Impermissible Qualified Charitable Distribution from 401(k) Plan as RMD

A participant's RMD for 2018 from a 401(k) plan was calculated as $160,000.  He transfers $100,000 to a charity and takes a taxable distribution of $60,000.  We find out after-the-fact.  How do we fix this now? 

My initial thought is issue 1099-R for a taxable distribution of $160,000 to the participant but curious about other opinions.  Thanks.

Did the 1099 show the whole $160,000 as taxable? 

Taxable distribution to participant of $160,000 and 1099-R for the same, what he did with the proceeds does not impact that. However, if the plan directly transferred the funds to the charity without reporting as taxable distribution to participant, then it likely violated the exclusive benefit rule.

The amounts were transferred directly from plan to charity.  Does it violate the anti-alienation rules?

Sorry to be unable to read between the lines, but did the plan treat the distribution of the $100K as a taxable distribution to the participant?  I infer the negative.  Voluntarily directing delivery of a distribution to a specified payee is not a problem, although it is a courtesy not required of the plan.  Failure to account for a distribution properly on Form 1099-R is a problem. My first thought is to issue a corrected Form 1099-R.  The participant will have to amend the 2018 tax return if it has been filed based on a Form 1099-R showing a distribution of $60K instead of $160K.

2 hours ago, QDROphile said:

Sorry to be unable to read between the lines, but did the plan treat the distribution of the $100K as a taxable distribution to the participant?  

No.  The participant was mistakenly attempting to take advantage of the Qualified Charitable Distribution rules pertaining to IRAs.  Apparently, he was misinformed by the financial advisor.   The plan may have to reissue the 1099-R for the correct higher amount.

So...who prepared the first 1099-R?  I can see how the financial and participant screwed this up, but not quite sure how the $100K was unreported in the first place.

If there was a payment to a payee other than the participant and that payment is not explained by a death, QDRO, other court order, IRS levy, or direct rollover to an eligible retirement plan, do those facts suggest the plan's administrator and the paying or processing service provider should evaluate controls?