ACAACAIndexSubsidy rules, calculated
FPL

Which federal poverty guideline the Marketplace uses

Match the coverage year to the prior guideline set and use the separate tables for Alaska, Hawaii, and the contiguous states.

Ruling
PTC calculations use the poverty guideline in effect on the first day of the coverage year's open enrollment period. For 2026 coverage, that is the 2025 guideline, with separate tables for Alaska, Hawaii, and the 48 states plus D.C.

Coverage year and guideline year differ

The HHS poverty guideline published during the coverage year is usually not the PTC table for that same coverage year. Follow Form 8962 and Marketplace guidance rather than selecting the newest HHS number.

Use residence and family size correctly

Alaska and Hawaii have separate guidelines. The applicable family size follows the PTC tax family, not only enrollees. A midyear move requires the Form 8962 rules for residence and coverage months.

Decision example and mistake

A household preparing a 2026 estimate uses the newly published 2026 HHS guideline. That creates the wrong FPL percentage. The mistake is matching the two labels by year instead of using the open-enrollment rule.

Select the guideline table deliberately

For a calendar-year Marketplace plan, use the poverty guideline in effect on the first day of open enrollment for that coverage year. That generally means 2026 coverage uses the 2025 guideline. Select the separate Alaska or Hawaii table when the household resides there and extend the published amount correctly for households larger than eight.

Archive the official guideline table used for the calculation, because later publications can display a newer year's figures beside the coverage-year return.

Filing and enrollment checks

  • Match the guideline year to the coverage year rule.
  • Use the household's applicable region.
  • Document the household size used to calculate the percentage of FPL.

Continue with

The 2026 ACA subsidy cliff: where the credit endsACA tax household versus the people who need coverageForm 8962 walkthrough: claim and reconcile the PTC

Authorities used for this guide