How do 2026 poverty guidelines affect Medicaid and CHIP income eligibility?
Executive summary
The 2026 federal poverty guidelines determine the income thresholds states use to decide Medicaid and CHIP eligibility, but most states will continue using the 2025 FPL numbers for early‑2026 eligibility actions until they adopt the new guideline year (states typically switch Feb–Apr) [1]. Medicaid adult expansion eligibility is effectively 138% of the FPL in expansion states (the 133% statutory floor plus a 5% MAGI disregard) and CHIP requires states to cap eligibility at the higher of 200% FPL or Medicaid’s 1997 upper level — while states set many child thresholds above those floors [1] [2].
1. How FPL numbers feed into Medicaid and CHIP rules
Medicaid and CHIP use the Federal Poverty Level as the primary yardstick for income eligibility. Federal law and CMS guidance tie many MAGI‑based coverage groups to specific percentages of the FPL, so when HHS updates the poverty guideline numbers each year, those dollar thresholds shift and states must reapply their percentage limits to the new FPL figures [3] [4].
2. Why you’ll often still see “2025” numbers in early 2026
HHS usually issues new poverty guidelines in January, but states stagger adoption: many don’t start using the new numbers for Medicaid/CHIP determinations until February–April. As a result, eligibility and Marketplace rule‑of‑thumbs for early 2026 frequently rely on the 2025 FPL numbers until states formally switch [1] [5].
3. What 138% of FPL means for adults in expansion states
In states that adopted Medicaid expansion, the practical adult income cutoff is 138% of the FPL. That figure arises from a 133% statutory threshold combined with a 5% MAGI income disregard — the effect is that adults with income up to roughly 138% of the FPL qualify for Medicaid in expansion states [1] [3].
4. How CHIP’s floor and state flexibility work
CHIP’s federal rule sets a minimum ceiling: eligibility must be at least the greater of 200% of the FPL or “50 percentage points above the Medicaid applicable income level” that existed in 1997. Within that framework, states choose their actual child income cutoffs and many set higher limits — KFF and CMS data show state variation with limits ranging widely, in some places above 300–400% of FPL for certain child programs [2] [6] [7].
5. Practical effects for families when guidelines change
When HHS raises the FPL dollar amounts, the same percentage‑of‑FPL cutoff buys a higher dollar eligibility limit — potentially making more families qualify in dollar terms even if percentages are unchanged. Conversely, if a state’s policy fixes eligibility in dollar amounts rather than as a percent of FPL, an HHS update won’t automatically change who qualifies. Many states, however, tie limits to the FPL percentage, so annual updates matter [4] [3]. Available sources do not mention whether any specific state in 2026 has frozen dollar limits instead of using percent‑based rules.
6. State variation and the order of determination
States determine Medicaid eligibility first and then CHIP, sometimes applying a 5% FPL “disregard” when moving from Medicaid to CHIP calculations; Mississippi’s materials illustrate that eligibility is checked for Medicaid first, then CHIP, with that disregard applied in practice [8]. CMS’s exhibit guidance and state tables further show that child eligibility levels and pregnant‑women thresholds vary by state [9] [6].
7. Where to look for your state’s 2026 thresholds
Authoritative, state‑specific income cutoff tables are maintained by CMS and KFF and mirrored on state Medicaid websites; these sources list the applicable percent‑of‑FPL thresholds for parents, children, pregnant women and adults and are the right place to check whether a state has adopted the 2026 FPL figures yet [6] [7]. Consumer guides also note that HealthCare.gov and state portals use the current FPL numbers to determine eligibility [4] [1].
8. Competing perspectives and limits of this reporting
Federal guidance describes the mechanistic link between FPL updates and eligibility [3], while consumer‑facing sites emphasize timing and practical examples of dollar thresholds in use [10] [1]. Sources agree states retain considerable discretion in setting child and pregnant‑woman thresholds [2] [6]. Available sources do not mention specific 2026 dollar cutoffs for every state or whether any states have announced nonstandard implementation dates beyond the usual Feb–Apr window.
Bottom line: the 2026 FPL numbers will reset the dollar levels behind Medicaid and CHIP percentage cutoffs; in practice many eligibility decisions in early 2026 will still use 2025 FPL figures until states formally adopt 2026 guidelines, and final impact varies by state because state plans set many of the child and pregnant‑woman thresholds [1] [3] [2].