bounds of ERISA preemption in Fort Halifax, holding that a statutorily mandated one-time, lump-sum severance payment to employees upon a plant closure did not require an administrative scheme to administer, and as such did not constitute an employee benefit plan generating the potential for conflicting regulation. 482 U.S. at 12, 107 S.Ct. 2211. The Court reasoned that “Congress intended preemption to afford employers the advantages of a uniform set of administrative procedures gov erned by a single set of regulations!, but this] concern only arises ... with respect to benefits whose provision by nature requires an ongoing administrative program to meet the employer’s obligation.” Id. at 11, 107 S.Ct. 2211; see also Peace v. Am. Gen. Life Ins. Co., 462 F.3d 437, 440-41 (5th Cir.2006) (<HOLDING>). Federal circuit cases addressing the
holding that plan administrator of an erisa health plan did not have to anticipate the confusion of a plan participant 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 the touchstone of determining existence of erisa plan is whether an administrative scheme is required holding that the employer did not have a plan under erisa where no administrative scheme was required to pay the annuity benefit holding that a claimants claim is barred when administrative remedies that are clearly required under an erisa plan are not exhausted