Not sure i agree.  Actually I don't agree.  If you follow flow Chart 1 on the 8915-F it specially leads me to only completed lines 12 though 15.  So not sure why you are saying it doesn't need to be completed or amending a return.  The client has simply deferred the corona distribution over 3 years and paying it back over the 3 years.  No tax effect.  I'm sure the IRS wants to know this.  It appears it should be on 8915-F and for 2021 8915-E is just a worksheet that flows to 8915-F.