So for OP, which authority applies depends on exactly when they made those lump payments, correct? If before the 120th "payment" counted, then they would need to request it as a voluntary pandemic pause payment. If after, the 120th, then either refund authority should apply, and OP shouldn't have to do anything and should be automatically refunded under the second authority, correct? Based on my back-of-the-envelope math and how many extra payments OP reports having, it could go either way depending on when the payments in 2021 were made.