IRA Rebates Above 150% AMI

What's Left After 25C Expiration — HOMES, Utility Rebates, and Financing Options (2026)

Last updated: April 11, 2026

25C and 25D Expired December 31, 2025 (OBBBA): The One Big Beautiful Bill Act, signed July 4, 2025, terminated the 25C Energy Efficient Home Improvement Credit and 25D Residential Clean Energy Credit for improvements installed after December 31, 2025. HEAR and HOMES rebate programs are unaffected — they are direct DOE rebate programs, not tax credits, and continue through September 30, 2031. 25C historical reference →

For clients above 150% of Area Median Income (AMI), 2026 is a meaningfully harder year. They never qualified for HEAR. And as of January 1, 2026, they lost the 25C tax credit — their primary federal incentive for heat pump HVAC, water heaters, insulation, and windows.

This guide covers what's still available: the HOMES rebate, state utility programs, and financing tools that close the gap for clients the federal rebate stack doesn't reach.

Who This Affects

HEAR (Home Electrification and Appliance Rebates) is income-limited: households must be at or below 150% of AMI to qualify. In practice, this is a wide swath of clients in affluent metros:

Metro Area150% AMI (family of 4)Implication
Boston, MA~$170,000Many middle-class households qualify for HEAR
New York City, NY~$175,000Wide HEAR eligibility in outer boroughs, less in Manhattan
Washington, DC~$185,000Generous AMI — most DC-area households qualify
Denver, CO~$150,000Many suburban households still qualify
Atlanta, GA~$130,000Above-AMI clients more common in affluent suburbs
Indianapolis, IN~$115,000More households fall above 150% AMI threshold
Rural/lower-cost counties$80,000–$100,000Many clients above threshold — check HUD AMI lookup

In lower-cost counties where 150% AMI is $85,000–$100,000, a significant portion of homeowners — especially those who own their homes and can afford upgrades — won't qualify for HEAR. For practitioners in suburban or rural markets, above-AMI clients may be the majority of their work.

How to find AMI for any county: HUD publishes income limits by county and metro area at huduser.gov/portal/datasets/il.html. Select the current year, find your state and county, and look at the 150% of median column. Also see the income verification guide →

What's Still Available: The 2026 Above-AMI Stack

Program Amount Status Income Limit?
HOMES rebate (Section 50121) Up to $4,000 Conditional No — but lower amounts above 80% AMI. Requires ≥20% whole-home savings.
State utility rebates Varies by program Available No income limit for standard programs
PACE financing Full project cost possible Available No (property-based, not income-based)
State green lending programs Up to $25,000–$50,000 Varies by state No income limit for most programs
25C tax credit Up to $3,200/year Expired 12/31/25 N/A — expired under OBBBA
HEAR rebate Up to $14,000 Income limit ≤150% AMI required — not available above threshold

Option 1: HOMES Rebate — Available at Any Income Level

HOMES (Home Efficiency Rebates, Section 50121) does not have an upper income limit. Any household in a live HOMES state can receive HOMES rebates — though the amounts are lower for market-rate (above 80% AMI) households than for LMI households.

Savings LevelLMI Household (≤80% AMI)Market-Rate (above 80% AMI)
20–35% whole-home savingsUp to $4,000 (up to 80% of cost)Up to $2,000 (up to 50% of cost)
35%+ whole-home savingsUp to $8,000 (up to 80% of cost)Up to $4,000 (up to 50% of cost)

For above-AMI clients, $2,000–$4,000 is not nothing — especially on a $15,000–$25,000 comprehensive upgrade project. The challenge: HOMES requires whole-home savings documentation. A heat pump replacement alone often won't hit 20% savings. A comprehensive project — heat pump + insulation + air sealing + water heater — usually does.

HOMES for an Above-AMI Client: What Works

Scenario: $18,000 project — heat pump HVAC ($10K) + air sealing/insulation ($5K) + heat pump water heater ($3K). Modeled savings: 38% whole-home energy reduction. Household income: $145,000 (above 150% AMI in their county).

Before OBBBA, this client would have added 25C at ~$2,700 (30% × $9,000 net cost) → $8,700 total savings. The 25C expiration costs this household $2,700.

HOMES is administered state-by-state. Check current program availability — several states have prioritized LMI households first and are phasing in market-rate enrollment. See the HOMES rebate program guide →

Option 2: State Utility Rebates — Income-Agnostic

Most utility rebate programs have no income requirement. They're funded by utility ratepayers and administered by utilities or third-party program administrators. These are often the most immediately accessible option for above-AMI clients.

State / ProgramHeat Pump HVAC RebateHeat Pump WH RebateNotes
Massachusetts — Mass Save (Eversource/National Grid)Up to $2,500Up to $750Income-agnostic standard tier; enhanced rebates for income-eligible
New York — ConEd Clean Heat$500–$1,500/systemNYC and Westchester; NYSERDA programs available statewide
Illinois — ComEd/Nicor Energy EfficiencyUp to $1,500Up to $500Income-agnostic; requires minimum efficiency
Wisconsin — Focus on EnergyUp to $600Up to $300Statewide; available to all WE Energies, Alliant, WPS customers
New Jersey — PSE&G / JCP&L Smart HomesUp to $1,500Up to $500Check specific utility; programs vary by provider
Michigan — DTE / Consumers EnergyUp to $1,000Up to $400DTE: $1,000 for qualifying cold-climate heat pump; Consumers: similar
Washington — PSE / AvistaUp to $1,500Up to $500PSE offers enhanced rebates for cold-climate units; stacks with HEAR
California — SoCalGas / SCE / PG&EVariesUp to $600Check TECH Clean California; varies by utility territory
Colorado — Xcel Energy / Black HillsUp to $1,500Up to $500Xcel offers rebates for air-source heat pump; stacks with HEAR for eligible households
Maryland — BGE / Pepco / DelmarvaUp to $1,500Up to $400Check EmPOWER Maryland; income-agnostic standard tier

The key practitioner action: for every above-AMI client, look up their utility provider and check the current rebate schedule before the proposal stage. Utility rebates often expire or change amounts mid-year. The stacking guide → covers application sequencing and the gross-vs-net cost issue.

Option 3: PACE Financing

PACE (Property Assessed Clean Energy) is property-secured financing repaid through the property tax bill. It's the leading financing option for above-AMI clients who don't want to tap home equity or personal credit.

How it works:

Where it's available: Commercial PACE is available in 40+ states. Residential PACE programs are more restricted:

PACE Practitioner Caution: R-PACE has faced regulatory scrutiny for high interest rates and disclosure practices, particularly in California. The CFPB has oversight authority over R-PACE under the 2022 Inflation Reduction Act consumer finance provisions. Always disclose total repayment cost and property lien implications clearly. Some states require specific disclosures.

Option 4: State Green Lending Programs

Several states operate their own below-market lending programs for home energy upgrades. These are often the best financing option where available:

StateProgramTermsIncome Limit?
Massachusetts MassSave HEAT Loan (Mass Clean Energy Center) 0% APR for income-eligible; market rate for others; up to $25,000; 7 year term 0% rate for ≤120% AMI; market rate for others — no income cutoff
Michigan Michigan Saves Home Energy Loan Competitive rates from 5.99%; up to $30,000; 5–15 year terms No income limit; stacks with DTE/Consumers rebates
Connecticut CT Green Bank Smart-E Loan 3.49–6.99% APR; up to $40,000; 5–15 year terms No income limit; available statewide through participating lenders
New York NYSERDA Green Jobs Green NY Loan Starting at 3.49%; up to $25,000; 5–15 years No income limit; income-eligible households may receive additional incentives
Maryland Maryland Clean Energy Center CleanEnergy Loan 7.49–8.99%; up to $20,000; 7–15 year terms No income limit
Wisconsin Focus on Energy On-Bill Financing 0–1.99%; up to $30,000; utility bill repayment Low-income priority but available to all utility customers

State program terms change. Verify current rates and availability directly with the administering agency before quoting clients.

Option 5: Mortgage-Linked Energy Financing

For clients refinancing, purchasing, or doing major renovations, mortgage-linked energy financing can be the most cost-effective option:

Fannie Mae HomeStyle Energy Loan

Allows borrowers to add up to 15% of the "as-completed" appraised value to a purchase or refinance mortgage for energy and water efficiency improvements. Heat pumps, insulation, windows, and solar all qualify. Processed as a standard mortgage — rates reflect the prevailing mortgage rate, not a specialty loan premium. Requires a contractor bid and independent verification.

FHA Energy Efficient Mortgage (EEM)

Allows FHA borrowers to add up to 5% of the property value (up to the maximum FHA loan limit) for energy improvements on top of an FHA purchase or refinance loan. Requires an energy audit by a qualified assessor. The energy savings must be cost-effective (documented payback period).

Unsecured Home Improvement Lenders

For clients who want simple financing without collateral:

The Client Conversation: Reframing the Post-25C Story

Above-AMI clients who hear "the tax credit is gone" may assume there's nothing left. The practitioner's job is to frame what remains accurately — not to oversell, but not to abandon the conversation either.

Suggested Framing: "The Stack Is Smaller, Not Gone"

"The 25C federal tax credit ended December 31st — that was $2,000–$3,200 off your federal taxes, and it's gone for now. But here's what's still on the table for your project: [utility rebate program] offers $[X] for the heat pump with no income requirement. And if the project hits 20% or more whole-home savings, you may qualify for HOMES rebates of up to $[2,000 or $4,000]. Add those together and you're at $[total] in direct incentives, separate from the energy savings you'll see on your bills.

"If you want to think about financing for the balance, I can walk you through [PACE / state green loan / contractor financing options]. The project math still works — it just takes a few more conversations."

Three questions to resolve in the above-AMI client conversation:

  1. Does this client qualify for HOMES? Run a quick energy model or home assessment. A comprehensive upgrade project (heat pump + insulation + air sealing) typically achieves 25–40% savings. If they're close to 20%, it may be worth designing toward that threshold.
  2. What utility rebates are available in their territory? Get the specific utility and check the current rebate schedule. Many utilities run seasonal promotions that aren't listed on their main pages.
  3. What's their tolerance for financing? If the project cash-flows well on a 7-year HEAT loan at 0%, present it that way. If they're in a state with PACE, present that as an alternative for clients who can't or don't want to touch their mortgage.

ROI Framing Without 25C

For above-AMI clients who relied on 25C as part of their payback calculation, the math changes by $2,000–$3,200. Here's how to reframe:

Project: $15,000 heat pump HVAC + $3,000 insulation, MA above-AMI householdPre-OBBBA (2025)Post-OBBBA (2026)
Utility rebate (Mass Save)$2,000$2,000
HOMES rebate (est. 28% savings)$2,000$2,000
25C tax credit$2,160 (30% × $7,200 net)
Total incentives$6,160$4,000
Net out-of-pocket$11,840$14,000
Est. annual energy savings$1,100$1,100
Simple payback10.8 years12.7 years

The payback extends roughly 2 years. For clients considering this on comfort, reliability, and decarbonization grounds — not purely financial — the 25C loss doesn't change the decision. For purely financial buyers, the loss is real and worth acknowledging directly.

Long-game note: 25C had bipartisan support before OBBBA and could be reinstated by a future Congress, potentially retroactively for 2026 installs. This is low probability and no timeline, but worth a brief mention for clients who are on the fence: documented 2026 installs could potentially benefit from reinstatement. Don't oversell it, but it's a real possibility worth naming.

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