If I have a bit and I do not know what the current value is, is it possible to use less energy than $E_b = k_b T \ln(2)$ so that if the bit value is already equal to what you want, you don't waste energy by setting it?
My guess is no: "observation/sampling" + "making a decision" would still involve a logic operation which would require the flipping of at least 1 bit.