How do states use the 2026 FPL to set Medicaid and CHIP income eligibility limits?
Executive summary
States set Medicaid and CHIP income limits as percentages of the Federal Poverty Level (FPL) and apply the most recently published FPL number that HHS has released for eligibility determinations — meaning the 2025 FPL numbers will govern Medicaid/CHIP eligibility through early 2026 until HHS issues the 2026 numbers and states adopt them (states typically switch between February and April) [1]. States then translate those FPL percentages into dollar thresholds (often adding the automatic 5% MAGI disregard) and apply state-specific rules — for example, expansion states use roughly 138% FPL for adult eligibility while children and pregnant women may have much higher percentage cutoffs set by each state [2] [3].
1. How the FPL functions as the baseline for state income limits
Medicaid and CHIP eligibility are expressed as percentages of the Federal Poverty Level; CMS and state agencies publish which coverage groups use MAGI-based income tests and the percent-of-FPL cutoffs that apply in each state [3]. That means states do not set dollar amounts independently each year so much as choose a percentage of the FPL — for example, 100% of FPL, 138% for expansion adults, or much higher percentages for some child‑coverage categories — and then convert that percentage into a dollar threshold using the current FPL table [3] [2].
2. Which FPL year a state uses and when it changes
The Department of Health and Human Services updates the poverty guideline numbers annually (typically in mid‑to‑late January), but states commonly delay operational use until a later date — many switch to the new numbers between February and April; Wisconsin has switched as early as February 1 in past years [1]. Consequently, for determinations made in late 2025 and into early 2026 most programs still rely on the 2025 FPL numbers until the official 2026 guidance is published and implemented [1].
3. The mechanics: percentages → dollar limits → program decisions
States publish income standards as a percent of FPL for principal MAGI coverage groups; CMS’s national table lists those percentages and notes that states sometimes display dollar‑amount thresholds derived from the FPL amounts [3]. Practically, an eligibility worker or online system takes the applicable percent-of-FPL cutoff, multiplies by the current FPL dollar value for the applicant’s household size (often with an automatic 5% disregard built in), and compares that to the household’s MAGI to determine eligibility [3] [4].
4. Key thresholds that drive program access
The ACA expansion for adults effectively set a 133% statutory cutoff, which operates as about 138% after the mandatory 5% disregard in MAGI calculations; expansion states therefore use that threshold to admit adults based solely on income [5] [3]. Children, pregnant women, and other groups often have different, generally higher percent‑of‑FPL ceilings; some programs and states set child coverage up to several hundred percent of FPL (examples and exact percentages vary by state) [3] [6].
5. Interaction with Marketplace subsidies and timing implications
The Marketplace uses the current year’s published FPL to check both Medicaid/CHIP eligibility and subsidy eligibility; if someone applies for coverage in late 2025 for a 2026 plan the Marketplace will still compare projected 2026 income against the 2025 FPL numbers until states adopt the 2026 FPL [1]. This timing can affect whether an applicant is routed to Medicaid versus to subsidized Marketplace coverage — and the return of the traditional 100–400% subsidy band in 2026 (reported in secondary sources) makes the correct FPL in force materially important for many households [4].
6. State variation and practical consequences for families
States differ sharply in the percent-of-FPL they set for specific groups; some non‑expansion states maintain extremely low effective dollar cutoffs for parents or adults, producing situations where modest increases in income can trigger loss of Medicaid (state examples and specific thresholds differ by state and should be checked on state tables) [7] [3]. CMS’s statewide eligibility table is the authoritative crosswalk for which groups use MAGI and what percent-of-FPL applies in each jurisdiction [3].
7. Limitations, ambiguity, and what reporting does not say
Available sources do not list the exact 2026 FPL published dollar values here; reporting instead documents the procedural rule that the 2025 FPL governs until the 2026 values are published and adopted by states between February and April [1]. Sources here also do not provide a single, up‑to‑date state‑by‑state 2026 table; for precise dollar thresholds for a given state and household size, consult the CMS eligibility tables and the state Medicaid agency [3].
Bottom line: states set Medicaid/CHIP income limits as percentages of the FPL and apply whichever year’s FPL HHS has in effect operationally; that means the 2025 FPL governs eligibility into early 2026 until states adopt the 2026 figures, and state‑specific percent cutoffs (plus the MAGI 5% disregard) determine the actual dollar cutoffs households face [1] [3] [2].