The Apples to Apples Comparison Act of 2025 directs the Secretary of Health and Human Services to publish, in machine‑readable form on the CMS public website, monthly Medicare expenditure totals and averages broken down by county and Metropolitan Statistical Area and by a long list of beneficiary categories. The statutory change requires CMS to start annual publication processes in 2025 and to include historical enrollment back to 2015 in the first year’s output.
The bill also requires the Medicare Payment Advisory Commission (MedPAC) to produce an annual retrospective comparison of average expenditures for Medicare Advantage enrollees versus comparable fee‑for‑service (FFS) beneficiaries (starting 2026), with specified data, methodology disclosure, and public comment steps. Finally, the law directs the Medicare trustees to include disaggregated expenditure information in their annual trust reports.
The package increases transparency for researchers and policymakers but raises operational, privacy, and methodological questions for CMS, contractors, and plans.
At a Glance
What It Does
The bill amends Social Security Act section 1874 to require CMS to publish monthly total and average Medicare expenditures by county and MSA in machine‑readable files, broken out across many enrollment and coverage categories, with an initial requirement to backfill data to 2015 for the 2025 publication. It also directs MedPAC to publish annual retrospective MA vs. FFS expenditure analyses and requires trustees to include disaggregated expenditure data in their reports.
Who It Affects
Primary obligations fall on HHS/CMS (data production, publication, and IT), MedPAC and the trustees (additional analytic and reporting tasks), Medicare Advantage plans and other payers (subject to public comparison), and researchers/state/local planners who will use the new granular data.
Why It Matters
This is a statutory push for granular, reproducible Medicare spending transparency intended to enable direct geographic and enrollment‑type comparisons between MA and FFS. The data requirements create new sources for policy analysis but also force choices about risk adjustment, cell suppression, and methodology that will shape public interpretation.
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What This Bill Actually Does
The core of the bill inserts a new public‑reporting duty into section 1874 of the Social Security Act. Starting in 2025, CMS must publish, in machine‑readable files on its public website and within a fixed post‑year window, monthly totals and averages of Medicare expenditures for beneficiaries who live in each county and each Metropolitan Statistical Area.
The publication must slice spending by a comprehensive set of beneficiary categories—combinations of Part A entitlement, Part B enrollment, Part D enrollment, Medicare Advantage enrollment and plan types, enrollment in federal health programs or group plans, and whether beneficiaries have supplemental coverage.
The statute sets two time‑dimension rules: a specified historical period equal to the 10 years ending on the reporting year’s last day, and a specified projected period that the Secretary may set up to five years into the future. For the first 2025 report, CMS must include enrollment information going back to 2015 and produce county/MSA‑level historical breakdowns.
CMS must publish the files promptly — the bill requires submission within 30 days after the end of each reporting year (beginning 2025) for the information described.Separately, the bill instructs MedPAC to add an annual retrospective analysis (starting with MedPAC’s 2026 report) comparing average expenditures for beneficiaries enrolled in Medicare Advantage plans with average expenditures for comparable Part A/Part B FFS beneficiaries who were eligible but not enrolled in MA. The law specifies data sources MedPAC must use (including the Chief Actuary and trustees), says analyses should account for benefit differences and demographic differences, requires that HCC risk score differences be considered but instructs MedPAC not to adjust for favorable selection into MA, and imposes process requirements: publish methodology 60 days before submission, allow at least 30 days for public comment, respond to comments, and make data available in a reproducible form while protecting personal confidentiality.Finally, the bill amends the trustees’ reporting duties so that the Boards of Trustees for the HI and SMI Trust Funds include aggregate and average expenditures in their annual trust reports (beginning 2026) for three high‑level beneficiary categories and, where practicable, disaggregate public tables using the categories above.
Together those changes create multiple, statutory publication streams intended to produce reproducible, county‑level and program‑level spending comparisons between MA and FFS for researchers, policymakers, and the public.
The Five Things You Need to Know
CMS must publish monthly total and average Medicare expenditures by county and Metropolitan Statistical Area in machine‑readable files, with the first such publication beginning in 2025 and annual publications thereafter.
The 2025 CMS publication must include enrollment information for prior years beginning in 2015, and the statute defines a ‘specified historical period’ as the 10 years ending on the report year’s last day.
MedPAC is required to produce an annual retrospective analysis (starting 2026) comparing average expenditures for Medicare Advantage enrollees versus comparable Part A/Part B FFS beneficiaries, using data from the Chief Actuary and trustees and accounting for benefit and demographic differences.
MedPAC must publish its analysis methodology at least 60 days before submission, allow a minimum 30‑day public comment period, respond to comments, and make underlying data public in a way that permits replication while protecting individual confidentiality.
The Medicare trustees must include aggregate and average expenditures by three beneficiary categories in their annual trust reports beginning in 2026 and, to the extent practicable, disaggregate published expenditure tables according to the bill’s categories.
Section-by-Section Breakdown
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Require public, machine‑readable publication and geographic disaggregation
This amendment forces CMS to move from internal reporting to public publication: the statutory report language is changed so that beginning with 2025 CMS must publish the report on its public website in machine‑readable format and provide the data by county and MSA. Practically, that converts a paper/administrative reporting obligation into an IT and transparency obligation — CMS must operationalize automated exports, define file schemas, and manage release schedules. The provision also adds a special rule that the 2025 publication must include enrollment breakdowns for prior years (back to 2015), creating a one‑time backfill requirement.
Granular monthly expenditure files and beneficiary category breakdowns
Subsection (h) is the bill’s data blueprint. It requires CMS, within 30 days after each reporting year (beginning 2025), to publish monthly total and average spending for items and services furnished to beneficiaries residing in each county and MSA, broken into a long enumerated list of mutually overlapping beneficiary categories (Part A only, Part B only, Part A+B, Part D enrollment status, MA enrollment and plan types, enrollment in federal programs or group plans, etc.). The statute also establishes the time framing rules: a ‘‘specified historical period’’ (10 years) and a ‘‘specified projected period’’ (an HHS‑set window up to 5 years). Implementers will need to reconcile residence assignment, attribution of spending to months, and mapping beneficiaries into the many listed categories.
Mandatory annual MA vs. FFS expenditure comparison with process rules
This addition obligates MedPAC to include, in its annual report beginning with the 2026 report, a retrospective analysis comparing average Medicare expenditures for MA enrollees versus comparable FFS beneficiaries. The statute prescribes data sources (Chief Actuary, trustees, and other data MedPAC finds appropriate), requires adjustment considerations (benefit differences, demographics, HCC risk scores) and explicitly bars adjusting for favorable selection into MA. The section creates procedural guardrails: public release of methodology 60 days ahead of submission, at least 30 days for comment, public responses to comments, and publication of underlying data in replication‑ready format while protecting confidentiality. That sequence is designed to harden the analysis against methodological surprise and to allow external replication.
Trustees must include disaggregated expenditure information in trust reports
The bill directs the Boards of Trustees for the HI and SMI Trust Funds to include aggregate and average expenditure information for three high‑level beneficiary groups (Part A only, Part B only, Part A+B non‑MA) in their annual trust reports beginning in 2026, and to disaggregate public expenditure tables by the bill’s categories to the extent practicable. This provision embeds expenditure transparency into the fiduciary trust reporting process and creates another public avenue for spending comparisons, which will likely require coordination between trustees’ teams and CMS statisticians.
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Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Health policy researchers and academics — Gain reproducible, county/MSA‑level monthly spending files and the underlying data and methodology MedPAC must publish, enabling independent analyses of geographic variation and MA vs. FFS comparisons.
- State and local health planners — Can use county/MSA breakdowns to align resource planning and identify local patterns in Medicare spending and supplemental coverage penetration.
- Congress and federal policymakers — Receive statutory analytic products (MedPAC analyses and trustee disaggregations) that make it easier to evaluate MA payments and national spending trends with standardized inputs and methods.
- Consumer and beneficiary advocates — Obtain clearer public evidence on how spending differs across plan types and geographies, which can inform litigation, advocacy, and enrollment guidance.
Who Bears the Cost
- CMS and HHS — Face substantial IT, personnel, and contractual costs to compile, validate, de‑identify, and publish monthly machine‑readable county/MSA files and to backfill historical data to 2015 for the 2025 publication.
- MedPAC and the trustees — Must expand analytic capacity, manage public comment processes, and prepare replication datasets, increasing workload and potential need for additional funding or contractor support.
- Medicare Advantage plans and supplemental insurers — Will be subject to greater public scrutiny and comparative analyses, which may trigger commercial responses, regulatory inquiries, or pricing pressure.
- Data vendors and contractors — May need to modify existing data feeds, build new aggregation pipelines, and implement suppression/sanitization methods; smaller contractors may struggle with the technical requirements.
Key Issues
The Core Tension
The bill forces a trade‑off between transparency and analytic integrity: releasing highly granular, county‑level monthly spending data improves accountability and research potential but increases privacy risks and hinges on methodological choices (risk adjustment, benefit valuation, suppression rules) that materially shape cross‑plan comparisons; deciding how to make MA and FFS ‘apples to apples’ requires judgments that can prove as consequential as the data themselves.
The bill prioritizes transparency but leaves key implementation choices to CMS, MedPAC, and the trustees. The statute enumerates beneficiary categories at a granular level but does not prescribe data suppression thresholds or de‑identification techniques; CMS must balance release utility against HIPAA and statistical disclosure risks.
County‑level monthly reporting raises small‑cell disclosure concerns in low‑population areas or for narrowly defined beneficiary categories, creating a trade‑off between geographic precision and confidentiality that the statute does not resolve.
Comparing MA and FFS expenditures is analytically fraught. The bill instructs MedPAC to account for HCC risk score differences but to exclude adjustments for favorable selection, and to consider benefit design differences (out‑of‑pocket caps, supplemental coverage, integrated Part D).
Those choices affect conclusions dramatically: including or excluding certain value elements or selection adjustments can flip whether MA appears more or less costly than FFS. The requirement to publish methodology and data for replication mitigates disputes but also exposes MedPAC and data providers to challenges about data quality, coding variation (e.g., MA diagnosis coding intensity), and attribution rules (residence vs. service location).
Finally, operational realities — namely the cost and time needed to standardize multi‑source data, validate place‑of‑residence assignments, and support public replication requests — could delay or limit the granularity actually published without additional appropriations or contractor capacity.
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