WHAT IS THE INCOME LEVEL BEING USED FOR 2026 aca POVERTY LEVEL
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Executive summary
For 2026 ACA eligibility and employer affordability calculations, sources show (a) premium tax credit/subsidy eligibility will again be tied to the federal poverty level (FPL) bands (generally 100%–400% of FPL for Marketplace premium tax credits if temporary enhancements are not extended) and those 2026 decisions use the prior year’s poverty guidelines in some cases (coverage year 2026 often uses 2025 FPL guidelines) [1] [2] [3]. For employer affordability, the IRS set the 2026 affordability percentage at 9.96% of household income and the FPL safe-harbor converts that to about $129.89–$129.90 monthly for self-only coverage under 2026 rules [4] [5] [6].
1. What “FPL for 2026” actually means in practice
The phrase “2026 poverty level” is used in two related but distinct ways in recent guidance: Marketplace subsidy eligibility for coverage in 2026 generally references poverty guidelines published the prior year (so coverage year 2026 commonly relies on the 2025 HHS poverty guidelines), while program-specific materials (state program charts, enrollment tools) label the relevant thresholds for eligibility in 2026 as “2026 FPL” even when they mean the guidelines applied for that coverage year [2] [1] [7]. HealthCare.gov and multiple state resources explain that FPL is the baseline used to compute who qualifies for premium tax credits and Medicaid/CHIP thresholds [7] [8].
2. Who qualifies for Marketplace premium tax credits in 2026
Multiple trade and consumer sources report that, absent further Congressional action, the temporary subsidy enhancements that removed the 400% cutoff expired after 2025, so traditional eligibility — generally incomes between 100% and 400% of FPL — reappears for 2026 coverage [1] [3] [7]. In short: for most people, Marketplace premium tax credit eligibility in 2026 will be determined relative to the federal poverty line bands (100%–400% FPL) using the applicable poverty guideline year [1] [3].
3. Employer “affordability” number used for 2026 compliance
The IRS set the ACA employer affordability percentage for 2026 at 9.96% of an employee’s household income; employers can use one of three safe-harbors to test affordability because they typically do not know individual household incomes [5]. The Federal Poverty Line (FPL) safe-harbor for calendar-year 2026 plans equates that percentage to a monthly cap for self-only coverage of about $129.89–$129.90 (several employer-advice sources report $129.89 or $129.90) — if an employer’s lowest-cost, minimum-value self-only plan costs an employee no more than that monthly amount, the coverage is “affordable” under the FPL method [4] [6] [5].
4. Which poverty guideline numbers are actually used (timing and labels)
Authoritative guidance and reference charts note that eligibility for coverage year 2026 is based on the relevant poverty guidelines published for the prior or same year depending on program timing; several summaries explicitly say “eligibility for premium tax credits in coverage year 2026 is based on 2025 poverty guidelines” [2] [1]. Consumer-facing sites and state programs sometimes present the tables labeled as “2026 FPL” for convenience when discussing programs in calendar year 2026, which can create confusion over which HHS guideline year is applied [8] [9].
5. Practical effects consumers and employers should expect
For consumers: expect the return of the traditional 100%–400% FPL sliding scale for premium credits in 2026 unless Congress acts; that can make some middle-income people lose the expanded help they had through 2025 [1] [3]. For employers: check that employee-only contributions don’t exceed the FPL safe-harbor monthly cap (~$129.90) or use the wage- or rate-of-pay safe-harbors to test affordability since IRS guidance sets the 9.96% threshold for 2026 [5] [4].
Limitations, disagreements and what reporting doesn’t say
Sources are not entirely uniform about the exact dollar rounding ($129.89 vs. $129.90) but agree on the 9.96% figure and an FPL-based monthly cap near $129.9 for self-only coverage [4] [5] [6]. Available sources do not mention specific numeric 2026 HHS poverty guideline rows (e.g., the per-household-size dollar amounts used in some tables) within the search results provided here — several sites note that the 2025 guidelines are used for 2026 eligibility but do not print every household-size figure in these excerpts [2] [1]. Where state materials differ (e.g., Covered California citing 138% FPL for Medi‑Cal eligibility), those are program-specific thresholds that coexist with federal Marketplace rules [8].
Bottom line: use the 9.96% employer affordability rate and the FPL safe‑harbor monthly cap (~$129.9) for employer planning in 2026, and for Marketplace subsidy eligibility expect traditional 100%–400% FPL bands for 2026 coverage using the applicable prior-year poverty guidelines unless legislation changes that picture [5] [4] [1].