Which federal and state programs use 100% FPL eligibility thresholds in 2025?
Executive summary
In 2025, a handful of federal programs and many state-administered benefits use the Department of Health and Human Services poverty guidelines (the common “FPL” reference point) as a baseline, and several specific eligibility rules hinge on the 100% FPL threshold — notably premium tax credit eligibility floors in non‑Medicaid‑expansion states, certain Medicaid rules and Medicare low‑income programs, and some family planning services — but implementation varies by program and by state [1] [2] [3] [4]. Reporting that cites “100% FPL” often masks important complexities: federal law, temporary subsidy changes, Medicaid expansion status, and state choices all matter [2] [5].
1. Federal health‑program thresholds that reference 100% FPL
At the federal level, Marketplace premium tax credits and related subsidy rules are anchored to FPL percentages: the floor for premium tax credit eligibility can effectively be 100% of the FPL in states that have not expanded Medicaid, meaning individuals at or above 100% FPL can qualify for Marketplace subsidies while those below typically fall into Medicaid eligibility in expansion states or remain uncovered in non‑expansion states [1] [2]. The federal Title X family planning program explicitly allows people with incomes below 100% of the FPL to access family‑planning and preventive services under its rules, making 100% FPL an explicit eligibility cutoff in that federal program [4]. Also, federal Medicare low‑income assistance rules such as the Qualifying Medicare Beneficiary (QMB) program use 100% FPL as a trigger for state payment obligations on behalf of beneficiaries in some circumstances [3].
2. Medicaid and CHIP: federal frame, state variation, many programs using 100% FPL
Medicaid eligibility is a hybrid: the Affordable Care Act’s Medicaid expansion sets a 138% FPL floor for adults in expansion states, but for non‑expansion states eligibility for traditional Medicaid adults can be at or near 100% FPL or lower, and many states use 100% FPL (or a percentage close to it) for various Medicaid categories (Aged, Blind, Disabled, long‑term care waivers, and other covered groups) — state rules therefore mean that “100% FPL” is a practical eligibility boundary for multiple state‑administered Medicaid programs in 2025 [1] [5] [3]. CHIP thresholds are set by states and often exceed 100% FPL, so 100% is only a baseline comparison point there [2] [6].
3. State programs, administrative uses, and examples
States routinely adopt the federal poverty guideline amounts to set ceilings for eligibility and to populate their eligibility systems; California’s Medi‑Cal materials, for example, use the annual FPL figures to derive program ceilings and update systems for 2025 values [7]. Many states therefore apply “100% of FPL” as a cut‑off for specific state programs (nursing‑home Medicaid, HCBS waivers, and some adult eligibility categories), although the exact programs and cutoffs differ state‑by‑state and by program category [5] [7].
4. Temporary law, policy changes, and common reporting blind spots
Short‑term federal changes — notably ARP and IRA marketplace subsidy enhancements that altered income caps through 2025 — mean that headlines about who “starts” at 100% FPL can be misleading unless the time window and state context are specified; as of the end of 2025 some of those enhanced rules expired or were under legislative consideration, returning the mechanics to the long‑standing 100%–400% framework for Marketplace subsidies in many cases [2] [4]. Many secondary sources conflate the HHS poverty guidelines, Census poverty thresholds, and program‑specific percentages; this obscures that a program “using 100% FPL” may mean different administrative treatments (eligibility floor, pass‑through for state liability, or a data input) depending on the source [8] [9].
5. Bottom line — where 100% FPL matters in 2025
In 2025, 100% of the HHS poverty guideline functions as a hard or practical eligibility threshold for several federal and state programs: it is the effective lower bound for Marketplace premium tax credits in non‑expansion states and a qualifying marker for programs like Title X and certain Medicare low‑income protections, while many state Medicaid and waiver programs also use 100% FPL as an income test — but details depend on Medicaid expansion status, temporary subsidy law changes, and each state’s statutory choices, so program‑by‑program and state‑by‑state verification is required [1] [2] [3] [5] [4].