Which federal programs explicitly use 150% of the HHS poverty guidelines for 2025 eligibility and how do they count household income?
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Executive summary
A narrow set of federal programs and program-specific guidance reference 150 percent of the HHS poverty guidelines for 2025; the clearest, explicit uses in the available federal reporting are the Low Income Home Energy Assistance Program (LIHEAP) guidance and (in third‑party reporting) the Medicare Part D Low‑Income Subsidy cutoff, while many other programs use various percentages and leave income‑counting rules to the administering agency [1] [2] [3] [4]. Determinations of “household” and which income is counted are not standardized across federal programs — the governing statute or agency regulation defines family/household and which income to include, and agencies often publish program‑level rules for gross vs. net, periodic vs. annual income, and rounding [4] [5] [6].
1. LIHEAP: the clearest federal instruction to use 150% for 2025 eligibility
The Administration for Children and Families’ LIHEAP implementation memorandum for FY2025 explicitly provides HHS poverty guideline multiples including 150 percent for use in LIHEAP eligibility and states that use of those multiples is optional in FY2025 and becomes mandatory in FY2026, with detailed tables and add‑ons per additional household member referenced in the guidance [1] [2]. The LIHEAP Clearinghouse documentation reproduces those same 150 percent tables and the instruction that for households above eight members a specified per‑member addition applies at the 150 percent level [2]. That guidance is the most direct federal administrative document available in this reporting that tells a program to use 150 percent of the HHS poverty guidelines for specific eligibility computations [1] [2].
2. Medicare Part D Low‑Income Subsidy: common cutoff reported at 150% (third‑party source)
Contemporary explainers report that the Medicare Part D Low‑Income Subsidy (Extra Help) uses a 150 percent of poverty ceiling as an income eligibility limit for the program, noting recent legislative changes that altered asset/income thresholds for full benefits [3]. This comes from a reputable health‑policy explainer rather than the HHS Federal Register notice itself; the Federal Register and ASPE materials confirm the existence of multiples (including 150 percent) but leave program‑specific application to the program’s statute or agency rules [4] [6]. The conclusion that Part D Extra Help uses 150 percent is consistent with such third‑party reporting but should be verified against Social Security/Medicare program rules for an authoritative legal cutoff.
3. Programs that sometimes reference multiples (including 150%) but leave details to program rules
ASPE’s poverty‑guidelines documentation states that HHS publishes percentage multiples — 100, 110, 125, 150, 185 percent and others — and that “a number of federal programs” use those multiples, but it warns that rounding rules, income definitions, and the eligibility unit are determined by each program’s governing law or administering office [6] [5]. The Federal Register’s 2025 notice reiterates the same principle: the statute or regulation for each program defines “income” and “family,” and where those terms are undefined the administering entity must define them [4]. Thus, many federal programs may reference 150 percent as a possible threshold in tables or program rules, but the precise use and income counting methodology will be found in the program’s own regulations rather than in the HHS poverty‑guidelines notice [6] [4].
4. How household income is counted — no single federal rule; program rules control
Federal reporting emphasizes that there is no uniform federal rule for whether programs count gross or net income, earned vs. unearned income, or how to compute monthly vs. annual income; those procedural matters are defined by the statute or the administering agency for each program [4] [5]. For LIHEAP, the HHS/ACF materials provide FPG tables and instruct programs on using the multiples (including the per‑member add‑ons at 150%), but income documentation and the exact income counting methodology remain within LIHEAP program guidance at the state level [1] [2]. Similarly, ASPE’s FAQ notes that agencies applying the poverty guidelines determine rounding and which income is included for eligibility calculations [6].
5. What this reporting cannot confirm and recommended verification steps
The sources confirm LIHEAP’s explicit inclusion of 150 percent in federal FY2025 guidance and identify 150 percent as a commonly used multiple, and third‑party reporting ties Medicare Part D Extra Help to a 150 percent cutoff [1] [2] [3]. The available federal texts and ASPE FAQ, however, do not provide a single authoritative list in this dataset of every federal program that uses exactly 150 percent in 2025 or a uniform description of how each counts household income — instead, the agency or statute for each program must be checked for specific counting rules [6] [4]. For authoritative determinations, consult the program’s official regulation or administrative guidance (e.g., LIHEAP IMs, SSA/Medicare regulations, or program‑level eligibility manuals).