Treasury made the boundaries of its regulation really clear -- to be protected by the Treasury Garnishment of Accounts Containing Federal Benefits Payments rule, transactions must include the "XX" in positions 54-55 of the Company Entry Description field and "2" in the Originator Status Code field of the Batch Header Record of the direct deposit entry.
If you don't see the "XX" in the Company Entry Description field of the ACH record, it's not covered.
There have been three waves of EIP payments during the pandemic -- two in 2020 and the third in 2021. The second wave included direct deposits protected by the "XX" because Congress declared they would be protected. The other two waves didn't include the "XX" in their ACH records.
So, rather than concern yourself with the type of payment and which agency sent it, look at the Company Entry Description field for the "XX". If it's there, apply the rule. If it's not, don't apply it.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8