"Especially with respect to a severance policy, an ERISA-governed plan must provide that the sponsoring employer has created an 'ongoing administrative program.' By contrast, a one-time calculation of a severance payment using a fixed formula will not qualify as an ERISA-governed plan.... [The] court therefore weighed the following factors: whether the employer's undertaking or obligation requires managerial discretion in its administration; whether a reasonable employee would perceive an ongoing commitment by the employer to provide employee benefits; and whether the employer was required to analyze the circumstances of each employee's termination separately in light of certain criteria." [Okun v. Montefiore Medical Center, No. 11 Civ. 9615 (S.D.N.Y. Sept. 10, 2013)]