Fact check: How are federal poverty guideline percentages (100%, 138%, 250%) used for program eligibility in 2025?

Executive Summary — Quick Bottom Line for 2025 Eligibility

The 2025 Federal Poverty Guidelines (FPL) and common fractions of them — 100%, 138%, and 250% — are the standard income thresholds used across federal and state programs to determine eligibility for health coverage, premium subsidies, and nutrition and assistance programs, with Medicaid expansion typically tied to 138% FPL and Marketplace cost-sharing or premium assistance often referenced around 250% FPL ^{[1] [2] [3]}. The Department of Health and Human Services issues updated guidelines annually, and states apply those levels differently: Alaska and Hawaii use higher dollar amounts, and expansion vs non-expansion states create major differences in who qualifies for Medicaid at these percentage cutoffs ^{[4] [5] [6]}.

1. Why 138% FPL Became the Medicaid Expansion Cutoff — The ACA’s Anchor

The Affordable Care Act’s design set 138% of the FPL as the de facto national benchmark for Medicaid expansion because federal statute and Centers for Medicare & Medicaid Services guidance tied enhanced federal funding to states that adopt expansion up to that level, creating a clear eligibility line for adults without dependent children in expansion states. The guidance and widely reported state-by-state summaries show that expansion states accepted adults up to 138% FPL, while non-expansion states retain more restrictive eligibility rules for adults and often limit Medicaid to parents or medically needy pathways ^{[2] [6]}. The 2025 updates to the FPL are applied to these percentage thresholds annually, meaning that the dollar income that equals 138% shifts with HHS updates and cost-of-living adjustments ^[5].

2. What 100% FPL Means — The Baseline for Many Programs

100% of the Federal Poverty Guideline is the statutory baseline used by numerous programs to define poverty-level income, and many program rules reference multiple percentages of that baseline to calibrate benefits or eligibility tiers. The 2025 guidelines list the exact dollar figures by household size — for example, $15,650 for one person and $32,150 for a family of four in the contiguous U.S. — and those numbers are the basis for multiplying to 138% or 250% thresholds ^{[2] [1]}. Programs such as certain federal assistance or fee waivers may use 100% FPL to determine the most narrowly targeted benefits, and annual updates from HHS ensure the baseline reflects inflation and policy changes ^[5].

3. Who Is Affected at 250% FPL — Marketplace Subsidies and Cost Sharing

Thresholds around 250% of FPL matter primarily for Marketplace affordability calculations, premium tax credits, and additional cost-sharing reductions or program eligibility that extends beyond the lowest-income tiers. Guides and analyses prepared for coverage years show that households at or below 250% may qualify for lower net premiums or extra savings on Marketplace plans, and some state programs that top up federal subsidies target populations at or below this percentage ^{[3] [7]}. The practical effect is that families earning between Medicaid levels and several multiples of the FPL often rely on these 250% thresholds to access meaningful financial assistance in the individual insurance market ^[3].

4. State Variation and Practical Eligibility — Expansion vs. Non-Expansion Realities

Despite uniform federal percentages, state policy choices produce very different access outcomes. Expansion states use 138% FPL to extend Medicaid to many adults, producing straightforward eligibility baselines, while non-expansion states limit adults to much lower thresholds or categorical eligibility, leaving people between Medicaid and Marketplace assistance in a coverage gap ^{[6] [4]}. Additionally, Alaska and Hawaii’s higher dollar guidelines mean the same percentage translates to a different absolute income threshold, so a Californian and an Alaskan with identical earnings could fall on opposite sides of a cutoff. Annual HHS updates translate across these state rules, but the policy architecture — expansion adoption, state supplements, and targeted program rules — drives on-the-ground eligibility outcomes ^{[4] [6]}.

5. Practical Takeaway — How Individuals and Administrators Use These Percentages

Individuals and program administrators use 100%, 138%, and 250% FPL as shorthand to determine benefit levels and to calculate dollar-based eligibility after the Department of Health and Human Services releases its annual guidelines. Outreach materials, state eligibility guides, and enrollment tools translate those percentages into specific dollar ceilings for household sizes so applicants know whether to seek Medicaid, Marketplace subsidies, or other assistance; updates and state-by-state guides published in 2025 reflect these conversions and explain local variations ^{[1] [2] [7]}. For policy watchers and practitioners, the critical fact is that percentage thresholds are constant anchors while the actual dollar cutoffs and coverage implications vary by state choices and HHS annual adjustments ^{[5] [6]}.