"Edit: Two tax professionals said - you do NOT amend. When she withdraws this year, she will get a 1099-R for the withdrawal, and then you reconcile it for the 2023 return."

Did she report the tax and penalty on the 2021 tax return, for the excise and the taxable earnings? I thought you stated no. Here's what you are overlooking:

Each tax year has a Status. that you need to address That is Excess (subject to excise tax because it was left in the account for that tax year) and any taxable earnings (because you are not allowed to benefit  from Roth tax-free rules on disallowed funds)."

Yes, she did not report the tax and the penalty on the 2021 returns, but the two other tax professionals are saying, do not amend, do not file 5329 for 2021 and for 2022. Just reconcile on 2023 because when she withdraws contributions and earning, 1099-R will be issued so you reconcile based on that 1099-R on 2023 taxes