How will 2026 FPL changes affect eligibility for pregnant people, children, and parents in each state?
Executive summary
Changes taking effect in 2026 will use the prior year’s poverty guidelines to judge Marketplace subsidy eligibility and most states will apply the 2025 FPL numbers for 2026 coverage decisions; premium tax credit eligibility for 2026 is compared to the 2025 poverty guidelines (coverage-year lag) and the enhanced ARP subsidies are ending, restoring a 100–400% FPL eligibility band for most Marketplace subsidies (with important state exceptions for Medicaid/CHIP) [1] [2] [3]. States set Medicaid/CHIP income cutoffs as percentages of FPL, so the new FPL figures and state policy shifts (including state-level rollbacks or immigrant eligibility changes) will change whether pregnant people, children and parents fall into Medicaid, CHIP or Marketplace subsidy cohorts in each jurisdiction [4] [5] [6].
1. How the 2026 FPL numbers determine who qualifies where — a rules-of-the-road primer
Eligibility for premium tax credits in coverage year 2026 is judged against the prior year’s poverty guidelines — meaning projected 2026 income is compared to the 2025 FPL figures — and states typically begin using the updated poverty numbers for Medicaid determinations between February and April [1] [2]. Federal guidance (ASPE) describes the poverty guidelines as the administrative baseline that many programs use but notes programs and states apply different percentage cutoffs on top of that baseline [4]. In short: the FPL numbers are the measuring stick; states and the Marketplace decide the thresholds that place a person into Medicaid/CHIP versus Marketplace subsidies [4] [1].
2. Pregnant people: protected floors but lots of state variation
Federal law requires that states offer at least a floor of pregnancy-related Medicaid benefits, and many states expand beyond that; pregnancy-related eligibility cutoffs vary by state and cannot be set below certain statutory minima (often in the ~133–185% FPL range depending on the category) [5]. Some states (for example, California) explicitly count unborn children in family size for determining pregnancy eligibility and are changing immigrant-related coverage rules in 2026 that will affect access for noncitizen pregnant adults [7]. Available sources do not provide a single national 2026 cutoff for pregnant people — the determining facts are the 2025 FPL numbers plus each state’s pregnancy Medicaid policy [5] [7].
3. Children: federal minimums plus state generosity
By federal requirement, states must cover children up to specified percentages of FPL (reporting here notes a baseline such as 154% FPL for some child coverage rules), but most states go well beyond that floor and set their own higher cutoffs for Medicaid/CHIP [8]. Because states implement eligibility as a percentage of the federal guideline, when the 2025 FPL numbers plug into 2026 determinations those percentage thresholds either expand or contract in dollar terms; in practice, most children up to about 138% FPL are eligible for Medicaid in many states, with higher cutoffs for CHIP or expanded Medicaid tiers in other states [6] [8].
4. Parents and adults: the Medicaid expansion split matters most
Whether a low‑income parent (or childless adult) gets Medicaid or must rely on Marketplace subsidies depends first on whether a state expanded Medicaid and what income-percentage it uses for parents. In expansion states, adults up to 138% FPL typically qualify for Medicaid; in non‑expansion states, Marketplace subsidies generally start at 100% FPL, leaving some low‑income adults in a coverage gap if state rules or immigration status bar them [1] [2]. The District of Columbia is an example of a jurisdiction that rolled back higher income cutoffs into the 133% FPL range effective Jan. 1, 2026, demonstrating how local policy changes can shift parents from Medicaid into Marketplace eligibility or out of coverage entirely [9].
5. Marketplace subsidy changes: ARP enhancements sunset, income cap returns
Enhanced Advance Premium Tax Credits (ARP-era increases) expanded subsidies beyond 400% FPL; those enhancements are set to expire, so in 2026 households above 400% FPL will generally lose Marketplace subsidies unless Congress acts [1] [3]. For households between 100% and 400% FPL, subsidies will remain but generally be smaller in 2026, increasing the chance that parents or pregnant people who fall into the Marketplace band will face higher premiums [3] [1].
6. Immigration status and other state policy pivots — a hidden determinant
State-level policy changes — for example California’s planned shift to restricted Medi‑Cal for some adults with unsatisfactory immigration status beginning January 1, 2026 — will change coverage pathways independent of income percentages: some pregnant noncitizens who previously received full‑scope benefits will face different rules in 2026 [7]. Likewise, state decisions to tighten income thresholds or reintroduce asset tests (reported for some states in secondary guides) will alter whether parents or childless adults land in Medicaid, CHIP, or the Marketplace [7] [10]. Available sources do not provide a complete state-by-state table for every population; determine an individual’s path by applying the 2025 FPL numbers to that state’s 2026 policy.
7. What an affected household should do now
Compare your projected 2026 household income to the 2025 FPL tables (the federal guideline applied for 2026 coverage) and then check your state’s published income cutoffs for pregnancy, children, and parent/caretaker categories because the same FPL dollar changes can place you into different programs depending on the state [1] [2] [6]. If you are near a threshold, monitor state notices (many states update in Feb–Apr) and Marketplace communications — and pay special attention to immigrant‑status rules that states are changing for 2026 [1] [7].
Limitations: this analysis uses federal guidance on how FPL is applied and sampled state notices in the reporting set; it does not list every state cutoff for 2026 because the provided sources do not contain a complete state-by-state eligibility table [4] [2].