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Posthumous QDROs
Chang, Ruthenberg & Long 
[Guidance Overview] Aug. 13, 2008
Excerpt: Over the years a series of cases have held, for various reasons, that a domestic relations order (DRO) assigning benefits to an intended alternate payee could not qualify as a QDRO if the order was entered after the participant's death. Many practitioners concluded that this was the law, although more recent cases have held to the contrary. PPA section 1001 is a wake up call: it is not too late to get a QDRO after the participant has died!
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