Which federal and state programs use the 2026 FPL to determine eligibility and benefit amounts?
Executive summary
Federal poverty guidelines (FPL) are used widely to set eligibility and benefit levels for federal and state programs, including Medicaid/CHIP, ACA premium tax credits and cost-sharing reductions, Medicare Savings Programs and Low‑Income Subsidy for Part D, and many state health plans and programs such as Covered California and Get Covered Illinois [1] [2] [3] [4]. Federal agencies and state marketplaces report that the 2025 FPL numbers will generally be applied to determine eligibility for coverage and subsidies during the 2026 coverage year, while many states publish 2026 eligibility charts tied to those guidelines [5] [4] [3].
1. FPL is the administrative yardstick for federal health programs
The Department of Health and Human Services’ poverty guidelines are explicitly used to determine eligibility for Medicaid, CHIP, and Marketplace savings such as premium tax credits and cost‑sharing reductions; healthcare.gov and healthinsurance.org list those programs as primary users of the FPL measure [1] [2]. ASPE notes the guidelines are an administrative simplification used across federal programs and that many programs use percentage multiples (for example, 125% or 185% of the guideline) to set cutoffs [6].
2. Marketplace subsidies and the year‑lag timing
Multiple sources explain the timing: the FPL guidelines published in a given year are typically used to calculate eligibility for the following coverage year. Analysts and state marketplaces say 2025 FPL numbers will determine Marketplace subsidy eligibility for coverage in 2026, and states are reflecting those numbers in their 2026 eligibility charts [5] [4]. This creates predictable but sometimes confusing lagging rules for consumers shopping in the 2026 Open Enrollment period [5].
3. Medicare low‑income supports use the FPL too
Healthinsurance.org highlights that Medicare Savings Programs (MSPs) and the Low‑Income Subsidy for Medicare Part D rely on federal poverty guidelines to set income limits for assistance [2]. That places MSPs and Part D low‑income subsidies in the same FPL‑tied eligibility framework as Medicaid and Marketplace savings [2].
4. States adapt and publish local program rules tied to FPL
States publish program charts that map FPL percentages to state programs. Covered California’s 2026 materials show which income bands qualify for Medi‑Cal vs. subsidized Marketplace plans and note most consumers up to 138% FPL will be eligible for Medi‑Cal [4]. Get Covered Illinois explicitly says it will use the 2025 FPL guidelines to calculate savings for 2026 coverage [3]. Kentucky, Arkansas and other state resources publish QHP/APTC and child‑care or school program charts tied to FPL bands [7] [8] [9].
5. Non‑health programs also rely on the poverty guidelines
HHS/ASPE lists several non‑health federal programs that use the poverty guidelines or percentages of them — Head Start, SNAP, National School Lunch, Low‑Income Home Energy Assistance Program, and CHIP among others — though the exact percentage tests differ by program [6]. That demonstrates the FPL’s role beyond health care in federal benefit administration [6].
6. Important caveats and gaps in available reporting
Sources note important nuances that consumers and advocates must track: some programs use the guidelines directly while others use a percentage multiple; not all poverty measures are identical — ASPE warns the “poverty guidelines” are a simplified administrative tool distinct from Census poverty thresholds [6]; and the materials supplied emphasize that eligibility timing often lags (e.g., 2025 guidelines applied to 2026 coverage), which can change how incomes are compared for subsidy calculations [5] [4]. Available sources do not mention a comprehensive, single federal list that ties every program to the 2026 FPL specifically — states and individual program offices publish the applicable cutoffs themselves [6].
7. What to watch for consumers and policy watchers
Policy briefings and state marketplace notices advise consumers to compare household income to the published FPL charts for their state and the relevant program year: Covered California’s 2026 chart, Get Covered Illinois’ guidance, and federal guidance on MSPs and Part D subsidies are the practical sources for eligibility checks [4] [3] [2]. KFF’s open‑enrollment analysis also flags programmatic changes that interact with FPL rules — for example, eligibility shifts for some immigrant groups and the scheduled return of subsidy “cliffs” in 2026 that will change where FPL percentages matter most [10] [5].
Sources cited: healthinsurance.org (program list, Medicare savings/Part D) [2]; healthcare.gov glossary [1]; Covered California 2026 chart [4]; Get Covered Illinois FPL guidance [3]; ASPE poverty guidelines summary [6]; finance buff and other analysts on timing of 2025 vs 2026 guidelines [5]; KFF analysis of 2026 marketplace changes [10].