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What programs use the 2026 FPL for determining subsidies and cost-sharing reductions?
Executive summary
For 2026 coverage, eligibility for the Affordable Care Act (ACA) premium tax credit (APTC) and cost‑sharing reductions (CSRs) is determined by comparing a household’s projected 2026 income to the prior year’s federal poverty level (the 2025 FPL) for most marketplace calculations — so 2025 FPL numbers are used to set who qualifies for 2026 subsidies [1] [2] [3]. Under current law the APTC universe will generally be people with incomes between 100% and 400% of FPL and CSRs will generally apply to those with incomes between 100% and 250% of FPL for the 2026 benefit year [4] [5] [6].
1. Which programs use the FPL to set 2026 subsidy eligibility — short list
Federal and state ACA‑related subsidy programs that rely on FPL guidelines to determine 2026 eligibility include: the Marketplace/Exchange premium tax credit (APTC) and associated cost‑sharing reductions (CSRs); Medicaid/CHIP eligibility thresholds (for states that use the federal guidelines); certain Medicare low‑income programs and Medicare Savings Programs referenced to FPL; and state‑run premium assistance programs that index eligibility to FPL [1] [3] [7] [8].
2. Marketplace premium tax credits (APTC): which FPL year is used and who qualifies
For coverage effective in 2026, the marketplaces use the prior year’s poverty guidelines — i.e., the 2025 FPL — to compare with a household’s projected 2026 MAGI and calculate APTCs [1] [2]. Under current law the enhanced pandemic/IRA expansions sunset at the end of 2025; absent Congressional action the subsidy rules revert and APTC eligibility will generally be limited to households with incomes at or above 100% and at or below 400% of FPL [6] [2] [9].
3. Cost‑sharing reductions (CSRs): income bands and plan effects
CSRs are tied to APTC eligibility but only apply for enrollees who pick Silver plans and meet the lower income bands. For 2026 benefit year rules cited by CMS, CSRs reduce maximum out‑of‑pocket limits most steeply for households between 100%–150% FPL and provide smaller reductions up to 250% FPL; no CSR reductions apply above 250% and through 400% FPL [5] [10]. Multiple explainers also state CSRs are available between 100% and 250% of FPL [4] [10].
4. Timing and which FPL number matters for which year
Marketplace subsidy calculations compare projected income for the coverage year to the previous year’s FPL numbers; thus 2026 coverage eligibility and subsidy levels are calculated against the 2025 FPL [1] [2] [11]. Some other programs (Medicaid determinations or employer safe‑harbors) may use slightly different timing rules or different official FPL publications, so plan years and non‑calendar employer plans can sometimes rely on the most recently published guideline in effect within a defined look‑back window [12].
5. State subsidy programs and special exceptions
Several states run their own premium subsidy or cost‑sharing programs (ConnectorCare, state subsidy pilots, New Jersey programs, Covered California charts) and tether their income limits to FPL as well; some states have expanded or temporarily adjusted income caps in response to the federal sunset, and those programs will use the FPL framework for eligibility [7] [3] [13] [14]. State rules can extend subsidies beyond federal cutoffs (for example Massachusetts’ ConnectorCare pilot extended to higher percentages for 2026) [7] [3].
6. What changes in 2026 could alter who gets subsidies
Key policy shifts for 2026 include the scheduled expiration of enhanced APTCs (which narrowed eligibility back to the 100–400% FPL band unless Congress acts), new rules affecting immigrants’ eligibility under some recent laws or regulations, and the possibility Congress funds CSR reimbursements — CMS has asked carriers to model both funded and unfunded CSR scenarios for 2026 rate filings [2] [15] [16] [17]. Analysts warn that if enhancements expire, many current enrollees above 400% FPL will lose APTCs and subsidies will shrink for others [2] [18] [9].
7. Practical takeaways for consumers and employers
Consumers: assume eligibility for 2026 APTCs and CSRs will be measured against 2025 FPL numbers (so check 2025 FPL thresholds for your household size) and that CSRs will be limited to those under 250% FPL unless legislation changes [1] [4] [5]. Employers: if you use the FPL safe harbor for affordability testing, the required contribution percentage and the FPL dollar amounts change for 2026 plan years and non‑calendar plans may be permitted to use either 2025 or 2026 FPL depending on plan timing [12].
Limitations and gaps: available sources do not present an exhaustive statutory table mapping every federal program and every administrative use of the 2026 FPL; most reporting focuses on marketplace APTCs/CSRs, Medicaid/CHIP links, employer affordability safe harbors, and state subsidy programs [1] [12] [7]. If you want, I can compile the specific 2025 FPL dollar thresholds by household size from the HHS poverty guidelines used in these calculations and map them to the programs above.