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What are the exact income ranges (as % of FPL) that qualify for enhanced ACA subsidies under the ARPA provisions?
Executive summary
Under the American Rescue Plan Act (ARPA) enhancements (extended through 2025 by the Inflation Reduction Act), premium tax credits were made larger and eligibility was broadened — temporarily removing the 400% of Federal Poverty Level (FPL) cutoff so some people above 400% FPL could qualify and capping required household premium contributions as low as 0% for the poorest enrollees through 2025 (extended by IRA) [1] [2] [3]. If enhancements expire at the end of 2025, subsidies revert to pre-ARPA applicable percentages that are projected for 2026 to range roughly from 2.0% at 100% FPL up to about 9.96% for 300–400% FPL, and subsidy eligibility would again end at 400% FPL [4] [5].
1. What ARPA/IRA did to income bands and the %-of-income caps
ARPA’s enhancements reduced the percentage of income households must pay for the benchmark (second-lowest-cost Silver) plan and temporarily removed the strict 400% FPL eligibility cliff, allowing some people above 400% FPL to receive credits if benchmark plan costs exceeded 8.5% of income; those expansions were extended through the 2025 plan year by the Inflation Reduction Act [1] [2] [3]. Commentaries and policy briefs emphasize that the result was both larger subsidies for lower- and middle-income households and subsidy availability for certain higher-income enrollees during 2021–2025 [6] [7].
2. Exact applicable percentages (the “caps”) if enhancements lapse in 2026
Analysts and budget shops projecting the post-enhancement formula show applicable percentages for 2026 reverting to a sliding scale that effectively caps required contributions at roughly 2.0% of income near 100% FPL, rising across income bands to about 6.60% at 200% FPL, and reaching about 9.96% for those between 300% and 400% FPL [5]. One explainer gives a projected range for 2026 of about 2.1% to 9.96% and notes that, under the pre-ARP structure, subsidies would not be available above 400% FPL [4].
3. How the bands read in practice (what people should watch for)
Under the pre-ARPA (and thus projected 2026) structure, subsidy eligibility is generally for households with income at least 100% of FPL up to 400% of FPL, with the household’s maximum contribution to the benchmark plan rising across bands and capped as noted above — e.g., ~2% at 100% FPL, ~6.6% at 200% FPL, and ~9.96% for 300–400% FPL [5]. During 2021–2025 the enhanced structure meant people with incomes above 400% FPL could still receive credits in some cases, but that temporary lift ends without Congressional action [8] [7].
4. Who gains and who loses if enhancements aren’t extended
Proponents of the enhanced credits point to large enrollment increases and substantial premium relief for lower- and middle-income households, noting many enrollees at 100–150% FPL could face $0 premiums under enhancements [6] [9]. Opponents or fiscal analysts highlight the cost to the federal budget and say the reversion will reintroduce the “subsidy cliff” that can sharply raise premiums for those just over 400% FPL (examples and numerical impacts referenced in the Bipartisan Policy Center and healthinsurance.org pieces) [6] [8].
5. Limitations in the available reporting and where uncertainty remains
Available sources give the applicable percentage points and the policy framing for 2026 reversion, but they do not present a single authoritative, line-by-line statutory table of every income breakpoint or the exact interpolation method used across all discrete bands in the way a tax-code table might; reporting instead summarizes the sliding scale and provides exemplar percentages [4] [5]. Also, sources document that enhanced rules applied through 2025 and that Congress had not acted as of mid-November 2025 in some reports, but they do not settle whether or how Congress might change the formula going forward — that remains a political question [4] [1].
6. Practical takeaway for consumers and policymakers
Consumers should be prepared that, unless Congress extends the ARPA/IRA enhancements, marketplace subsidies will likely revert to a structure that caps household contributions at progressively higher percentages of income (roughly 2% to 9.96% across 100–400% FPL) and reimposes a 400% FPL eligibility cutoff — potentially raising premiums sharply for some [5] [4]. Policymakers debating extensions face a trade-off between federal spending and the affordability and continuity gains that advocates attribute to the enhanced credits [7] [9].
If you’d like, I can extract the specific percentage schedule as presented in the CRFB/other projection and format it as a simple table of income bands → applicable percentages using only the cited sources.