76¢ July 1–Dec. 31, 2026, IR-2026-29); Medicare.gov, Joining a plan (Open Enrollment October 15–December 7); 42 CFR §422.2264 (written Scope of Appointment for in-person marketing appointments). Checked October 14, 2026.
This article is general information for US taxpayers, not legal, tax, compliance or accounting advice. Whether your home office is your principal place of business, and how your upline's payments are treated, depend on your facts; ask a tax professional about yours. Follow your carriers' and CMS's rules on handling beneficiary information. TaxMiles is published by Gigabyte LLC, the company that wrote this page, and is not affiliated with the IRS, CMS, Medicare or any insurance carrier. Phone Diet, RecipeScan and Trending Music below are also our apps. Apple and iPhone are trademarks of Apple Inc., which doesn’t endorse this article.
