TaxGuyBill
Level 15

As was pointed out, that is zero guidance in this regards.  So as it is, I would say "no".

Even if/when the IRS does issue guidance in this regards, in MANY cases there won't be a repayment anyways.  That is because the potential credit is NOT based on the cost of insurance (which was partially refunded).  It is based on the Second Lowest Cost Silver Plan (SLCSP).   Because of that, in most cases the credit would not change due to partially refunded premium.

However, the credit is reduced if the potential credit is higher than the actual cost of insurance.  So in those cases, then there hypothetically should be a repayment due to the MLR rebate.  But as I said above, there is zero guidance from the IRS about it, so I would not do anything until the IRS issues guidance about it.