What programs use the 2026 FPL to determine eligibility and income limits?
Executive summary
Federal poverty guidelines (FPL) set by HHS are the baseline for many federal, state and local income‑tested programs; 2025 FPL numbers are being used for most eligibility calculations for coverage in 2026, including Marketplace premium tax credits and Medicaid/CHIP determinations in many contexts [1] [2] [3]. Agencies and programs also apply specific percentage multiples of the guidelines (for example 138% for Medicaid expansion, 100%–400% bands for Marketplace subsidies) and distinct program rules—Head Start, SNAP, school lunch, LIHEAP and CHIP explicitly use the HHS guidelines or multiples of them [4] [5] [6].
1. What the FPL is and which year’s numbers apply to 2026 coverage
The HHS poverty guidelines—commonly called the FPL—are published annually and used to set income cutoffs; for coverage year 2026, most enrollment and subsidy calculations use the 2025 guidelines that HHS issued the year before [3] [2]. State marketplaces and enrollment sites (for example Covered California and Get Covered Illinois) explicitly state they will use the 2025 federal poverty guidelines to determine eligibility for programs and financial help for 2026 coverage [5] [7].
2. Major health programs that use the FPL for eligibility
Medicaid and CHIP eligibility, Marketplace premium tax credits and cost‑sharing reductions, and Medicare low‑income programs are tied to the FPL or percentages of it. HealthCare.gov and healthinsurance.org list Medicaid/CHIP, ACA premium tax credits and cost‑sharing reductions, and Medicare Savings Programs/Medicare Part D Low‑Income Subsidy as programs that rely on the guidelines [3] [6]. States publish charts translating FPL percentages into program thresholds (Covered California, Kentucky, Rhode Island examples) showing the operational use of the guidelines [5] [8] [9].
3. Non‑health federal and local programs that use the guidelines
Beyond health care, the HHS policy shop lists Head Start, SNAP, the National School Lunch Program, LIHEAP, and CHIP among programs that use the poverty guidelines or multiples of them (e.g., 125% or 185%) to determine eligibility [4]. Local education and early‑childhood programs (GSRP, Head Start) also reference FPL charts when evaluating family income [10].
4. How programs vary in applying the FPL—percentages, rounding and unit definitions
The FPL is a baseline; each program decides the percentage multiple to use (e.g., 138% for Medicaid expansion eligibility), what counts as income, how to round, and who counts in the household or eligibility unit. ASPE warns that program rules differ and that the phrase “FPL” can be ambiguous operationally [11] [4]. State materials and calculators reflect that variability by translating the same HHS chart into program‑specific thresholds [8] [12].
5. Important 2026 changes and policy context to watch
Several policy shifts affect 2026 eligibility: the temporary “no cliff above 400% FPL” enhancement ended after 2025 unless renewed, meaning traditional 100%–400% subsidy eligibility returns for 2026 coverage absent new legislation [2]. The ACA’s affordability safe harbor for employer coverage also updates in 2026 using FPL math—IRS guidance ties the affordability safe harbor to a 9.96% figure and an FPL‑based monthly threshold [13] [14]. KFF and other analysts flag regulatory and legislative moves that will change immigrant eligibility, special enrollment periods, and subsidy calculations for 2026 and beyond [15].
6. Practical takeaways for people checking eligibility
If you’re shopping for 2026 coverage or applying for Medicaid/CHIP, use the 2025 HHS poverty guidelines to estimate where your household falls; state marketplace sites and navigators will apply those numbers to compute subsidies or program access [3] [7]. Expect program‑specific rules about what income is counted, household composition, and rounding to affect final determinations—consult your state’s enrollment page or the specific program’s FPL chart for exact cutoffs [5] [11].
Limitations and caveats: official HHS/ASPE detailed tables and program rules govern exact dollar thresholds and treatment of income; available sources do not give a single universal list of every federal, state and local program that uses the FPL—rather, HHS/ASPE and individual program materials enumerate many major uses and note that individual programs set their own multiples, counting rules and rounding methods [4] [11].