How do 2026 FPL levels affect eligibility for Medicaid and CHIP?
Executive summary
States and the federal Marketplace generally use the prior year’s Federal Poverty Level numbers to judge Medicaid and CHIP eligibility: for 2026 coverage most systems are using the 2025 FPL until HHS issues the 2026 guideline and states adopt it (states typically switch between February and April) [1]. In expansion states adults at about 138% of FPL qualify for Medicaid; children’s CHIP/Medicaid thresholds vary widely by state and can exceed 100–200% of FPL [2] [3].
1. How FPL numbers determine Medicaid and CHIP eligibility — the operational rule
Federal poverty guidelines are the income yardstick for Medicaid and CHIP eligibility decisions nationwide; the Marketplace checks Medicaid/CHIP first when someone applies [4]. For practical purposes, eligibility determinations use the “current year” FPL numbers in effect for the program year — but because HHS updates FPL annually and states take time to adopt changes, the FPL being applied for 2026 coverage is the 2025 guideline until states switch to the 2026 numbers (states typically update between February and April; some states switch earlier, e.g., Wisconsin on Feb. 1) [1].
2. What the key percentage cutoffs mean for adults and children
In states that expanded Medicaid under the Affordable Care Act, adults with household income at or below roughly 133% of FPL (effectively 138% after the standard 5% disregard used in MAGI rules) qualify for Medicaid based on income alone [2] [5]. Children’s eligibility bands are broader and set by states: federal rules require at least 133% for children but many states set higher CHIP/Medicaid thresholds (state tables show wide variation and some states cover children well above 200% FPL) [5] [3].
3. Timing quirks that affect people enrolling for 2026 coverage
If you apply for 2026 Marketplace coverage in late 2025, the Marketplace will compare your projected 2026 income to the 2025 FPL because the 2026 FPL has not yet been adopted in most systems [1]. States follow HHS updates at different speeds, which means the exact dollar cutoffs used for Medicaid/CHIP applications can change mid‑spring when states adopt the new guideline [1].
4. State-by-state variability and the hidden complexity
Medicaid and CHIP are joint federal‑state programs: while the FPL percentage framework is federal, states set specific income ceilings and apply MAGI rules, income disregards, and other criteria (citizenship, immigration status, household composition) differently [3] [5]. That produces stark differences — for example, in non‑expansion states many low‑income adults remain ineligible no matter how low their income, while children’s eligibility can be generous in some states [6] [3].
5. Practical implications for families and applicants
Because the Marketplace assesses Medicaid/CHIP first and uses the current FPL table in effect, people near common thresholds (100%, ~138%, 250%, 400%) should expect small calendar timing effects: whether you use 2025 or 2026 FPL numbers for a given application depends on when HHS published the guideline and when your state implements it [1] [7]. For planning, many consumer guides and calculators continue to apply the prior year’s FPL for the next year’s coverage cycle [7] [8].
6. Conflicting headlines and what to watch for in 2026
Some outlets emphasize the return of “traditional” 100%–400% subsidy bands for Marketplace tax credits in 2026 and note the special ARP/IRA changes that expired through 2025; these affect subsidy eligibility but do not change baseline Medicaid/CHIP FPL mechanics [7] [8]. Eligible thresholds for Medicaid expansion (about 138% FPL) remain the decisive line for adults in expansion states [2]. Readers should watch HHS’s January guideline release and state adoption dates for the clearest, binding dollar figures [1].
7. Limitations in current reporting and unanswered specifics
Available sources describe the timing rule (states using prior year’s FPL until they switch) and the main percentage thresholds, but they do not list the exact 2026 dollar figures or a state‑by‑state calendar for when each state will adopt the 2026 FPL — those specifics are “not found in current reporting” here and must be checked with HHS and individual state Medicaid agencies when the 2026 guideline is published [1] [3].
Bottom line: whether a given household qualifies for Medicaid or CHIP in 2026 depends on (a) whether your state expanded Medicaid, (b) your household MAGI relative to the FPL percentage threshold your state applies (commonly ~138% for expansion adults), and (c) which year’s FPL table — 2025 or the newly published 2026 guideline — the state is using at the time you apply [2] [1] [3].