Failure to provide QPSA explanation

[Guest Grumpy456]

A DB plan provides a fully-subsidized QPSA benefit and also provides an alternate death benefit to non-spouse beneficiaries if the QPSA is waived by the participant with spousal consent.

The DB plan document says that the QPSA explanation will be provided automatically by the plan sometime during the three year window which opens on the first day of the plan year the participant turns 32 and closes on the last day of the plan year the participant turns 34.

The DB plan sponsor is not providing the QPSA explanation at any time during this three year notification window.

Not providing a notice required by (1) applicable law and (2) the plan document is potentially, with respect to (1), a disqualifying defect and, with respect to (2), an operational defect.

Is this a problem to be concerned about?

Does the IRS offer any correction to this problem?

Thanks in advance for any suggestions.