Please see this answer from bradenleg100
Yep, the folks that opted for the full monthly subsidies in 2020 are absolved from paying back the credit if they fell out of the PTC range, but the IRS has not yet addressed those taxpayers that chose to pay full monthly health premiums and instead take the tax credit at year end. There are very few people that fall into that bucket, so am assuming it has not come up yet. Hopefully, guidance is provided soon.
