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@qbteachmt wrote:

That's the only way it impacts the subsidy.

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Not necessarily.  Logic, reason and the principal of balancing things dictate that when the premiums are partially refunded, it potentially SHOULD retroactively affect the previous year's Premium Tax Credit because lower premiums have the potential to have reduced that credit.  If the refunded premiums had been done in the year of the Premium Tax Credit, the credit could have been smaller.  Logic and reason says there should be an offsetting to that in the current year by recalculating the previous year's credit.

That is what the OP asked about, and that is why that Q&A says the IRS is considering issuing guidance.

But because there is currently no guidance, we are left hanging, which typically means we ignore the situation.   🙂