The 1040-NR instructions don't come out and say it, but the fact that they give the address for mailing a dual-status return without mentioning e-filing (as they do with a single-status return) suggests that these still have to be paper returns.  So just use your Sharpie.  

Added:  See Page 12 of the 1040-NR instructions.  They give the addresses for mailing if the return is not e-filed.  Then they give the same addresses, without a mention of e-filing, for dual-status returns.  

What did the taxpayer do for the 2022 return?