A few weeks ago, I noted that one of the numerous ACA-related provisions of the American Rescue Plan was this one:
Put simply, subsidized enrollees last year received around $6.3 billion in "excess subsidies"...they underestimated their income for the year 2020 and would normally be required to pay them back, but the ARP is waiving that "clawback" of overpayments for one year only in response to the pandemic.
Again, these are subsidies which were already paid out in 2020. The money is already in the hands of the enrollees (well, technically it's in the hands of the insurance carriers, but that in turn freed up an equal amount in the bank accounts of the enrollees, anyway). This provision simply says that the enrollees don't have to pay it back.