How are FPL percentages (100%, 133%, 138%, 200%, 250%, 400%) used to determine eligibility for federal programs in 2026?
Executive summary
Federal programs and ACA rules use specific percentages of the Federal Poverty Level (FPL) to gate who gets Medicaid, Marketplace premium tax credits, cost‑sharing reductions, and employer “affordability” safe harbors; commonly used thresholds include 100%, 138% (Medicaid expansion), 250% (CSR eligibility), and 400% (premium tax credit cutoff that was reinstated to 100–400% for 2026 absent further law) [1] [2]. For employer coverage affordability in 2026, the IRS set the FPL‑based affordability percentage at 9.96%, producing an FPL safe‑harbor monthly dollar test of roughly $129.89 for self‑only coverage using the 2025 FPL base used in early 2026 determinations [3] [4].
1. How FPL percentages function as eligibility cutoffs
Federal and state programs do not use the raw FPL number alone; they compare household modified adjusted gross income (MAGI) or countable income to percentage multiples of the HHS poverty guidelines. For example, many Medicaid expansion programs use 138% of the FPL as the eligibility threshold for adults in expansion states, while other programs (SNAP, Head Start, LIHEAP, CHIP and various state programs) adopt different percentage cutoffs tied to administrative rules [5] [6]. Covered California’s 2026 chart explicitly maps program buckets to FPL percentages — noting Medi‑Cal eligibility up to 138% and that consumers above 400% FPL are not eligible for federal premium tax credits under standard rules [2].
2. Marketplace subsidies, CSRs and the familiar 100–400% range
Marketplace premium tax credits historically applied to households with incomes between 100% and 400% of FPL. Several consumer‑facing guides and calculators show the practical buckets: 100% (poverty), 138% (Medicaid expansion), 250% (cost‑sharing reduction tiers) and 400% (premium credit cliff) — and they note that special, temporary policy expansions that removed the 400% cliff expired after 2025 unless Congress extended them, meaning “traditional 100%–400% eligibility applies for 2026” absent new legislation [1] [7]. Covered California’s materials reiterate that enhanced Silver plans and zero/limited cost sharing options are tied to income bands below those thresholds [2].
3. Cost‑sharing reductions (CSRs) and the 250% anchor
CSRs — which lower deductibles and out‑of‑pocket costs for Marketplace enrollees — are calibrated to income bands beneath 250% of FPL (with specific CSR plan levels like Silver 94, 87, 73 referenced in California guidance). Thus an enrollee’s eligibility for CSRs depends on where their MAGI falls relative to the 250% FPL marker [2] [7]. State materials and consumer guides show these bands are operational levers insurers and exchanges use to assign plan metal‑level subsidies.
4. Employer affordability safe harbor tied to an FPL percent (9.96% in 2026)
For the ACA employer mandate, employers may use an FPL‑based “safe harbor” test: coverage is affordable if employee‑only premium cost does not exceed a percentage of the FPL. For plan years beginning in 2026 the IRS set that percentage at 9.96%, which — when applied to the FPL figure — translates to a monthly self‑only affordability safe‑harbor threshold of about $129.89 using the FPL figure in play (and employers offering a plan at or under that amount meet the affordability test under the FPL safe harbor) [3] [8] [4]. Non‑calendar plan years may use the FPL published in the six months before the plan year start, so timing matters for which FPL table is applied [4].
5. Why multiple percentages (100, 138, 133/138, 200, 250, 400) appear in guidance
Different programs and legal provisions reference different multiples: 100% is the poverty baseline for many program rules; 138% is the statutory Medicaid expansion cutoff; 133% vs. 138% sometimes appears in statutory language vs. practical MAGI conversion and temporary administrative fixes (reporting notes that 133% vs 138% distinctions were effectively indistinguishable through 2025 but would matter again in 2026 if laws weren’t extended) [7]. Percentages like 200% or 250% are used by specific programs or CSR tiers. The ASPE poverty‑guideline documentation explains this is deliberate: guidelines are simplified thresholds used administratively and agencies pick percentage multiples for program rules [5].
6. Limits, timing and what the sources do not say
Available sources document the role of these percentiles for healthcare subsidies, employer safe harbors, and many social programs, and they show 2026 policy changes for affordability percentages [3] [4] [2]. Available sources do not mention precise 2026 dollar values for every FPL percentage band for every household size in this packet of results — consumers must consult the HHS/ASPE FPL table and program‑specific state guidance to compute exact cutoffs [5] [2]. Also, whether Congress will change the 100–400% framing or extend temporary subsidy enhancements is not covered in these documents [1] [7].
7. What to do if you need an exact eligibility answer
Check the current HHS/ASPE poverty guidelines for the relevant year and household size, then multiply by the program’s percentage cutoff (100%, 138%, 250%, 400% etc.) as shown in Covered California and ASPE materials; for employer affordability questions use the 9.96% 2026 percentage and the safe‑harbor monthly formula described by IRS guidance and industry explainers [5] [3] [4]. If you need state‑level Medicaid or program rules, use your state exchange or Medicaid office’s FPL chart because states set some thresholds differently [2] [6].