In general, you must file your tax return AND reconcile your premium tax credits using Form 8962 for every year you received premium tax credits. If you do not, the marketplace may discontinue premium tax credits for future coverage.
The marketplace will also not automatically re-enroll enrollees with financial assistance if enrollees who received advanced premium tax credits in previous years failed to file their taxes for the years they received tax credits.
NOTE: 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. However, HealthCare.gov still includes a section on the application requiring you to attest to having filed and reconciled premium tax credits for past years because the requirement to file and reconcile 2019 premium tax credits is still in place. Failure to check this attestation box could result in losing your eligibility for premium tax credits, even if you know you won’t be able to reconcile premium tax credits for 2020, 2021, or 2022. Therefore, when you apply for coverage you should check this box, even if you did not file taxes or reconcile premium tax credits for 2020, 2021, or 2022.
The marketplace will discontinue premium tax credits and cost-sharing reductions for enrollees receiving premium tax credits and cost-sharing reductions who have not contacted the marketplace to update their information for the last two years and no IRS income information available for them. You should file your taxes now so the IRS will be able to verify your income and so you do not lose eligibility for subsidies in future years.
(CMS, Guidance on Reenrollments and Redetermination for Exchange Coverage for 2018, July 13, 2017; CMS, Guidance on Reenrollments and Redetermination for Exchange Coverage for 2019 and Later Years; CMS, Failure to File and Reconcile (FTR) Operations Flexibilities for Plan Years 2021 and 2022 – Frequently Asked Questions (FAQs)).