How are 2026 FPL percentages (100%, 138%, 150%, 200%, 250%, 400%) used to determine eligibility for Medicaid, CHIP, ACA subsidies, and SNAP?
Executive summary
In 2026 eligibility for major benefits ties to tiers of the federal poverty level (FPL): Medicaid expansion typically covers up to 138% FPL while ACA premium tax credits generally apply between 100%–400% FPL under current law (with the 400% cap scheduled to return in 2026 absent new legislation) [1] [2]. Cost‑sharing reduction (CSR) eligibility is limited to 100%–250% FPL and SNAP rules use a mix of federal minimums (net income ≤100% FPL) and state options that raise gross‑income screens up to 200% FPL via BBCE [3] [4] [5].
1. How the FPL scale is used to gate health coverage: Medicaid vs. Marketplace
Medicaid’s financial doorway depends on whether a state adopted the ACA expansion: in expansion states most nonelderly adults are eligible up to roughly 138% of FPL; in non‑expansion states the Medicaid floor remains much lower and many adults under 100% FPL may be uninsured or routed to limited programs [1] [6]. Covered California’s 2026 chart reiterates: “most consumers up to 138% FPL will be eligible for Medi‑Cal” illustrating how the 138% threshold functions as the practical Medicaid/marketplace dividing line in expansion states [6].
2. Premium tax credits (Marketplace subsidies): the 100%–400% band and the 2026 change
Under pre‑ARP ACA rules, the premium tax credit applied to households from 100% up to 400% of FPL; temporary enhancements removed or relaxed the 400% cap through 2025. Multiple policy trackers and calculators say the 400% limit is scheduled to return for coverage year 2026 unless Congress extends the ARPA/IRA enhancements — meaning typical eligibility in 2026 will again be roughly 100%–400% FPL for premium subsidies [3] [2] [7]. Analysts also flag that applicable percentages used to compute required household contributions (the formula that determines the subsidy size) will revert to higher levels in 2026, raising out‑of‑pocket premiums across the FPL distribution [4] [8].
3. Cost‑sharing reductions (CSRs): who gets lower deductibles and copays
CSRs — the extra help that lowers deductibles and co‑pays — are targeted by income, not by every Marketplace enrollee. Public guides and eligibility charts show CSR assistance is available to people who enroll in a Silver plan and have incomes roughly between 100% and 250% FPL; above that range CSR does not apply [3]. That creates a secondary cliff: two households with Marketplace subsidies can still face very different out‑of‑pocket costs depending on whether they are inside the 100%–250% CSR band [3].
4. SNAP uses FPL differently: net vs. gross tests and state flexibility
SNAP eligibility is structured around multiple screens: federal rules set gross‑income and net‑income tests (for most households gross income is tested at around 130% FPL and net income must be ≤100% FPL after deductions), but most states use Broad‑Based Categorical Eligibility (BBCE) to raise gross‑income eligibility to as high as 200% FPL for screening purposes [9] [5] [10]. State pages and SNAP guides show large variation — Florida, Washington, North Carolina and others use 200% FPL for gross income under BBCE while federal net tests and deductions remain decisive for final benefit amounts [10] [11] [12].
5. Practical interactions and “where the lines matter” for households
The key intersection: a household below 138% FPL in an expansion state is generally steered to Medicaid and excluded from Marketplace subsidies; a household above 138% but under 100% FPL (in non‑expansion states) may fall into a coverage gap [1] [7]. Households between 100%–400% FPL in 2026 are candidates for premium tax credits — but the return of the 400% cap and the reversion of applicable percentages means many who received large enhanced subsidies through 2021–2025 will see costs rise substantially without Congressional action [2] [13].
6. Where sources disagree or leave gaps
Official federal glossaries and state charts align on the broad thresholds (100%, 138%, 250%, 400%) but differ in emphasis and timing: healthinsurance.org and HealthCare.gov stress that Marketplace eligibility and Medicaid referrals use prior‑year guidelines for subsidy calculations and that states implement new FPL numbers on different timetables [14] [1]. Some private guides and calculators reiterate the traditional 100%–400% subsidy band for 2026 but note the ARPA enhancements’ sunset, a policy change rather than a data disagreement [3] [2]. Available sources do not mention any federal rule tying SNAP eligibility uniformly to the 150% or 250% FPL marks you listed; instead SNAP uses 100% net and various gross thresholds and state BBCE choices [5] [9].
7. Bottom line for readers deciding where to apply
If you’re under ~138% FPL in an expansion state, apply for Medicaid first; if you’re between ~100%–400% FPL expect Marketplace premium tax credit eligibility in 2026 under current law (but expect smaller subsidies than 2025 unless Congress acts) and CSR only if you’re ≤250% FPL and enroll in a Silver plan [1] [2] [3]. For food assistance, check your state’s BBCE and gross/net tests because many states raise SNAP gross‑income screens to around 200% FPL even though federal net limits still drive benefit size [5] [10].
Limitations: this summary synthesizes federal guidance, state charts and policy analyses from the provided sources; state‑level rules vary and the pending Congressional decisions about extending enhanced subsidies will change the 2026 landscape if enacted [15] [2].