Yes, if they reported it on Form 1099-NEC (Non-Employee Compensation) they are treating it as earned income.
He will need to report the 1099-NEC on Schedule C and pay Self-Employment tax.
This is the same (almost) as when it was added to his W-2 income.
Using Schedule C means he pays both halves of the FICA tax, but he also gets half as a credit.
Because he is not in a trade or business to receive this income, he should answer "No" to being eligible for the 199-A Qualified Business Deduction. I also advise he not claim any expenses on the schedule C and only use it as a vehicle to report the income and pay the taxes.
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