Failure to pay QPSA, spouse has died

[fiona1]

DB plan where the only death benefit is the required QPSA, payable to a spouse. A participant terminated in the '80s with a $19 benefit. He died in 2006 and his required beginning date would have been 4/1/2008. 
The pre-retirement QPSA was never paid to the spouse, and she died in 2015. 

Does anyone know where the plan sponsor would go from here? I assume an "operational failure" has occurred (in terms of not paying the QPSA timely) but don't know that there is clear guidance in the EPCRS on how to handle this type of failure. I know it addresses what to do if a participant is not paid by their RBD, but what kind of options exist for this situation? Can they forfeit the benefit and move on? Do they have to pay this benefit to the participant or the spouse's estate?

[CuseFan]

We would pay the value of the missed payments plus interest to the spouse's estate and then review/revise procedures that led to this failure. They could forfeit and move on and likely never have it discovered but that is not the correct (or right) thing to do. Two years removed from spouse's death, however, may make this difficult, especially if estate was closed or there isn't one. In that case I would suggest seeking out any children.

[jpod]

Don't you also have to contend with the missed payments to the participant?

[fiona1]

15 minutes ago, jpod said:

Don't you also have to contend with the missed payments to the participant?

In this scenario there were no missed payments to the participant. The plan allows a terminated participant to defer their benefit past NRD. The participant died before benefits were required to begin.

And thanks CuseFan for the answer. Makes complete sense and it is certainly in line with the correction principles of the EPCRS which includes restoring the plan to the position it would have been in had the failure not occurred.