How long to roll 401K distribution

I am helping my 25 year old friend do his 2019 taxes and he got a 1099-R.  He tells me that his former employer closed out his 401K and sent him a check unsolicited for the full amount (only about $200)  He did not realize using the money would be a taxable event with  penalty.  Is it too late for him to open a rollover IRA with the amount of the disbursement in order to avoid taxes and penalty?  He received the disbursement moree than 60 days ago.