benefit plans, the Court recognized that the purpose of ERISA preemption of state law is to create a single set of regulations to govern benefit plans’ complex and ongoing administrative activities. Id. at 8-15, 107 S.Ct. at 2215-19. From the fountain of Fort Halifax, and the stream of circuit court cases that have flowed from it, a relatively simple test has emerged to determine whether a plan is covered by ERISA: does the benefit package implicate an ongoing administrative scheme? See Fort Halifax, 482 U.S. at 12, 107 S.Ct. at 2218 (“The theoretical possibility of a one-time obligation in the future simply creates no need for 'an ongoing administrative program for processing claims and paying benefits.”); Kulinski v. Medtronic Bio-Medicus, Inc., 21 F.3d 254, 257 (8th Cir.1994) (<HOLDING>); James v. Fleet/Norstar Fin. Group, Inc., 992
holding the touchstone of determining existence of erisa plan is whether an administrative scheme is required holding that touchstone in determining whether one act is part of continuing violation is whether employee was put on notice that his rights had been violated holding that a claimants claim is barred when administrative remedies that are clearly required under an erisa plan are not exhausted holding expert testimony was not required where jury is capable of determining existence of duty holding that the employer did not have a plan under erisa where no administrative scheme was required to pay the annuity benefit