Which federal assistance programs use 100%, 133%, 138%, 200%, 250%, and 400% of FPL as eligibility cutoffs in 2026?
Executive summary
For coverage year 2026, most sources say traditional eligibility bands return: Medicaid expansion uses about 138% FPL, Marketplace premium tax credits generally apply between 100% and 400% FPL, and other program thresholds referenced in guidance include 133%/138% nuances and 250% for cost‑sharing reduction–related silver plan benefits (sources vary) [1] [2] [3]. Reporting agrees that the enhanced “no cutoff above 400%” subsidy from the American Rescue Plan expired after 2025 unless Congress acted, so 2026 reverts to 100%–400% for premium tax credit eligibility absent new law [3] [4].
1. Who uses 100% of FPL: the floor for marketplace subsidies and Medicaid gaps
Most guidance treats 100% FPL as a key boundary: people below 100% FPL generally are steered to Medicaid (where expansion exists) rather than marketplace premium tax credits, and 100% is the lower limit for many subsidy calculations and categorical eligibility discussions [5] [1]. HealthCare.gov describes income below 100% FPL as typically ineligible for Marketplace savings but likely eligible for Medicaid/CHIP in expansion states [5].
2. The 133% vs. 138% wrinkle: statutory math and practical application
The historic ACA statutory threshold is 133% FPL, but the effective Medicaid expansion eligibility is commonly implemented as 138% FPL because of how income counting and an income disregard roll up; consumer guidance and brokers emphasize 138% as the Medicaid expansion cutoff used in states that expanded [1]. Independent explainers note that for states with expansion, the practical minimum to be kept out of Marketplace subsidies and placed into Medicaid is about 138% [1].
3. 138% of FPL: Medicaid expansion’s commonly applied cutoff
Sources repeatedly cite 138% FPL as the working threshold for Medicaid expansion eligibility in participating states for 2026 coverage determinations [1]. This is the number used by many navigators and calculators to decide whether an applicant is routed to Medicaid rather than Marketplace premium tax credits [1].
4. 200% of FPL: a common reference point for affordability and subsidy phase‑ins
While none of the provided sources list a single federal program that uses a strict 200% FPL cutoff as a universal eligibility rule, 200% is commonly used in policy tools and slide decks as an affordability/phase‑in marker and appears in formulas and repayment cap explanations used by some calculators and advisors (available sources do not mention a single standing federal assistance program that uses exactly 200% FPL as its sole eligibility cutoff) (not found in current reporting).
5. 250% of FPL: cost‑sharing reduction (CSR) silver plan significance
Guidance indicates 250% FPL matters for cost‑sharing reduction eligibility tied to certain enhanced Silver plans sold on Marketplaces; brokers and reference charts include the 250% line for CSR and related help in benefit design [1] [6]. Documentation compiling thresholds for coverage year 2026 lists 250% among the reference points used for determining CSR eligibility and plan types [6].
6. 400% of FPL: the premium tax credit ceiling returned for 2026 absent extensions
Multiple consumer guides and trackers report that the ARP-era effective removal of the 400% cliff expired after 2025 unless Congress extended it, meaning the traditional 400% FPL upper limit for premium tax credit eligibility applies for 2026 unless new law reinstates the higher protection [3] [4]. HealthCare.gov–style explanations and subsidy calculators for 2026 treat 100%–400% as the general subsidy window in coverage year 2026 [2] [4].
7. Practical effect and timing: which year’s FPL numbers are used for 2026 coverage
Calculations for premium tax credits in 2026 use the prior year’s FPL guidelines (2025 poverty guidelines) as the measurement baseline; that lag affects exact dollar cutoffs though not the percentage thresholds discussed above [7] [2]. Several sources emphasize that the numerical FPL guidelines are updated each January and applied with a one‑year lag for Marketplace subsidy eligibility [7] [2].
8. Limits, disagreements and what’s not in the record
Sources agree on the broad framework (100% floor, ~138% Medicaid expansion, 250% CSR, 400% subsidy ceiling returning for 2026) but differ on whether to cite 133% or 138% as the statutory versus operational Medicaid threshold; navigators use 138% in practice [1]. Available sources do not name a federal assistance program that exclusively uses exactly 200% FPL as its decisive eligibility cutoff (not found in current reporting). All factual statements above are drawn from the provided materials [1] [3] [6] [4] [2] [5].
If you want, I can extract the actual dollar amounts for 100%, 138%, 250% and 400% FPL for a given household size (using the 2025 guidelines applied to 2026 coverage) and cite the precise source table.