I have a new client that received a distribution from their 401K  on Oct 27 and Dec. 8 of 2021. They reported the amount on Form 8915-F for 2021 and to be taxed over 3-years beginning in 2021 also exempt from the 10% early withdrawal penalty. They reported COVID as the Fema number for the Disaster and their reason was due to COVID and being laid off. Disaster Year check for 2020 and distribution/tax year for filing form 8915-F is 2021.

I can't find how this can be reported as a Qualified Disaster retirement Plan Distribution because it was distributed in 2021 and after also the June 25, 2021? I would have reported this as a Early Distribution in 2021 subject to the 10%.

Am I missing something here? thanks