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Did Eliminating “Meaningful Difference” Make a Meaningful Difference in Medicare Advantage Plan Offerings?
by Randy Herman


Product Design 3

Understand the Latest Medicare Advantage Policy Changes from the Centers for Medicare & Medicaid Services

Prior to 2019, Medicare Advantage (MA) organizations could submit bids for multiple plans in the same county under the same contract only if those plans were substantially different from one another. This limitation was known as the meaningful difference requirement.   

For Plan Year 2019 the meaningful difference requirement was eliminated. The CMS-stated goal of eliminating the meaningful difference requirement is “to improve competition, innovation, available benefit offerings, and provide beneficiaries with affordable plans that are tailored for their unique health care needs and financial situation. [1]

The elimination of this requirement opens the door for MA plans to create multiple “packages” of benefits that may be attractive to different segments of Medicare consumers – but have Medicare Advantage organizations taken advantage of this change? 

Deft analyzed the recently published Medicare Landscape Files to see if plan choices increased for beneficiaries.  The answer is YES.   

For this analysis we performed a “same store” analysis by treating each contract-county combination as a “store.” We compared the number of products (plans) offered in each store for 2019 versus 2018.  Finally, we ignored new entrants to the county (new “stores”) and contracts exiting the county (closed stores”).   We repeated this analysis for the 2017/2018 period for comparison purposes. 

This analysis showed the same store growth in products-per-store was 11.2% for 2019/2018, compared to only 1.2% growth for 2018/2017, which represents a ten-fold increase in the growth rate.

Did most MA organizations expand their offerings?  No, at least not yet. The following table shows the proportion of “stores” that increased the number of products sold, the proportion that decreased the number of products sold and the proportion who did not change their number of products offered.  

Proportion of Stores Changing Number of Products

All Plan Types Plans [2] 

Zero Dollar Plans [2] 



YoY Change 



YoY Change 

Increased Number of Products







Decreased Number of Products







No Change in Number of Products







While most stores did not change the number of products offered, the proportion of stores increasing the number of products was notably higher in 2019 (16.5% vs. 8.3%).  If we look specifically at the number of Zero Dollar Premium products offered, we see that there was a 378% increase in the proportion of stores expanding their Zero Dollar Premium offerings (from 2.9% in 2018 to 13.8% in 2019).

 All-in-all, the elimination of the meaningful difference requirement has prompted growth in the number of products offered.  Given the high percentage of plans that have not yet expanded their offerings, this growth is likely to continue into future plan years. 

Learn more about Deft Research’s Product Design Service. Deft has retooled the Product Design research method with the new Conjoint + MaxDiff solution that focuses on what members value in their health plan.Schedule a Discovery Call and tap into our resources. 

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[1] "Medicare Program; Contract Year 2019 Policy and Technical Changes to the Medicare Advantage, Medicare Cost Plan, Medicare Fee-for-Service, the Medicare Prescription Drug Benefit Programs, and the PACE Program," 83 Federal Register 73 (16 April 2018), pp. 16490. 

[2] MAPD plans excluding SNP, MMP, PACE, MSA and EGHP plans. 

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