[HC-03] The Medicaid Floor: When Your Income Is Too Low for ACA Subsidies

The early-retiree’s minimum-income problem — and why “too much money for Medicaid” is usually false

Pillar: Healthcare Navigation · Applies to: Early retirees / FIRE with low taxable income, in both Medicaid-expansion and non-expansion states Length: Extended — one question (“what is my minimum income?”) with three regimes: the 138% FPL expansion floor, the 200% FPL Basic Health Program floor, and the 100% FPL non-expansion coverage gap. Splitting the BHP floor out would force every regime to re-explain the other two. Last verified: August 2026 · Refresh cadence: Annual (November) + event-driven (OBBBA Medicaid provisions phasing in 2027–2028) Related: HC-01 ACA Bridge Before Medicare · HC-02 Medicare 101 · ER-02 Roth Conversion Ladder · TX-01 0% Capital Gains · FN-02 Key Numbers · FN-03 Policy Watch · ST-04 State Quick-Reference

Not advice. Educational reference. Medicaid rules are set state-by-state and are changing fast under OBBBA (2025). Verify eligibility, asset rules, and estate-recovery policy with your state Medicaid agency and marketplace before acting — the mechanics below vary by state and by the month.

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TL;DR

• ACA premium subsidies are a function of MAGI, and they have a floor as well as a ceiling. Drive your income too low and the exchange stops offering you a subsidized plan and routes you somewhere else. Where “somewhere else” is depends entirely on whether your state expanded Medicaid.
• Expansion states (40 + DC): below 138% FPL (~$21,597 single / $29,187 for two in 2026) you’re eligible for Medicaid, not marketplace subsidies. That’s a hard floor, not a phase-out. ✅
• Non-expansion states (10): there’s a coverage gap between roughly 0% and 100% FPL — too rich for that state’s threadbare Medicaid, too poor for premium tax credits, which don’t begin until 100% FPL ($15,650 single in 2026). An estimated 1.4 million people sit in it. ✅
• Basic Health Program jurisdictions (MN, OR, NY, DC) have a second floor at 200% FPL. Public coverage extends to 200% FPL there, and being eligible for it blocks your premium tax credit whether or not you enroll. In Oregon the number to clear is $42,300 for a couple, not $29,187 (§2). ✅
• The load-bearing misconception: “I have too much in savings to qualify for Medicaid.” For the ACA-expansion adult group, there is no asset test — eligibility is income-only. A household with a seven-figure portfolio and $18k of realized MAGI qualifies for Medicaid in an expansion state. ✅
• The fix in both regimes is the same lever, run in reverse: manufacture just enough MAGI — a small Roth conversion or gain harvest — to clear the floor and land in subsidized-marketplace territory. Clearing the floor is often nearly free and productive (it advances your Roth ladder).
• Watch OBBBA. Work/community-engagement requirements for expansion adults land January 1, 2027 — though a state may defer to as late as December 31, 2028 under a good-faith-effort exemption, and 25 states are suing over the rule — with 6-month redeterminations and new cost-sharing behind them. Medicaid is getting more administratively fragile as a FIRE tool. → FN-03

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1. The Floor Is the Mirror Image of the Cliff

HC-01 is about the ceiling: keep MAGI under 400% FPL or lose everything. This article is about the opposite failure. As an early retiree who controls MAGI by choosing which accounts to spend from, it is entirely possible — common, even — to show so little income that the marketplace won’t sell you a subsidized plan at all.

Two numbers bound the subsidized-marketplace zone:

	Lower bound (the floor)	Upper bound (the cliff)
Expansion state	138% FPL — below it, Medicaid	400% FPL — above it, full price
Expansion + Basic Health Program (MN, OR, NY, DC)	200% FPL — below it, Medicaid or the BHP	400% FPL — above it, full price
Non-expansion state	100% FPL — below it, the coverage gap	400% FPL — above it, full price

Premium tax credits are only generated for household MAGI at or above 100% FPL. That statutory floor never moved. What Medicaid expansion did was raise the practical floor to 138% FPL in expansion states — because between 100% and 138% the exchange hands you to Medicaid instead of writing a credit. In non-expansion states, nothing fills the 0–100% band, which is the coverage gap.

The counterintuitive consequence: in a non-expansion state, a very-low-income early retiree may need to show more income to get any affordable coverage. Reporting less is worse.

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2. The Map: Expansion vs. Non-Expansion (2026)

As of 2026, 40 states plus the District of Columbia have adopted the ACA Medicaid expansion; 10 have not. North Carolina was the most recent to expand (late 2023); no state expanded in 2024 or 2025. ✅

The 10 non-expansion states: Alabama, Florida, Georgia, Kansas, Mississippi, South Carolina, Tennessee, Texas, Wisconsin, and Wyoming. ✅ (Wisconsin is a partial case — it covers adults up to 100% FPL through a waiver, so it has no coverage gap even though it never took the ACA expansion. Georgia runs a limited work-conditioned program. Treat both as “verify locally.”) ◻️

Why it matters for your plan:

• Expansion state, income-controlled retiree: your risk is accidentally qualifying for Medicaid by under-reporting MAGI when you’d rather hold a marketplace plan. The remedy is to lift MAGI over 138% FPL on purpose.
• Non-expansion state, income-controlled retiree: your risk is the coverage gap. Medicaid for a non-disabled, non-pregnant adult without dependent children frequently doesn’t exist at any income in these states, and childless-adult thresholds where they exist are far below 100% FPL. The remedy is to make sure your projected MAGI is at least 100% FPL so premium tax credits kick in.

The second floor: Basic Health Program jurisdictions

Four jurisdictions run an ACA §1331 Basic Health Program (BHP) — public coverage for people between roughly 138% and 200% FPL who would otherwise buy a subsidized marketplace plan. Where one exists, the floor you must clear is 200% FPL, not 138%:

Jurisdiction	Program	Operating since	Enrollee cost
Minnesota	MinnesotaCare	Jan 1, 2015	~$0–$80/mo premiums ◻️
Oregon	OHP Bridge	July 1, 2024	$0 — no premiums, copays, or deductibles ✅
New York	Essential Plan	2015 (see below)	$0–low premiums ◻️
District of Columbia	BHP	Jan 1, 2026	◻️

Why this is a floor and not a menu. Under 26 CFR §1.36B-2, a BHP counts as a program “similar to” Medicaid/CHIP for premium-tax-credit purposes. Being eligible for it makes you ineligible for a PTC — whether or not you enroll. Declining the coverage does not restore your credit; only an Exchange determination that you are not eligible does. ✅

The practical consequence: an Oregonian at 150% FPL who follows the generic expansion-state advice in §7 lands in OHP Bridge, not a subsidized Silver plan. To reach the marketplace, a couple there must clear 200% FPL — $42,300 in 2026, not $29,187. ✅

New York, as of August 2026 — a floor that just moved. NY’s Essential Plan ran under a §1332 waiver that extended eligibility to 250% FPL from April 2024. OBBBA (H.R. 1, July 2025) eliminated the premium-tax-credit eligibility that made the expansion financially viable; CMS approved the state’s request to terminate the waiver effective July 1, 2026. From that date the Essential Plan reverts to BHP authority covering up to 200% FPL, and the 200–250% FPL population moves back to marketplace QHPs — becoming newly PTC-eligible. A rare case of a floor falling. Verify current status before planning. → FN-03 ✅

Note the interaction with the CSR bands. In a BHP jurisdiction you cannot reach the marketplace until 200% FPL — which is exactly where the richest cost-sharing reductions end (HC-01 §3). BHP-state residents who clear the floor land at 73% AV Silver at best, never the 94% or 87% tiers. The BHP itself is usually the better deal on cost; you’re clearing the floor for network, travel, HSA eligibility, or estate-recovery reasons (§5), not to save money.

→ Live expansion status and the state subsidy layer live in ST-04.

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3. The Misconception That Sinks People: “I Have Too Much for Medicaid”

For the population this wiki serves, the single most expensive misunderstanding is assuming a large nest egg disqualifies you from Medicaid. It usually doesn’t.

MAGI Medicaid — the ACA “new adult group” — has no asset or resource test. Federal law bars states from applying one to the MAGI eligibility groups (expansion adults, children, pregnant applicants, parents/caretakers). Savings, brokerage balances, home equity, and retirement accounts do not count. Eligibility is determined on income alone, using essentially the same MAGI you compute for the ACA (see HC-01 §2). ✅

So a 45-year-old FIRE couple with a $2.3M portfolio who spends from cash and high-basis taxable lots and shows $19,000 of MAGI is, in an expansion state, Medicaid-eligible — regardless of the portfolio. The exchange will tell them so when they apply.

This cuts two ways:

• If Medicaid is acceptable to you, it is nearly free comprehensive coverage that ignores your wealth. That’s a legitimate, legal outcome the ACA designed.
• If you don’t want it (see §5), low reported income is a trap you can walk into without noticing — and the marketplace will not let you buy a subsidized plan while it thinks you belong on Medicaid.

Don’t confuse MAGI Medicaid with the other Medicaid

The no-asset-test rule applies to MAGI Medicaid for under-65 adults. It does not apply to the non-MAGI pathways — Medicaid for people 65+, or the SSI/aged-blind-disabled and long-term-care programs. Those keep the traditional asset test (commonly ~$2,000 in countable resources for an individual) and their own income rules. ✅ Two practical implications:

1. At 65, you age out of MAGI Medicaid and into the asset-tested world. A wealthy-but-low-income strategy that worked at 45 does not carry into 65 — by then you’re on Medicare anyway (HC-02).
2. Long-term-care Medicaid is an entirely different animal with a 5-year lookback and estate recovery (§4). Nothing here is about qualifying for that.

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4. Estate Recovery: The Age-55 Asterisk

The one place a low-income Medicaid year can reach back for your assets is the Medicaid Estate Recovery Program (MERP). Federal law requires states to recover — from the estate of a deceased enrollee who was age 55 or older — the cost of long-term-care services: nursing-facility care, home- and community-based services, and related hospital and prescription-drug costs. ✅

What this means for the early-retiree case:

• Under 55: MERP is not in play. A 45-year-old on MAGI Medicaid has no estate-recovery exposure. ✅
• 55–64 on MAGI (non-LTC) Medicaid: federal law mandates recovery only for long-term-care services. States may elect to recover the cost of other Medicaid services (ordinary doctor visits, prescriptions) for the 55+ group, and a minority have historically done so. If you’re 55–64, income-controlling into Medicaid, in a state that pursues broad recovery, ordinary claims could theoretically attach to your estate. Verify your state’s recovery scope before choosing Medicaid over a marketplace plan in these years. ◻️
• Protections: no recovery while a spouse survives, or a child under 21 or a blind/disabled child of any age; hardship waivers exist. Recovery hits the estate, not you in life. ✅

For most healthy sub-55 FIRE households the MERP worry is overblown. For the 55–64 band in a broad-recovery state, it’s a real reason to lift MAGI over the 138% floor and buy a subsidized marketplace plan instead.

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5. Is Medicaid Actually Fine? An Honest Ledger

Medicaid is real, comprehensive coverage — often with near-zero premiums and minimal cost-sharing. Do not reflexively engineer your way out of it. But it differs from a marketplace plan in ways that matter to this audience:

Dimension	Medicaid (MAGI adult group)	Subsidized marketplace Silver (CSR)
Premium	~$0	$0–few hundred/mo after PTC
Cost-sharing	Minimal to none	Deductible/copays, reduced by CSRs (HC-01 §3)
Provider networks	Narrower; lower physician acceptance in many areas	Broader commercial networks
Care while traveling	Poor — coverage is state-bound; out-of-state is emergency-only	Varies, but PPOs travel better
Wealth optics / recovery	Age-55 estate-recovery asterisk (§4)	None
Administrative burden	Redeterminations; new OBBBA work rules from 2027 (§6)	Annual re-enrollment + income verification
HSA contributions	Ineligible — Medicaid isn’t an HDHP	Bronze/Silver HDHPs let you keep funding an HSA (HC-04)

The HSA point is easy to miss: a year on Medicaid is a year you cannot contribute to an HSA, forfeiting the deduction-that-lowers-MAGI compounding move that makes Bronze+HSA so strong for early retirees (HC-01 §4). For some households that alone justifies lifting MAGI over the floor.

Bottom line: Medicaid is an excellent deal for someone who values the near-zero cost, stays in-state, and is comfortable with the network. It’s a poor fit for the traveler, the HSA-maximizer, the 55–64 resident of a broad-recovery state, or anyone running a large Roth-conversion program who wants the income anyway.

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6. OBBBA Is Making Medicaid a Shakier FIRE Tool (as of August 2026)

The One Big Beautiful Bill Act (P.L. 119-21, July 2025) reworked Medicaid in ways that land during exactly the years an early retiree might lean on it. Stated as of August 2026; these are implementation-dependent — track in FN-03:

• Community-engagement (“work”) requirements. Expansion adults aged 19–64 (not pregnant, not on Medicare) must document 80 hours/month of work, community service, job-training, or half-time-plus education — or qualify for an exemption. CMS issued the implementing interim final rule (CMS-2454-IFC) on June 1, 2026. States must implement no later than January 1, 2027. Statutory exemptions include caregivers of dependents, pregnant and postpartum people, Tribal members, veterans with total disability ratings, the medically frail, and people already meeting SNAP/TANF work requirements. ✅
  • Two things soften the January 2027 date, both new since the rule landed. A state may seek a good-faith-effort exemption that delays implementation to no later than December 31, 2028 ✅ — so your state’s posture, not the federal date, is what governs you. And on June 30, 2026, 25 states and DC sued CMS over provisions of the interim final rule, including its treatment of “medically frail” — meaning the exemption categories themselves are unsettled. ✅ → FN-03 §4
  • The FIRE wrinkle, still unresolved: a voluntarily unemployed early retiree may not meet an 80-hour work test and may not fit a listed exemption. Depending on how your state writes its rules, MAGI Medicaid could become conditional on activity you left work to avoid. This remains the biggest open question for using Medicaid as a bridge, and nothing since June 2026 has answered it.
• Twice-a-year redeterminations. Expansion enrollees face eligibility re-checks every 6 months rather than annually — more paperwork, more churn risk. ◻️
• New cost-sharing. Expansion adults with income above 100% FPL face cost-sharing up to $35 per service (with an overall cap), phasing in later in the decade. ◻️

None of this makes Medicaid unusable. It does mean the “just fall onto Medicaid for a few gap years” plan now carries administrative and political risk it didn’t in 2024. Plan under current law and treat Medicaid as a coverage source you actively manage, not a passive backstop.

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7. Clearing the Floor: Manufacturing MAGI on Purpose

The tools are the same ones you use to stay under the cliff in HC-01 — run in the other direction. The goal is to lift household MAGI to a target just above the relevant floor.

Levers that create MAGI (use deliberately):

1. Roth conversions — 100% MAGI, and they advance your conversion ladder’s 5-year clocks (ER-02). This is the workhorse: it manufactures income and does productive tax work.
2. Capital-gain harvesting — realize long-term gains from taxable lots. In the 0% LTCG bracket this is federally tax-free and resets your basis higher (TX-01). Only the gain is MAGI.
3. Traditional IRA/401(k) withdrawals — 100% MAGI; useful if you also want the cash.

Aim above the floor with a buffer. Undershoot the floor and you’re back on Medicaid (or in the gap); the marketplace re-checks against actuals. In a standard expansion state a common target is ~145–160% FPL — comfortably clear of 138%, and in the sweet spot for 94% or 87% AV cost-sharing reductions on a Silver plan (HC-01 §3).

In a Basic Health Program jurisdiction (MN, OR, NY, DC), that target is wrong — 145–160% FPL sits inside the BHP band and still blocks your PTC. Your target there is just above 200% FPL (§2).

Worked example A — Expansion state, lifting off the 138% floor

Couple, both 47, expansion state with no Basic Health Program (see §2 — this example does not work in MN, OR, NY, or DC). They spend $72k/year from cash and high-basis taxable lots; their natural MAGI is only $18,000 — below the two-person 138% floor of $29,187, so the exchange routes them to Medicaid. They’d rather hold a Silver marketplace plan (travel, network, and they want to keep funding an HSA).

Step	Amount
Natural MAGI	$18,000 (85% FPL-equiv → Medicaid)
Target	~150% FPL = $31,725
Roth conversion to add	~$13,700
Federal tax on the conversion	≈ $0 — a MFJ couple’s 2026 standard deduction ($32,200) more than covers total income of $31,725 ✅
Result	MAGI $31,725 → 94% AV Silver with a strong PTC (the 94% band runs 100–150% FPL; above 150% it steps down to 87%), HSA-eligible if they choose Bronze, and $13,700 laddered into Roth tax-free

Clearing the floor cost them essentially nothing in tax and bought a rung on the Roth ladder. This is the rare move that’s free and productive at once.

Worked example B — Non-expansion state, escaping the coverage gap

Single, 52, non-expansion state (e.g., TX/FL). Natural MAGI $9,000 — below 100% FPL ($15,650). Medicaid doesn’t cover childless non-disabled adults here, and PTCs don’t begin until 100% FPL. Result: the coverage gap — no affordable coverage at all.

The fix: project MAGI at or above $15,650. A $7,000 Roth conversion lifts projected MAGI to ~$16,000 (≈102% FPL). That unlocks:

• Premium tax credits (they start at 100% FPL), and
• the richest CSR tier — 94% actuarial value Silver (available 100–150% FPL) — often for a near-$0 net premium.

A $7,000 conversion, taxed at roughly nothing after the standard deduction, moves this person from uninsured to a 94%-AV plan for about zero dollars a month. It is the highest-leverage move in this entire wiki.

The good-faith-estimate protection (non-expansion states): if you enroll projecting income ≥100% FPL in good faith and the marketplace grants a PTC, but your actual year comes in below 100% FPL, the credit is generally not clawed back — you’re still treated as an applicable taxpayer for that year. This is what makes the gap-escape strategy safe to attempt. Estimate honestly and defensibly; keep your worksheet. ✅ ◻️ (confirm current-year treatment before relying on it)

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8. Three Scenarios

A. The asset-rich, income-poor couple (both 45, $2.3M portfolio, expansion state). Living on cash and a high-basis brokerage, they naturally show ~$16k MAGI. The exchange says “Medicaid.” They’re fine with it for one year while a parent is ill and they’re homebound anyway — near-zero cost, and they’re not traveling. But they note two things: no HSA contributions this year, and the OBBBA work rules arriving in 2027. For 2027 forward they plan a standing $16k/year Roth conversion to sit at ~150% FPL, holding a subsidized Silver plan and keeping the ladder moving.

B. The coverage-gap near-miss (single, 58, non-expansion state). Projected MAGI $14,000 — $1,650 under the 100% FPL line. Left alone, she gets nothing: no Medicaid (childless adult, non-expansion), no PTC (under 100%). She harvests $3,000 of long-term gains (0% federal bracket) to project $17,000 (~109% FPL), landing a 94% AV Silver plan near $0/month. At 58 she also checks her state’s estate-recovery scope — moot here, since she’s on a marketplace plan, not Medicaid, which is part of why she preferred to climb out of the gap.

C. The 60-year-old who wants Medicaid but shouldn’t lean on it (expansion state). Low spending, ~$20k MAGI, Medicaid-eligible. But he’s 60, lives in a state that elected broad estate recovery for the 55+ group, and travels half the year. Two strikes: potential estate claims on non-LTC services (§4) and Medicaid’s poor out-of-state coverage. He converts ~$11k of Roth to reach ~140–150% FPL, buys a subsidized Silver PPO, and sidesteps both issues for the five years until Medicare (HC-02).

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💡 Pro-Tips

1. Write down your floor, not just your cliff. Each January, record your household’s 100% and 138% FPL figures next to the 400% cliff. Steer MAGI to a target with buffer on both ends.
2. Clearing the floor is the cheapest income you’ll ever manufacture. A Roth conversion sized to lift you over 138% FPL is usually taxed at ~0% (standard deduction) and advances your ladder. Do it on purpose, in December, once income is known.
3. In a non-expansion state, err slightly high. Projecting a hair over 100% FPL unlocks PTCs and the 94% AV CSR tier. The good-faith-estimate rule protects an honest projection that later comes in low.
4. Target 145–160% FPL, not 139%. It buys a margin against a low actual and lands you in the 87–94% AV cost-sharing band. In MN, OR, NY, or DC, target just above 200% FPL instead — below that a Basic Health Program blocks your credit entirely.
5. Remember the HSA cost of a Medicaid year. No HDHP means no HSA contribution — factor the lost deduction into “is Medicaid worth it this year?”
6. If 55–64, look up your state’s estate-recovery scope before choosing Medicaid — mandatory recovery is LTC-only, but some states reach further for the 55+ group.
7. Don’t income-plan into Medicaid past 2026 without reading the OBBBA work rules. A voluntarily-retired adult may not meet an 80-hour test or fit an exemption. → FN-03
8. Medicaid ignores your portfolio — say it out loud. The no-asset-test fact reshapes low-income years; just don’t confuse it with the asset-tested 65+/LTC programs.

⚠️ Common Pitfalls

1. Assuming savings disqualify you from Medicaid. MAGI Medicaid is income-only — no asset test. You can be a millionaire and eligible.
2. Under-reporting into Medicaid when you wanted a marketplace plan. Below 138% FPL (expansion) the exchange won’t sell you a subsidized plan — it hands you to Medicaid.
3. Falling into the coverage gap in a non-expansion state by showing under 100% FPL, then discovering there’s no affordable option — not Medicaid, not a PTC.
4. Clearing 138% FPL in a Basic Health Program jurisdiction and expecting a marketplace plan. In MN, OR, NY, and DC the public program runs to 200% FPL, and eligibility — not enrollment — is what blocks your credit. Declining the BHP does not get you a PTC.
5. Confusing MAGI Medicaid with LTC/aged Medicaid — importing a $2,000 asset limit or a 5-year lookback that doesn’t apply to the under-65 adult group (and vice-versa).
6. Overblowing estate recovery for a healthy under-55 enrollee — MERP is age-55+ and mandatory only for long-term-care services.
7. Ignoring the 55–64 broad-recovery states, where non-LTC claims can attach to the estate.
8. Treating Medicaid as a passive backstop through 2027, as work requirements, 6-month redeterminations, and cost-sharing phase in.
9. Forgetting you can’t fund an HSA on Medicaid — a quiet loss of the MAGI-lowering compounding play.
10. Undershooting the floor by projecting too conservatively, then bouncing onto Medicaid at reconciliation.
11. Assuming a good-faith high estimate gets clawed back if actual income is low — in the coverage-gap case it generally doesn’t; estimate honestly and keep proof.

✅ Actionable Checklist

Before you retire / while modeling MAGI

• Look up whether your state expanded Medicaid (sets floor at 138% vs. a 100% coverage-gap edge) — ST-04
• Check whether your state runs a Basic Health Program (MN, OR, NY, DC) — if so, your floor is 200% FPL, not 138%
• Compute your household’s 100%, 138%, and 200% FPL dollar figures from FN-02
• Decide, deliberately, whether Medicaid is acceptable to you this year (cost vs. network/travel/HSA/recovery)
• If 55–64: confirm your state’s estate-recovery scope (LTC-only vs. broad)

At enrollment

• Project MAGI to a target above the floor with buffer (~145–160% FPL) if you want a marketplace plan
• Non-expansion state: make sure projected MAGI is ≥100% FPL to trigger PTCs; document the good-faith basis
• If you’re comfortable on Medicaid, confirm eligibility on the exchange and enroll — no asset disclosure required for the MAGI group

Every year on the bridge

• December: size a Roth conversion / gain harvest to hit your target line once income is known (ER-02, TX-01)
• Re-check OBBBA implementation in your state — work rules, whether it sought a good-faith-effort deferral, redetermination cadence — FN-03
• Keep your income worksheet and enrollment screenshots for verification/redeterminations

Approaching 65

• Understand you age out of MAGI Medicaid at 65 into Medicare (HC-02) — re-plan coverage and IRMAA (HC-06)

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State notes (→ ST-01, ST-04): This entire article is a state-dependent question. Expansion status is the master switch — it decides whether your floor is a soft 138%-FPL handoff to Medicaid (40 states + DC) or a hard 100%-FPL coverage-gap edge with nothing beneath it (10 non-expansion states: AL, FL, GA, KS, MS, SC, TN, TX, WI, WY — WI covers to 100% FPL via waiver, so no true gap). ✅ A second switch sits on top of it: four jurisdictions — Minnesota, Oregon, New York, and DC — run an ACA §1331 Basic Health Program covering roughly 138–200% FPL, which raises the effective floor to 200% FPL because BHP eligibility blocks the premium tax credit (§2). ✅ Beyond both switches, estate-recovery scope varies: federal law mandates recovery only for long-term-care services for the 55+ group, but states may elect to recover other Medicaid costs — check yours before income-planning into Medicaid at 55–64. States also differ in how they are implementing the OBBBA work and redetermination rules (§6), and several run state premium-subsidy programs that change the marketplace-vs-Medicaid calculus at the margin. Model your state, not the national picture.

Sources & further reading (verified Aug 2026)

• Medicaid.gov — Eligibility Policy (MAGI methodology; the 5-percentage-point income disregard that sets the effective ceiling at 138% FPL) and Estate Recovery
• KFF — Status of State Medicaid Expansion Decisions (40 states + DC expanded; 10 not, as of 2026) and coverage-gap population estimates
• One Big Beautiful Bill Act (P.L. 119-21, July 2025) — Medicaid community-engagement requirement, redeterminations, and cost-sharing provisions
• CMS — Medicaid Community Engagement Requirement interim final rule (CMS-2454-IFC) and implementation guidance
• 42 U.S.C. §1396a(a)(10)(A)(i)(VIII) (the ACA adult group) and 42 U.S.C. §1396p (estate recovery, age-55 rule and exemptions)
• 26 CFR §1.36B-2 (treatment of taxpayers with household income below 100% FPL who estimated at/above it in good faith; and the treatment of Medicaid/CHIP/BHP eligibility as disqualifying minimum essential coverage)
• Medicaid.gov — Basic Health Program (ACA §1331; operating jurisdictions and start dates); Oregon Health Authority OHP Bridge FAQ; MinnesotaCare eligibility guidance
• NY State of Health — guidance on the end of New York’s §1332 waiver and the Essential Plan 200–250% FPL population (termination effective July 1, 2026)
• 2025 HHS Poverty Guidelines (govern 2026 plan-year eligibility) — FN-02
• Your state Medicaid agency and marketplace for eligibility, recovery scope, and OBBBA implementation specifics