Medicare Data in the CO APCD
The Colorado All Payer Claims Database (CO APCD) contains over 1.3 billion claims, with more added every month. These claims are submitted by commercial health insurance plans, including Medicare Advantage, voluntarily submitted Employee Retirement Income Security Act (ERISA) and mandated non-ERISA self-insured employer plans, Medicaid, and Medicare Fee-for-Service (FFS). The CO APCD does not contain claims for people covered by Federal health insurance programs such as the Veterans Administration, TRICARE federal employees, or Indian Health Services, and does not include information for uninsured Coloradans.
The CO APCD holds information for over 70% of insured individuals in Colorado with medical coverage, representing over 5.6 million lives in total across all coverage types (medical, dental and pharmacy). As of this post, 33 commercial payers submitted claims in 2025 along with Medicaid and Medicare FFS.
This is the final installment of a series focusing on CO APCD data submitted by payer line of business – commercial health plans, Medicaid, and Medicare Advantage and Medicare FFS. The data in each line of business has different nuances that are helpful to be aware of when using the CO APCD.
Medicare Advantage vs. Medicare Fee-For-Service
When we talk about Medicare claims, it’s important to specify which type we are talking about. There are two types of Medicare coverage: Medicare FFS, or traditional Medicare, and Medicare Advantage, which can be purchased and is administered through commercial health plans. CIVHC is one of the few organizations that collects both Medicare FFS and Medicare Advantage claims and can release data on both types.
The difference comes in which services each plan covers. There are four central parts, or coverage types, for Medicare plans:
- Part A: Provides inpatient/hospital coverage
- Part B: Provides outpatient/medical coverage
- Part C: Also known as Medicare Advantage, the alternative way to receive coverage for Part A and Part B
- Part D: Prescription drug coverage
Under Medicare FFS, which is administered by the Centers for Medicare & Medicaid Services (CMS), parts A and B are included and beneficiaries have the option to join a separate program to receive part D coverage. There are also options to purchase supplemental Medicare FFS plans to cover care outside of regular FFS coverage. Medicare Advantage is considered a “bundled” plan, which includes parts A, B, and D and sometimes includes additional benefits such as vision, hearing, and dental coverage. Some of the common types of Medicare Advantage plans are Health Maintenance Organizations (HMOs), Preferred Provider Organizations (PPOs), and Private Fee-For-Service (PFFS).
The payment process between the plans is also different. While Medicare FFS is paid directly through the federal government, under Medicare Advantage, private plans contract with the government and receive payment for enrollments through CMS.
Medicare FFS Claims Collection in the CO APCD
CIVHC receives and releases Medicare FFS data via two separate mechanisms. CIVHC first began collecting Medicare FFS claims data in 2014 through the State Agency Request Program, which allows us to use de-identified Medicare FFS data for public and non-public analyses to serve the state in identifying trends and patterns in health care delivery.
In 2019, CIVHC became one of only a handful of nationally approved organizations to use Medicare FFS data through the Qualified Entity Certification Program. Under the program, CIVHC can release Medicare FFS data when combined with Medicaid and Commercial data to produce public reporting on provider performance, and is able to provide Change Agents with actionable data to improve quality of care. For more information on release rules around Medicare FFS data, visit our FAQ.
Medicare FFS Release Schedule Variation
Medicare FFS claims for medical and pharmacy are submitted on different schedules than the monthly frequency all other submitters follow. While commercial payers and Medicaid submit claims paid through as recently as two months ago, completion of Medicare claims lags by about a year. For example, in the recent November refresh of the CO APCD Data Warehouse, commercial and Medicaid claims were paid through August of 2025. However, medical claims under Medicaid were paid through September of 2024.
As a result, Medicare FFS claims are not available for the complete time period displayed in the CO APCD Insights dashboard and are currently only available in the dashboard through December 2023 for medical claims and December 2022 for pharmacy claims. Similarly, Medicare FFS eligibility records are available through December 2023 only.
Medicare FFS does not offer dental coverage and therefore it is not available as a coverage type for Medicare. It is also important to note that under Medicare FFS, commercial payers pay for Part D coverage, meaning the number of payers under Medicare FFS in the CO APCD appears higher. For more information about what’s currently available in the CO APCD (paid through dates), click here and download the “CO APCD Paid Through Dates” document under the Resources tab.
