What programs and benefits use a percentage of the 2025 FPL for eligibility, and what income cutoffs should applicants watch for?
Executive summary
Federal programs and benefits commonly set eligibility as a percentage of the 2025 Federal Poverty Level (FPL); key cutoffs applicants should watch are roughly 100% FPL (Medicaid/CHIP thresholds in many places), 138% FPL (Medicaid expansion benchmark used by some states), and 400% FPL (traditional ACA premium tax credit ceiling, though temporary policy changes affect that ceiling) [1] [2] [3]. The 2025 HHS poverty guideline for the 48 contiguous states is published and used by programs that explicitly tie their income tests to FPL percentages [4] [5].
1. Why the FPL matters now: the official yardstick agencies use
The Department of Health and Human Services issues poverty guidelines every January and those 2025 figures are the baseline many federal and state programs use to set income limits expressed as percentages of FPL (for example, “138% of FPL” or “400% of FPL”) [5] [4]. The technical guideline document explains programs vary in how they calculate income, round multiples, and define the household used for the test — so the raw FPL number alone does not give the full eligibility result for any specific benefit [4].
2. Medicaid and CHIP: watch the 100% and 138% markers
Medicaid and the Children’s Health Insurance Program (CHIP) use FPL-based cutoffs to determine eligibility. In many states, “income below 100% FPL” is a red line for some Medicaid pathways and “up to ~138% FPL” is often the expansion-related threshold for adults in states that expanded Medicaid [2] [1]. States set their own exact rules and rounding conventions; applicants must check state notices because some states apply different percentages for parents, children, pregnant people, or elderly/disabled applicants [4].
3. ACA premium tax credits and the 400% FPL boundary (and the policy caveat)
Historically, premium tax credits for Marketplace plans phased out at 400% of FPL; many consumer resources still cite that cutoff [1]. However, recent federal actions since 2021 changed that cliff into a more gradual slope and allowed credits above 400% FPL under certain affordability tests; reporting notes these changes are temporary and subject to future congressional action, so the practical 400% boundary may differ for 2025–2026 eligibility [3] [6]. Applicants should watch both the 400% number and any current guidance about the affordability test when estimating subsidy eligibility [3] [6].
4. Other programs and the many percentages used across benefits
Beyond Medicaid, CHIP, and Marketplace subsidies, a range of federal and state benefits reference the FPL or “poverty guidelines” as their income metric. The ASPE guidance and the HHS detailed tables make clear some programs use strict multiples while others — and states — choose different cutoffs; some programs list explicit percentages in their rules while others use alternative measures altogether [5] [4]. The result: applicants must look for program-specific language about which percentage of FPL applies and how household income is counted [4].
5. Dollar numbers to watch (how to translate percentages into incomes)
HHS publishes the 2025 poverty guidelines so those planning can translate a percentage to a dollar cutoff for their household size. The public summaries show the 2025 annual guideline for a single person in the contiguous U.S. (and separate numbers for Alaska and Hawaii), enabling applicants to calculate 100%, 138%, 400%, etc., for their household and compare to projected MAGI or counted income [4] [5]. Exact dollar cutoffs were published in HHS materials and in state charts like Covered California’s program eligibility tables that list the percent-of-FPL thresholds consumers should watch [4] [1].
6. Practical steps for applicants: don’t assume one-size-fits-all
Because programs differ in which incomes they count, their measurement period (monthly vs. annual), and whether they use the current or prior year’s FPL numbers, applicants must: identify the exact program and state rule; use the 2025 HHS poverty guideline table to compute the percentage cutoff for your household size; and check whether the program compares monthly or annual income or applies different rules for projected vs. past income [4] [2]. Covered California and federal glossaries reiterate these operational differences and list typical thresholds like 138% and 400% for health programs [1] [2].
Limitations: available sources outline which programs commonly use percentage-of-FPL tests and give the official 2025 guideline tables, but do not provide a comprehensive, single list of every federal or state program and its exact percentage cutoff; applicants should consult the specific program’s rules in their state for definitive cutoffs [4] [5].