The answer is “no”, right? Per this section of the Affordable Care Act:
The problem could become, though, that if you don’t file a federal tax return, you might not have the handy evidence to show that you were overseas. For example, you go to Japan for two years and don’t file a tax return for the U.S. How do you establish that you were in Japan, either as “bona fide resident” (Sec. 937) or for the 330 days of a 360 day calendar period? (Sec 911(d)). The tax return is establishing that you were, in fact, out—because that’s what you told the IRS. If the IRS doesn’t hear from you, and you go to enroll in an Affordable Care Act program upon your return to America, that now raises some flags that it used not to.
Once again, the sage advice is: file a tax return when you are living and working overseas.