The general IRS rule that a cash distribution from a retirement plan incurs a 10% early withdrawal penalty if the distributee is younger than age 59.5 does not apply to withdrawals from a QDRO account.
But in contrast, a cash withdrawal from an IRA if younger than age 59.5 does incur the 10% early withdrawal penalty.
So in general an Alternate Payee should not roll retirement plan money over to an IRA and then take a cash withdrawal.
Early withdrawal penalties also apply to withdrawals from annuities. And those withdrawals apply even if the distributee is older than age 59.5.