I also posted in the DB forum, but I am posting here b/c it seems this forum has more activity.
As you know, plans were required to start operating in compliance with the Qualified Optional Survivor Annuity ("QOSA") rules for plan years beginning after 12/31/2007. What do you do if a plan failed to offer QOSA as an option in 2008? Is there a correction method for this type of failure? If not, is there a correction procedure for failiing to offer a QJSA that by analogy could be applied to a failure to offer a QOSA?