It's not guidance from the IRS; it's just the way that this particular 529 plan has elected to process requests from account owners to do 529 to Roth IRA rollovers. That's why I wrote that you should check with your own 529 plan administrator. If they haven't implemented any kind of internal process and are telling account owners that you are on your own, then I guess you will just have to ask for a distribution of not more than $7,000 and once received turn around and deposit an equal amount into a Roth IRA account owned by the 529 beneficiary. Just make sure you keep all the documentation necessary to clearly show the IRS what you did, in case they come knocking later on.