If you have never filed a federal income tax return before, you can receive premium tax credits so long as you file a federal income tax return for the upcoming year. There is no requirement to have filed a tax return for any prior year in order to qualify. In order to continue receiving premium tax credits, you must file a tax return and reconcile any advance premium tax credits received using the appropriate IRS form, Form 8962. The marketplace will notify you when your coverage is renewed if you are not eligible for premium tax credits because you received premium tax credits in the past and did not file a tax return or failed to reconcile advanced premium tax credits using Form 8962.
However, due to the impact of the COVID-19 pandemic, for plan years 2021 and 2022, you will not lose eligibility for premium tax credits if you did not reconcile your prior year’s premium tax credits. (CMS, Failure to File and Reconcile (FTR) Operations Flexibilities for Plan Years 2021 and 2022 - Frequently Asked Questions (FAQ); 26 C.F.R. § 1.36B-2; 45 C.F.R. § 155.305).