How have federal poverty levels trended from 2020 to 2025 for health coverage?
Executive summary
Federal poverty guidelines used for health coverage rose each year from 2020 through 2025, with the 2025 guideline for a single person in the contiguous U.S. set at $15,650 — up from $15,060 in 2024 — and higher figures for Alaska ($19,550) and Hawaii ($17,990) [1] [2]. Marketplace and Medicaid eligibility use those annual HHS guidelines differently: eligibility for 2025 Marketplace subsidies is based on 2024 guidelines, while 2026 subsidy eligibility uses the 2025 guidelines [3] [2].
1. Trendline: modest, steady increases set by HHS — not large jumps
The HHS poverty guidelines are updated annually to reflect price changes; the 2025 mainland U.S. guideline of $15,650 represents a year-over-year rise from $15,060 in 2024, a change explained by HHS’s CPI-based adjustment [1] [4]. Reporting and guidance across Medicaid and employer-affordability rules consistently cite these incremental upward adjustments rather than abrupt policy-driven resets [1] [5].
2. How those numbers map to health coverage rules
Health coverage rules use different years’ FPL numbers for eligibility: Marketplace premium-tax-credit eligibility for a given coverage year is typically calculated from the prior year’s poverty guidelines — for example, eligibility for 2025 coverage used 2024 guidelines, while 2026 coverage eligibility relies on the 2025 guidelines [3] [6]. Medicaid uses the HHS guidelines for enrollment thresholds (including the 138% expansion cutoff used in many states), so the upward movement in FPL raises the dollar-level cutoff for programs tied to percentages of the FPL [7] [2].
3. Geographic nuance: Alaska and Hawaii differ materially
HHS publishes separate tables for Alaska and Hawaii; the 2025 FPL is substantially higher in those states ($19,550 for Alaska and $17,990 for Hawaii) than the contiguous U.S. figure of $15,650 [1] [2]. Policy implementations — for example, employer ESR affordability safe harbors — rely on the FPL for the state where an employee works, so the higher Alaska/Hawaii guidelines have concrete effects on affordability testing and program thresholds [1].
4. Policy changes and temporary exceptions that affected 2020–2025 eligibility
Beyond annual guideline increases, Congress and administrative action affected subsidy reach during this period: expansions and temporary exceptions (for example, the ARP and IRA-era changes) modified the practical income ranges eligible for Marketplace credits through 2025, meaning that the same FPL percentage could translate into different real-world access across years [8] [7]. Available sources note the IRA extended ARP improvements through 2025, and that some subsidy rules in effect 2021–2025 temporarily relaxed the 400% cutoff [8] [7].
5. Interaction with employer coverage and affordability tests
Employers use the FPL to test affordability under certain safe harbors; HHS’s increase in the FPL and the separate increase in the ACA benchmark percentage for 2025 changed the dollar threshold employers use to determine whether coverage is “affordable” [1]. Mercer and federal guidance cite both the updated FPL and the higher ACA benchmark percentage when describing 2025 employer testing [1].
6. What this meant for Medicaid and the coverage gap states
Because many Medicaid eligibility rules are expressed as percentages of the FPL — notably 138% in expansion states — annual FPL increases raise the nominal income ceiling for Medicaid eligibility. In non‑expansion states, people in the coverage gap remain affected by those same dollar thresholds; sources highlight that a number of states still have pre‑ACA limits, leaving some residents eligible for Marketplace subsidies only if they meet the relevant FPL-based rules [2] [8].
7. Data and reporting caveats readers should know
HHS updates guidelines annually (usually mid‑January) and bases them on CPI adjustments to Census poverty thresholds; reporting often mixes coverage-year and guideline-year references (e.g., “2024 guidelines used for 2025 coverage”), which can create confusion if readers don’t note which year’s FPL is being applied to a program year [4] [3] [6]. Also, not all sources in the corpus cover every year-by-year FPL table back to 2020; available sources confirm the 2024→2025 increase and explain the mechanics, but they do not provide a full year-by-year numeric series from 2020 through 2025 in a single table [1] [5].
8. Bottom line for people shopping for coverage or judging eligibility
Because the dollar amounts tied to percentage cutoffs (e.g., 100%, 138%, 400%) rose modestly each year, a household near an eligibility boundary in 2020–2025 likely saw its nominal dollar cutoff move upward; however, the practical effect on access depends on whether temporary subsidy expansions or state Medicaid expansion choices were in place for that year [1] [8]. For precise eligibility calculations, use HHS/ASPE poverty-guideline tables for the relevant guideline year and note whether the coverage program reads the prior year’s guideline or the same-year guideline [5] [3].