or (4) plans that have combinations of any of these three features. In re Hall, 151 B.R. 412, 418 (Bankr.W.D.Mich.1993) (quoting Christy & Skeldon, Shumate and Pension Benefits in Bankruptcy, 2 J.Bankr.L. & Prac. 719, 725 (1992)) (hereinafter “Christy & Skeldon”). Some courts have held that “ERISA qualified” means that a plan satisfies both ERISA and the IRC. However, this approach has been criticized because creditors could reach plan benefits if an employer fails to amend a plan to comply with a change in the tax law. In re Hall, 151 B.R. at 418, n. 17 (quoting Christy & Skeldon at 725). Notwithstanding this possibility, the Hall court held that a plan is “qualified” when it is satisfies both the IRC and ERISA. Id. at 419. See also In re Sirois, 144 B.R. 12, 14 (Bankr.D.Mass.1992) (<HOLDING>); In re Wit-wer, (“ERISA qualified plans are
holding that plan administrator of an erisa health plan did not have to anticipate the confusion of a plan participant holding that a plan is qualified if it complies with erisa and the irc holding that erisa does not preempt the plaintiffs claim that the erisa plan administrator is liable for medical malpractice where the plaintiff premised the claim solely on state law and did not invoke the erisa plan holding that it is not necessary to ascertain whether a plan is tax qualified but only that it is covered by erisa holding that state law relates to an employee benefit plan and is therefore preempted by erisa if it has a connection with or reference to such a plan