Apples to Apples Comparison Act of 2025
- Sponsor
- Rep. Bean, Aaron [R-FL-4]
- Committees
- Energy and Commerce Committee (primary)
- Last action
- Sep 16, 2026
Bottom line
The bill significantly increases transparency and public access to detailed Medicare expenditure and enrollment data, aiming to facilitate comparative analysis between different Medicare program components and beneficiary groups.
What it actually does
This bill mandates the Secretary of Health and Human Services to publish extensive, granular Medicare expenditure and enrollment information on the Centers for Medicare & Medicaid Services (CMS) public website, broken down by county, Metropolitan Statistical Area, and over 30 categories of beneficiaries. It also requires the Medicare Payment Advisory Commission (MedPAC) and the Boards of Trustees of the Medicare Trust Funds to conduct and publish specific analyses comparing Medicare Advantage (MA) and traditional fee-for-service (FFS) expenditures, with detailed methodological considerations and public comment requirements.
Proponents argue
Proponents argue this bill will enhance transparency in Medicare spending, allowing policymakers, researchers, and the public to better understand cost drivers, evaluate program efficiency, and compare expenditures between Medicare Advantage and traditional fee-for-service plans. This increased data availability will foster accountability and inform future legislative and administrative reforms to optimize Medicare's financial sustainability and value.
Opponents contend
Opponents might raise concerns about the significant administrative burden and cost associated with collecting, processing, and publishing such granular data, especially given the extensive historical and projected data requirements. There could also be arguments that the vast amount of data might be misinterpreted without proper context, potentially leading to misleading conclusions about program performance or beneficiary choices.
The bill is concise and its core provisions are clearly stated, making it accessible for an informed reader to understand its main objectives and mechanisms within a reasonable timeframe.
Section 2, amending Section 1874(g) of the Social Security Act
Enhanced Public Reporting of Medicare Enrollment Data
This provision requires the Secretary of Health and Human Services, starting in 2025, to publish annual reports and machine-readable files on the CMS public website containing Medicare enrollment information. This data must be broken down by State, and beginning in 2025, further disaggregated by county and Metropolitan Statistical Area (MSA). Additionally, the reports must include enrollment data for each category of individuals described in the new subsection (h)(1), providing a comprehensive view of beneficiary demographics.
Supporters argue
Supporters argue that making granular enrollment data publicly available will enhance transparency, allowing for better understanding of Medicare's reach and demographic shifts, which is crucial for effective program management and future policy planning.
Critics contend
Critics might contend that the extensive data collection and publication requirements impose an undue administrative burden on CMS, potentially diverting resources from other critical functions without a clear demonstration of proportional benefit.
Tradeoffs
The provision balances the desire for increased public transparency and data availability against the administrative costs and resource allocation required for CMS to fulfill these new mandates.
Section 2, adding new subsection 1874(h) to the Social Security Act
Public Publication of Detailed Medicare Expenditure Information
This section mandates the Secretary of Health and Human Services to publish, starting in 2025, total and average Medicare expenditures for items and services. This data must be broken down by county and Metropolitan Statistical Area, for each month within a 10-year historical period and a projected 5-year period. Crucially, the expenditures must be categorized across 30+ distinct groups of individuals based on their Medicare enrollment status (e.g., Part A only, Part B only, Part A+B, with/without Part D, with/without other health coverage, MA plans, etc.), providing an unprecedented level of detail.
Section 3, amending Section 1805(b) of the Social Security Act
MedPAC Analysis of Medicare Advantage vs. Fee-for-Service Expenditures
This provision requires the Medicare Payment Advisory Commission (MedPAC), starting with its 2026 report, to conduct and publish a retrospective analysis comparing average expenditures for individuals enrolled in Medicare Advantage (MA) plans versus those in traditional fee-for-service (FFS) Medicare who are eligible for MA but not enrolled. The analysis must consider differences in value (e.g., out-of-pocket caps, supplemental benefits) and demographics, and specifically account for HCC risk scores but *not* for favorable selection differences. MedPAC must also make all data and methodology public, allowing for public comment on the methodology.
Section 4, adding new subsection 1874(i) to the Social Security Act
Trustees' Report of Disaggregated Expenditure Information
This provision requires the Boards of Trustees of the Federal Hospital Insurance Trust Fund and the Federal Supplementary Medical Insurance Trust Fund, starting with their 2026 annual reports, to include aggregate and average expenditure information for specific categories of Medicare beneficiaries. These categories include individuals entitled to Part A only, enrolled in Part B only, and those entitled to Part A and enrolled in Part B but not in a Medicare Advantage plan. Furthermore, the Trustees must disaggregate all their public expenditure data, to the extent practicable, based on these same beneficiary categories.
When MedPAC conducts its analysis comparing Medicare Advantage and fee-for-service expenditures, it is explicitly instructed to 'not take into account any favorable selection differences with respect to enrollment in such plans.'
Section 3(B)(ii)(III), amending Section 1805(b) of the Social Security Act
Why it matters:The inclusion of this specific exclusion is a policy choice that could significantly impact the perceived fairness and outcome of the MedPAC analysis. While technically a methodological instruction, its placement might be seen as an attempt to de-emphasize a potentially controversial aspect of MA plan enrollment dynamics.
Case for: Proponents of this exclusion argue that it ensures the comparison focuses purely on the costs of care delivery and benefits provided, rather than being skewed by the characteristics of the populations that choose different plans. This allows for a more direct 'apples to apples' comparison of program efficiency, as intended by the bill's title.
Case against: Critics, particularly those supportive of Medicare Advantage, might argue that ignoring favorable selection (where healthier individuals disproportionately enroll in MA plans) fundamentally distorts the comparison. They contend that favorable selection is a real-world dynamic that contributes to MA plans' lower costs and should be accounted for to provide a complete and accurate picture of program performance.
Estimated impact: This methodological constraint could significantly influence the reported cost differences between Medicare Advantage and traditional fee-for-service, potentially leading to findings that portray MA plans as more or less costly than they would appear if favorable selection were considered.