Under the new 401(a)(9) regs, plan sponsors may elect to amend their plans to use the 5-year rule for all or certain distributions in cases where a participant dies before distributions begin and there is a designated beneficiary. Does anyone know how this election would interact with QPSA requirements, i.e., if a plan is amended to adopt the 5-year rule, does the 5-year rule supercede QPSA requirements, or vice-versa? Does anyone have a cite?

If the life expectancy method is not available under the plan, then a beneficiary would not be able to choose an optional form paying beyond 5 years, including a QPSA. So, I think I agree with you; a QPSA plan must provide for the life expectancy method at least as an option.