In light of the recent nurses’ strike at Brigham and Women’s Hospital, I’ve spent the last week poring through financial and legal documents related to Mass General Brigham (MGB), formerly Partners HealthCare, its arms, its subsidiaries, and its overall financial relationships. I wanted to understand the structure of the organization. I wanted to understand the reasons behind the strike — whether the stance of the Massachusetts Nurses Association (MNA) had any merit or not — and I also wanted to understand the strike from the viewpoint of MGB.¹

Before I begin, I want to let you know that my partner is an award-winning registered nurse at Brigham and Women’s Hospital. We live together. She’s the mother of our four children. I love her, and I’m grateful to have her in my life. If she hadn’t supported me for all these years, I’d probably already be dead.²

I’ve taken the time to investigate these issues as a whole because of my love for her, my respect for all of her coworkers — they’re truly amazing nurses — and my inability, as a maniac with ADHD and OCPD, to rest until I uncover and understand every detail of any project that captures my attention.

The Institution Behind the Strike

Mass General Brigham is the largest private employer in Massachusetts; it employs approximately 85,000 workers.³

Mass General Brigham maintains an extensive real estate footprint across New England; its current corporate headquarters is in Boston, its 800,000-square-foot Assembly Row campus remains in Somerville, and its clinical network reaches across Massachusetts, New Hampshire, Maine, and Rhode Island.⁴

For an organization with that depth and breadth, it’s naturally going to have a web of organizations under its umbrella. The most striking part of this exercise — I just learned that MGB operates a venture capital platform through entities it controls — was the sheer size of the organization; it’s a behemoth. The public record, however, is largely incomplete; I’ve pieced it together using the IRS’s site, the Commonwealth’s site, and many other sites.⁵

The documents I’ve examined number in the thousands; they come from the federal government, the Commonwealth of Massachusetts, and other sources. Due to the limited scope of this post, it’s not practicable to list them all here, but I could make them available to you on request. I’ve done my best to download many of them while keeping the URLs as organized as possible.

I will tell you that I hit a wall with the State of Delaware filings. I decided that I wasn’t going to pay to download and investigate them. Also, I haven’t researched the state filings in Maine, New Hampshire, or Rhode Island.

Since Mass General Brigham is the Commonwealth’s largest employer, I decided to train my focus on its pension plan, which is called the Consolidated Cash Balance Program of Mass General Brigham and Member Organizations (Plan 499). As part of the nurses’ strike, the benefit package — which includes a pension plan — is the part of MGB’s operations that affects those 4,000 nurses most directly. In fact, that pension plan affects more than 90,000 MGB employees, former employees, retirees, and beneficiaries.⁶

As a guy with a financial background, I looked at the breakdown of the assets held for Plan 499 as reported in the MGB ERISA Master Trust’s FY2025 filing. Plan 499’s reported invested assets are pooled in that Master Trust. After reviewing its current value, I’ve learned that the filing reports $9.2 billion of the Master Trust’s $11.5 billion itemized total as partnership and joint venture interests.⁷

Directors Under Contract

Three current Mass General Brigham directors also appear in MGB’s FY2024 Form 990 through transactions involving companies tied to them. John Fish, Jonathan Kraft, and Phillip Ragon each held a board seat while MGB or its affiliates paid Suffolk Construction, NPP Development, NPS LLC, or InterSystems in relationships the filing identifies as involving those directors. Whether MGB applied its stated conflict safeguards — disclosure, recusal, competitive proposals when applicable, and written fair-and-reasonable findings — is not a question the filings answer.⁸

John Fish is a Vice Chair of the Board of Directors at Mass General Brigham and the Chairman and CEO of Suffolk Construction. Across the currently reconciled public filings, Partners HealthCare and Mass General Brigham reported nearly $470 million in construction-related payments to Suffolk Construction. John and Cyndy Fish have given more than $19.3 million to Brigham and Women’s Hospital priorities over the years.⁹

Jonathan Kraft is the son of Robert “Bob” Kraft; he’s currently a Vice Chair of the Board of Directors at Mass General Brigham and the President of The Kraft Group, which identifies private equity and venture investing as one of its core businesses and says its president oversees the day-to-day activities of each operating business. In 2009, Brigham and Women’s Hospital and Massachusetts General Hospital opened a healthcare center at Patriot Place; Brigham opened an additional center there in 2019. In 2011, the Kraft family pledged $25 million to Partners HealthCare to launch the Kraft Center for Community Health. In late 2021, MGB announced that it would expand its Patriot Place footprint in 2022 with a performance and research center. In that same year, Bob and the Kraft Family Foundation gifted $50 million to Massachusetts General Hospital. There are now two Kraft Family Blood Donor Centers; there’s one at Massachusetts General Hospital and another at Dana-Farber Cancer Institute and Brigham and Women’s Hospital. The family’s documented hospital philanthropy dates to 1984, when Robert and Myra Kraft established the Dana-Farber/Brigham blood donor center.¹⁰

Phillip “Terry” Ragon is a Director on the Board of Directors at Mass General Brigham and the Founder and CEO of InterSystems Corporation, a healthcare information systems technology company. InterSystems was founded in 1978 around MUMPS, a programming language developed at Massachusetts General Hospital in the 1960s; MGB’s FY2024 Form 990 reports a products and services transaction, but the scope of its complete billing history is unknown. Since 2009, the Ragons have publicly committed $300 million to the Ragon Institute — a collaboration among MGB, MIT, and Harvard — in addition to an undisclosed gift toward the Phillip and Susan Ragon Building.¹¹

Many of the relationships between Mass General Brigham, its predecessors, and the current and former members of its various arms and boards have run for decades, and many of them have moved money or influence toward the organization, which is commendable.

That overarching pattern doesn’t prove a corrupt bargain, but it does mean the same names recur on both sides of MGB’s ledger often enough that arm’s-length dealing can no longer be assumed — it has to be demonstrated.

Fish, Kraft, and Ragon are all on MGB’s board.

MGB’s own FY2024 Form 990 places Suffolk, NPP Development, NPS LLC, and InterSystems in Schedule L, Part IV: “Business Transactions Involving Interested Persons” — with the relationship fields reading “Director–Fish,” “Director–Kraft,” and “Director–Ragon.”

The disclosed payments total $59.38 million:

• Suffolk / Fish — $48.96 million for construction services
• NPP Development / Kraft — $8.21 million for a lease
• NPS LLC / Kraft — $1.50 million for marketing
• InterSystems / Ragon — $0.71 million for products and services

These were substantial payments made to corporations tied to sitting MGB directors in only one year; this is a non-profit corporation paying companies tied to sitting directors in categories its own tax return identifies as transactions with interested persons.¹²

Pension Managers in the Boardroom

There’s another tier of board member…

After screening current board members, it’s obviously not merely a tight-knit social network:

• Robert Atchinson is a Co-Founder and Managing Director of Adage Capital Management, L.P., the investment manager of Adage Capital Partners, L.P.; the FY2025 Master Trust lists Adage Capital Partners at $797.2 million.
• John Connaughton is Chair of Bain Capital, and Paul Edgerley is a Senior Advisory Partner with the same firm; the FY2025 Master Trust lists Bain at $47.1 million.
• Nitin Nohria is a Partner and Executive Chairman at Thrive Capital; the FY2025 Master Trust lists eight Thrive positions at $74.6 million.
• Carol Vallone is an Industry Advisor to Berkshire Partners whose stated role can include due diligence and investment deliberation; the FY2025 Master Trust lists four Berkshire funds at $9.8 million.

The combined Adage, Bain, Thrive, and Berkshire issuer row basket is $928.6 million, or 8.0% of Schedule H, Part I total assets. Schedule C separately lists eligible indirect compensation disclosures involving Adage Capital Partners, Bain Capital Credit, and Thrive Capital Management without quantifying the full economics. Berkshire is not part of that disclosure.¹³

A sixth current director presents a historical manager relationship: Carmichael Roberts is a Co-Founder and Managing Partner of Material Impact and was formerly a General Partner at North Bridge Venture Partners; the FY2025 Master Trust lists four North Bridge funds at $7.8 million combined. Including that historical relationship, the reported issuer rows total $936.5 million, or 8.1% of Schedule H, Part I total assets. Six current MGB directors therefore have current or former outside affiliations with manager firms whose names appear in the Master Trust’s reported holdings.¹⁴

Three more current directors count toward the board’s investment role count even though their firms do not appear by name in the reviewed FY2025 Master Trust filing. Alexander L. “Lanny” Thorndike is President of Choate Investment Advisors and oversees its investment strategy and day-to-day operations. Benjamin Gomez is Managing Director of Pilot House Associates, a family investment office; a 2025 corporate biography also identifies him as serving on MGB’s Investment Committee. Jason Krantz is the Founder and Managing Partner of Breachway Capital, a venture capital and growth equity firm launched in 2025.¹⁵

There’s also another layer of board members; this one involves Mass General Brigham and Thermo Fisher Scientific.

Scott Sperling is Chairman of MGB’s Board of Directors, a Lead Director at Thermo Fisher, and Co-Chief Executive Officer of Thomas H. Lee Partners, L.P. (THL). Marc Casper is a Director on the MGB Board of Directors and Thermo Fisher’s Chairman and CEO; his company biography states that he began his career at Bain & Company and later joined Bain Capital. Between the two, they wield enormous influence at MGB and Thermo Fisher.

Thermo Fisher does not appear in MGB’s record merely as a vendor; it appears as a research collaborator, the subject of more than $11 million in disclosed product purchases, and the 2025 licensee of MGB-developed ExoTRU technology.

That sequence does not prove preferential treatment, but it establishes that the selection process, licensing terms, disclosure, and recusals are material questions.

Thermo Fisher’s public relationship with the Mass General Brigham system is not a new vendor connection; it reaches back to at least 2002, when its predecessor, Thermo Electron, began a formal research collaboration with Partners HealthCare, equipped the Harvard–Partners Proteomics Facility, and placed a scientist in residence. In 2009, Brigham and Women’s Hospital reported more than $11 million in Thermo product payments on Schedule L, and in 2025, MGB — the successor to Partners HealthCare — announced an ExoTRU diagnostic license to Thermo Fisher. Today, MGB’s Biobank Genomics Core still requires certain Thermo TaqMan assays to be available on demand — the public record traces a continuum from research infrastructure to procurement to commercialization.¹⁶

Diane Patrick, a former Co-Managing Partner of Ropes & Gray LLP’s Boston office and the wife of former Massachusetts Governor Deval Patrick, sits on the MGB Board of Directors. The FY2025 Schedule C for the MGB ERISA Master Trust identifies Ropes & Gray LLP as a legal services provider that was paid $0.23 million. The filing does not specify the depth or scope of the work.¹⁷

Martin “Marty” Walsh deserves attention not principally as a former mayor of Boston, but as a former leader of Laborers’ Local 223 and the Greater Boston Building Trades Council. That background places a construction union leader on a board whose Vice Chair, John Fish, runs Suffolk Construction — the company MGB reported paying $48.96 million for construction in FY2024. The filing does not identify the projects, subcontractors, or union locals involved, but it makes the board’s lack of an identified nurses’ union representative a revealing contrast.¹⁸

MGB’s Twenty-Six Directors

The current MGB board has twenty-six directors. There are three members who have interested person and vendor relationships: Fish, Kraft, and Ragon; that’s 12% of the board. There are twelve members who have current private equity, venture capital, family office, or investment management roles or current or historical affiliations: Sperling, Atchinson, Casper, Connaughton, Edgerley, Gomez, Kraft, Krantz, Nohria, Roberts, Thorndike, and Vallone.

That’s 46% of the board. There are two members who have direct leadership roles at Thermo Fisher, an MGB research, procurement, and licensing counterparty: Sperling and Casper; that’s 8% of the board. There is one director who is a former Co-Managing Partner of Ropes & Gray’s Boston office, a legal services provider to the MGB ERISA Master Trust: Patrick; that’s 4% of the board. There is one director who has led a Massachusetts construction union and a union trade group: Walsh; that’s 4% of the board. Because Sperling, Casper, and Kraft each fall into two categories, those relationships encompass sixteen distinct directors — 62% of the board — including the Chairman and the two Vice Chairmen.¹⁹

Here’s the complete Mass General Brigham Board of Directors list…

• Scott M. Sperling, Chairman
• Robert G. Atchinson
• Marc N. Casper
• John P. Connaughton
• Paul B. Edgerley
• John Fish, Vice Chair
• Benjamin A. Gomez
• Daphne Haas-Kogan, MD
• Karen R. Hale
• David W. Ives
• Reshma Kewalramani, MD
• Anne Klibanski, MD
• Jonathan Kraft, Vice Chair
• Jason Krantz
• Carl J. Martignetti
• Nitin Nohria
• Nawal M. Nour, MD
• Diane B. Patrick
• Phillip T. Ragon
• Carmichael S. Roberts
• James D. Taiclet
• Alexander L. Thorndike
• Carol Vallone
• Martin J. Walsh
• Pratt N. Wiley
• Anne M. Wilkins

With the Board of Directors identified, the financial statements reveal the size and composition of the institution that those directors oversee.

A few questions arise… Does the current board steward the organization with full fiduciary fidelity? If not, are there conflicts? If there are conflicts, have some of them been unnecessarily created by commingling personal and professional silos? The questions may continue to multiply…

ERISA makes fiduciary duty a legal obligation, not ceremonial language. Anyone entrusted with control over pension assets must place the participants’ interests first. Whoever is unwilling to accept that obligation has no business exercising that control.

Plan 499: The Master Trust

For Mass General Brigham employees, the pension plan is of utmost importance. All eligible employees earn an employer-funded retirement benefit throughout their careers. MGB calculates annual pay credits according to each employee’s age and years of service, places those credits into a hypothetical cash balance account, and applies a separate formula that determines each employee’s annual pension growth rate.²⁰

The Consolidated Cash Balance Program of Mass General Brigham and Member Organizations — Plan 499 — is a defined benefit pension plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), and Plan 499’s FY2024 financial statements say that “the assets of the Plan are pooled and invested in the Master Trust” and report that Plan 499 held a 100% interest in the Master Trust’s net assets as of September 30, 2024. MGB’s FY2025 audit reports $11.586 billion in defined benefit plan assets, while the FY2025 Master Trust filing reports $11.586 billion in net assets — balances that reconcile at the audit’s presentation scale. Plan 499 determines the promises made to employees; the MGB ERISA Master Trust is the investment pool through which the assets of their pension plan are deployed.²¹

As of September 30, 2025, MGB reported $11.586 billion in defined benefit pension assets against $9.292 billion in benefit obligations — a funded surplus of $2.294 billion.²²

Those two structures file separate annual Form 5500 reports. Plan 499’s filing describes the benefit program and its participants, while the Master Trust’s filing reports the pooled investments. The separate filings keep those two numbers off the same page; the table below is what puts them where they belong.

I’ve created a table using data from MGB’s audited financial statements and Plan 499 records over the past ten years. This is the inflection point. This is where a Massachusetts Nurses Association fight turns into a systemwide fight.

The following table compares the Master Trust’s fiscal-year return ratios with the calendar-year pension growth rates assigned to Plan 499 accounts over the past ten years.

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One Pension Pool. Two Growth Measures.
Plan 499 Calendar-Year Pension Growth Rate Compared with the MGB ERISA Master Trust Fiscal-Year Return Ratio

Ending Year	Plan 499 Calendar-Year Pension Growth Rate	Master Trust Fiscal-Year Return Ratio	Master Trust – Plan 499 Spread
2016	+5.00%	+8.68%	+3.68%
2017	+5.00%	+15.05%	+10.05%
2018	+5.00%	+7.00%	+2.00%
2019	+5.00%	+3.88%	−1.12%
2020	+5.00%	+11.97%	+6.97%
2021	+5.00%	+29.03%	+24.03%
2022	+5.00%	−14.67%	−19.67%
2023	+5.00%	+8.78%	+3.78%
2024	+6.44%	+17.08%	+10.64%
2025	+5.04%	+14.78%	+9.74%
10-Year Average	+5.15%	+10.16%	+5.01%
$100 Compounding Illustration (FY2016–FY2025)	$165.19	$250.46	≈ $85.28 difference
$4.33 Billion Asset-Scale Illustration (FY2016–FY2025)	$7.16 billion	$10.85 billion	≈ $3.69 billion difference

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The table exposes MGB’s financial design: nearly $3.69 billion of illustrated upside separates the Master Trust’s compounded return path from the pension growth assigned to Plan 499 accounts.

MGB uses Plan 499’s pension assets to pursue higher returns through higher-risk investments inside the Master Trust while limiting employee accounts to a bounded formula based on Treasury bills. When the Master Trust return exceeds the annual pension growth rate assigned to employees, the additional growth remains in the Master Trust. The unbalanced growth is not being proportionately added to employee accounts, even though their promised retirement benefits are the reason the $11.6 billion investment pool exists.

In practical terms, MGB has structured the MGB ERISA Master Trust to pursue returns that can far exceed the annual pension growth rate assigned to Plan 499 employee accounts.

The One-Year Treasury Bill Formula

MGB’s public-facing description is incomplete. The company’s careers page advertises that employee accounts earn interest guaranteed to be at least 5%, but it does not identify that minimum as the floor of a bounded formula; it omits the 12% cap and the one-year Treasury bill formula. Employees do not receive the Master Trust return.

Plan 499 calls the annual growth applied to each hypothetical employee account an “interest credit.” In this context, credit has nothing to do with borrowing money or using a credit card; it is an accounting entry that increases the employee’s pension balance. A credit card — or, more formally, a credit account — extends borrowed purchasing power to a qualified holder, whereas a pension interest credit is an accounting increase applied to a qualified employee’s hypothetical pension balance.

MGB calculates the annual pension growth rate using the following formula:

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T = the one-year Treasury bill rate for September of the previous year.

In plain language:

1. We take the one-year Treasury bill rate for September of the previous year.
2. We add one percentage point.
3. If the result is below 5%, we raise it to the 5% floor.
4. If the result falls between 5% and 12%, we use it as calculated.
5. If the result is above 12%, we reduce it to the 12% cap.

• Below the Floor: If the prior September’s one-year Treasury bill rate is 2.5%, MGB adds 1%, producing 3.5%. The 5% floor raises the employee’s interest credit to 5%.
• Exactly at the Midpoint: If the Treasury bill rate is 7.5%, MGB adds 1%, producing an 8.5% interest credit — exactly halfway between the 5% floor and the 12% cap.
• Above the Cap: If the Treasury bill rate is 12.5%, MGB adds 1%, producing 13.5%. The 12% cap reduces the employee’s interest credit to 12%.²⁴

The WTW Comparison

A point of order…

The Master Trust states its assets on two surfaces: Schedule H, Part I reports the top-level totals, while Page 126 — the Schedule H, Line 4i attachment — itemizes the holdings reported by issuer and vehicle. This examination uses Page 126’s itemized total when calculating its line-item percentages. Part I reports total assets roughly $140 million higher, and the public filing does not explain that reconciliation difference; partnership and joint venture interests represent 80.0% of Page 126’s itemized current value and 79.0% of Part I total assets.

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Page 126 of the FY2025 Form 5500 classifies 80% of its itemized current value as partnership and joint venture interests. By contrast, the annual pension growth rate assigned to employees comes from a bounded formula based on one-year Treasury bills. Only 2.2% of Page 126’s itemized current value is tied to U.S. government securities; partnership and joint venture interests outweigh those securities by more than 36 to 1.²⁵

The systemic risk tied to the private equity and other leveraged, illiquid strategies held through many partnership and joint venture vehicles dwarfs the systemic risk tied to one-year Treasury bills. At the macroeconomic level, their systemic risk profiles operate in opposite directions: one-year Treasury bills function as shock absorbers, while illiquid alternative investments using high leverage can function as shock amplifiers. When the financial system begins to collapse, money runs toward one-year Treasury bills, while contagion can spread through leveraged and illiquid alternatives.

In other words, the Master Trust is making bets that should never be tied to an employee pension plan at the rate those bets are being made. Willis Towers Watson (WTW), the actuary for Plan 499, published “2023 Asset Allocations in Fortune 1000 Pension Plans,” which examined 418 Fortune 1000 defined benefit sponsors. WTW divides pension assets among four broad classifications: cash, public equity, debt, and alternatives; this analysis applies those classifications to Page 126’s reported line items exactly as MGB filed them; it does not look through or reclassify the investment vehicles.

WTW and its predecessor firms have served as the plan’s actuary since before 2014 — a relationship MGB itself acknowledged in a 2020 federal court filing. Plan 499’s FY2024 Schedule C reports $434,428 in direct actuarial compensation paid to WTW. A WTW-enrolled actuary signed Plan 499’s FY2025 Schedule SB. That schedule reports the plan’s actuarial value of assets, funding target, target normal cost, funded percentage, and minimum required contribution and requires certification by an enrolled actuary. WTW is not an outside commentator on this pension structure; it is the paid actuarial firm whose enrolled actuary signed the plan’s federal funding schedule after the firm had served as plan actuary for more than a decade.²⁶

WTW’s study found that alternative investments averaged 10.3% across Fortune 1000 plans, 13.2% among larger plans, and 17.9% on an asset-weighted basis. Page 126 reports $949.4 million — 8.3% of its itemized current value — in the line items corresponding to WTW’s cash, public equity, and debt classifications: interest-bearing cash, U.S. government securities, corporate debt, corporate stock, and mortgage loans. The remaining three reported line items — partnership and joint venture interests, common and collective trusts, and registered investment companies (RICs) — total $10.50 billion, or 91.7%. Under WTW’s classifications applied to Page 126, 91.7% is the Master Trust’s alternative allocation. Those partnership and joint venture interests alone account for almost 80% of Page 126’s itemized current value.

As Plan 499’s paid actuary, has WTW warned MGB that the Master Trust’s alternative allocation, measured from Page 126’s reported line items under WTW’s classifications, is between 5.1 and 8.9 times every benchmark presented in WTW’s own study — and that partnership and joint venture interests constitute almost four-fifths of Page 126’s itemized current value?

WTW’s Reported Benchmarks:

Overall Alternative Allocation Under WTW’s Classifications Applied to Page 126 — 91.7%

• Fortune 1000 Average: 91.7% versus 10.3% — 790.3% higher, or 8.9× (81.4 ÷ 10.3 × 100 = 790.3%).
• Large-Plan Average: 91.7% versus 13.2% — 594.7% higher, or 6.9× (78.5 ÷ 13.2 × 100 = 594.7%).
• Asset-Weighted Allocation: 91.7% versus 17.9% — 412.3% higher, or 5.1× (73.8 ÷ 17.9 × 100 = 412.3%).

Partnership and Joint Venture Interests Alone — 80.0%

• Fortune 1000 Average: 80.0% versus 10.3% — 676.7% higher, or 7.8× (69.7 ÷ 10.3 × 100 = 676.7%).
• Large-Plan Average: 80.0% versus 13.2% — 506.1% higher, or 6.1× (66.8 ÷ 13.2 × 100 = 506.1%).
• Asset-Weighted Allocation: 80.0% versus 17.9% — 346.9% higher, or 4.5× (62.1 ÷ 17.9 × 100 = 346.9%).²⁷

The differences are eye-popping.

Jeff Levin-Scherz is a WTW managing director and its North American Population Health Leader, advising large employers on health benefits strategy. Earlier in his career, he served as chief medical officer of Partners Community HealthCare. The WTW–MGB history therefore includes more than the actuarial engagement: one of WTW’s senior health benefits executives previously occupied a leadership position inside the Partners system. This is not an indictment of Levin-Scherz. In the past few days, I’ve come across hundreds of names that seem to circle around Mass General Brigham at a high level; its directors, current and former executives, investment managers, advisers, vendors, and donors form a remarkably tight institutional orbit in which the same people and firms keep reappearing in different roles.²⁸

When we think of personal retirement plans, we may think of steady investments with low to medium risk that aim to meet or beat a benchmark like the S&P 500. As part of those personal retirement plans, we may think of indexed annuities. Those annuity accounts can protect owners from the market’s worst losses while limiting participation during its strongest gains. Such contracts can use an interest crediting formula to determine the annual increase: a floor establishes the minimum credited rate, while a cap establishes the maximum. When we think of personal retirement accounts, we do not usually think of private equity, hedge funds, and partnership and joint venture interests consuming four-fifths of the investment pool; we certainly do not expect those investments to generate returns for the pension fund while our own accounts remain bound to a Treasury bill formula with a fixed floor and cap.

MGB’s structure raises a brutal question: when the Master Trust earns more than the annual pension growth rate assigned to employee accounts, who ultimately benefits from the resulting pension spread?

As the table illustrates, applying the two compounded growth paths to the Master Trust’s FY2016 opening assets produces a ten-year difference of $3.69 billion — the equivalent of $60,900 per active Plan 499 participant. That figure is not an accounting of benefits owed to individual employees under the terms of Plan 499. The underlying divide is real: employees receive the pension growth rate established by MGB’s bounded formula, not a proportionate share of the Master Trust’s investment returns.²⁹

Plan 499 participants’ hypothetical balances receive 100% of their annual interest credits through a bounded formula based on one-year Treasury bills. By contrast, only 2.2% of Page 126’s itemized current value is invested in U.S. government securities, while three reported line items — partnership and joint venture interests, common and collective trusts, and registered investment companies (RICs) — account for 91.7% of that itemized current value. That divergence makes the Master Trust’s governing duties impossible to separate from its investment strategy.

Asset Liability Matching

The Legal Framework

I’m about to get into some technical ideas, and it’s going to be boring, but it’s essential reading. The underlying legal tenets of pension plan governance, administration, fiduciary duties, investment oversight, prohibited transactions, reporting, and enforcement determine what MGB may do with the Master Trust; they are the rules against which every allocation, relationship, and unanswered question must be measured. Once those rules are understood, the Master Trust’s investment structure can be appropriately judged against the law.

ERISA establishes federal rules for most private-sector pension and retirement plans and many employer-sponsored health, disability, and life benefit plans; its requirements govern plan sponsors, administrators, and fiduciaries; service providers can also fall within its disclosure, prohibited transaction, and fiduciary rules depending on their functions and relationships to a plan.

ERISA protects plan participants through a federal framework administered by more than one agency. The Department of Labor’s Employee Benefits Security Administration (EBSA) administers and enforces Title I’s fiduciary, reporting, and disclosure provisions; the Internal Revenue Service (IRS) and Pension Benefit Guaranty Corporation (PBGC) have separate responsibilities under other provisions. Martin “Marty” Walsh, a current director on the MGB Board of Directors and Executive Director of the National Hockey League Players’ Association (NHLPA), was the 29th U.S. Secretary of Labor.

Because they are plan assets, those allocations sit directly within ERISA’s fiduciary framework and the principles underlying Asset Liability Matching (ALM). ERISA’s prudence and diversification duties require pension fiduciaries to evaluate a portfolio in relation to the plan’s obligations, including its liquidity, anticipated cash flow needs, and funding objectives — not simply by its potential returns. ALM is one financial discipline that can put those protections into practice; ERISA does not mandate a particular ALM or Liability Driven Investment (LDI) model.

Asset Liability Matching (ALM) is a risk management strategy focused on coordinating an institution’s investment assets with its future payment obligations. Under a total return mandate, the primary objective is earning investment returns within stated risk limits. Under ALM, asset choices are evaluated against the timing and sensitivity of the liabilities, with the goal of protecting funded status and improving the likelihood that sufficient assets will be available as those liabilities fall due.

In pension and retirement plan management, ALM addresses the core challenge of mismatched timing and sensitivity between assets and liabilities; if a plan has a large benefit payment due in ten years, a portfolio dominated by volatile or illiquid investments whose cash flows do not align with that obligation creates a mismatch that can contribute to a funding shortfall.

All pension managers can use several ALM methods to reduce mismatch risk; three common techniques follow.

Primary ALM Techniques

Cash Flow Matching: Dedicated Portfolios

This is the most direct matching approach: the portfolio manager selects zero-coupon bonds or high-quality fixed-income securities whose maturity dates and coupon payments exactly coincide with the projected pension payout schedule. If the plan owes retirees $10 million in November of a given year, the manager structures a bond ladder so that exactly $10 million in principal and interest matures in that same month. Exact matching sharply reduces timing and reinvestment risk, but it does not eliminate default risk or prevent market values from moving before maturity.

Duration Matching Through Portfolio Immunization

When matching exact cash flows is too expensive or impractical, managers turn to duration matching. Under that approach, duration measures a portfolio’s sensitivity to changes in interest rates. Because pension liabilities resemble long-duration bond obligations, falling discount rates increase the present value of future benefits and threaten the plan’s funded status. By building an asset portfolio with approximately the same interest rate sensitivity as its liabilities, managers can reduce volatility in funded status when rates move modestly. Even then, the protection depends on assumptions about the yield curve and convexity, and the portfolio must be rebalanced as time passes and market conditions change.

Contingent Immunization Strategy

This is a hybrid strategy used to capture higher returns while maintaining a safety net. The manager actively manages the portfolio as long as the plan maintains a predetermined surplus (a “safety margin”). If market downturns or interest rate shifts cause the surplus to shrink to a critical trigger point, predetermined rules call for shifting the portfolio toward an immunized strategy designed to preserve enough value to meet the liabilities.

The ALM Principle

These techniques align return-seeking with the timing and amount of promised benefit payments.³⁰

The Risks Inside the Allocation

Out of Page 126’s itemized current value of approximately $11.45 billion, a staggering $9.16 billion — roughly 80% — is reported as partnership and joint venture interests. When grouped with common and collective trusts — $666.9 million — and registered investment companies — $675 million — those three reported line items account for 91.7% of the itemized total under WTW’s classifications applied to Page 126. The sharper risk facts inside that allocation are the $9.16 billion partnership and joint venture line, MGB’s audited 32.9% private equity allocation, and $1.243 billion in unfunded defined benefit commitments.

Because the MGB ERISA Master Trust reports an exceptionally large concentration in partnership and joint venture interests, several critical operational, legal, and financial issues arise.

The Valuation Problem

Unlike public equities or government bonds, many private partnership and joint venture interests do not have daily, publicly quoted market prices. MGB’s audited statements report that $10.219 billion in defined benefit assets held through private partnerships and commingled funds was measured using net asset value (NAV) as a practical expedient; for the plan sponsor, this introduces intense valuation scrutiny. Those plan fiduciaries remain responsible for ensuring that the reported values are determined prudently, while the annual audit must obtain sufficient evidence supporting those values; the public filing does not reveal the depth of any look-through testing performed on the underlying partnerships.

Liquidity and Cash Flow Mismatches

Many private partnerships are illiquid and can restrict an investor’s ability to withdraw capital on demand; in a pension plan, those restrictions directly affect Asset Liability Matching (ALM) strategies. If benefit payments rise unexpectedly, the plan may be unable to liquidate private fund interests quickly without accepting secondary market discounts. Consequently, the plan must maintain enough liquid assets and dependable distributions to meet immediate obligations.

The ERISA Prudent Man Standard

Under ERISA Section 404, plan fiduciaries are legally required to diversify plan investments to minimize the risk of large losses unless, under the circumstances, it is clearly prudent not to do so. A reporting of approximately 80% of Page 126’s itemized current value as partnership and joint venture interests makes the underlying diversification, liquidity, leverage, valuation, and manager exposures essential to any prudence analysis. MGB’s fiduciaries must therefore be able to document the process used to evaluate those risks, the plan’s cash flow needs, and the diversification within and across the underlying strategies.³⁰

The Missing Policy

MGB’s audited financial statements define the Master Trust’s objective as achieving “the highest reasonable total return” after considering plan liabilities, funding status, projected cash flows, market assumptions, and MGB’s ability and willingness to incur market risk. They separately state that the Investment Committee of MGB’s Board of Directors oversees pension assets and seeks incremental returns through external manager selection and asset allocation within allowable ranges. I have not found the Investment Policy Statement (IPS) defining those ranges or any Asset Liability Matching (ALM) or Liability Driven Investment (LDI) framework governing the Master Trust. Whether MGB has conducted a formal ALM study or operates an LDI program cannot be ascertained from the public record. Without those documents, the public cannot compare the Master Trust’s allocation with the policy governing it or determine how that policy accounts for Plan 499’s liabilities.³¹

ERISA’s Measuring Stick

The Responsible Actors

The inquiry therefore begins by identifying the responsible actors. Section 3 defines fiduciaries, administrators, service providers, employers, and other parties connected to transactions involving plan assets. ERISA uses those definitions to establish the legal cast of characters for everything that follows.

ERISA Section 3: Definitions

ERISA defines the actors governed by its fiduciary and prohibited transaction rules.

• Fiduciary (Section 3(21)(A)): “a person is a fiduciary with respect to a plan to the extent (i) he exercises any discretionary authority or discretionary control respecting management of such plan or exercises any authority or control respecting management or disposition of its assets, (ii) he renders investment advice for a fee or other compensation, direct or indirect, with respect to any moneys or other property of such plan, or has any authority or responsibility to do so, or (iii) he has any discretionary authority or discretionary responsibility in the administration of such plan”.
• Plan Fiduciaries and Officials as Parties in Interest (Section 3(14)(A)): “any fiduciary (including, but not limited to, any administrator, officer, trustee, or custodian), counsel, or employee of such employee benefit plan”.
• Service Providers as Parties in Interest (Section 3(14)(B)): “a person providing services to such plan”.
• The Employer as a Party in Interest (Section 3(14)(C)): “an employer any of whose employees are covered by such plan”.
• Specified Officials as Parties in Interest (Section 3(14)(H)): “an employee, officer, director (or an individual having powers or responsibilities similar to those of officers or directors), or a 10 percent or more shareholder directly or indirectly, of a person described in subparagraph (B), (C), (D), (E), or (G), or of the employee benefit plan”.

Section 3 establishes that ERISA responsibility follows function, not merely title. ERISA assigns fiduciary status through authority or control over the plan or its assets, compensated investment advice, or administrative responsibility; it separately places the employer, plan insiders, and service providers within its broad definition of a party in interest. Section 3, therefore, identifies the people and organizations whose authority, relationships, and transactions must be examined throughout the Master Trust.

ERISA Section 402: Establishment of Plan

Section 402 establishes the written governance structure of an employee benefit plan.

• Written Instrument and Named Fiduciaries (Section 402(a)(1)): “Every employee benefit plan shall be established and maintained pursuant to a written instrument. Such instrument shall provide for one or more named fiduciaries who jointly or severally shall have authority to control and manage the operation and administration of the plan.”
• Funding Policy (Section 402(b)(1)): Every plan must “provide a procedure for establishing and carrying out a funding policy and method consistent with the objectives of the plan and the requirements of this subchapter.”
• Allocation of Responsibilities (Section 402(b)(2)): Every plan must “describe any procedure under the plan for the allocation of responsibilities for the operation and administration of the plan.”

Section 402 makes that authority traceable. MGB’s governing documents must identify the named fiduciaries, provide the procedure for establishing and carrying out the funding policy, and describe the procedure for allocating responsibility for operating and administering the plan. MGB’s governing documents should also identify the decision-makers responsible for setting the Master Trust’s investment policy, selecting and monitoring its managers, and maintaining ERISA compliance.

ERISA Section 403: Establishment of Trust

ERISA Section 403 governs the trust that holds pension plan assets and establishes the purposes those assets may serve.

• Trust Requirement and Trustee Authority (Section 403(a)): “Except as provided in subsection (b), all assets of an employee benefit plan shall be held in trust by one or more trustees. Such trustee or trustees shall be either named in the trust instrument or in the plan instrument described in section 1102(a) of this title or appointed by a person who is a named fiduciary, and upon acceptance of being named or appointed, the trustee or trustees shall have exclusive authority and discretion to manage and control the assets of the plan,” subject to the following two provisions.
• Directions From a Named Fiduciary (Section 403(a)(1)): Trustees may be “subject to proper directions of such fiduciary which are made in accordance with the terms of the plan and which are not contrary to this chapter.”
• Delegation to Investment Managers (Section 403(a)(2)): “authority to manage, acquire, or dispose of assets of the plan” may be delegated to one or more investment managers under Section 402(c)(3).
• Exclusive-Purpose and Anti-Inurement Rule (Section 403(c)(1)): “the assets of a plan shall never inure to the benefit of any employer and shall be held for the exclusive purposes of providing benefits to participants in the plan and their beneficiaries and defraying reasonable expenses of administering the plan”.

Section 403 establishes a boundary: pension plan assets cannot be treated as MGB’s corporate capital or deployed for the purpose of advancing MGB’s separate institutional interests. That distinction sharpens the question surrounding MGB’s investment relationships: not merely whether the Master Trust earned more than employee accounts received, but whether any investment decision, manager relationship, or transaction caused pension assets to serve MGB’s separate interests. MGB’s investment map matters because any connection between Master Trust assets and MGB’s separate institutional interests must be measured against that boundary.

ERISA Section 404: Fiduciary Duties

Section 404 requires a fiduciary to discharge its duties “solely in the interest of the participants and beneficiaries” and establishes five responsibilities:

• Providing Benefits (Section 404(a)(1)(A)(i)): “providing benefits to participants and their beneficiaries”.
• Reasonable Expenses (Section 404(a)(1)(A)(ii)): “defraying reasonable expenses of administering the plan”.
• Prudence (Section 404(a)(1)(B)): Acting “with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent man acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims.”
• Diversification (Section 404(a)(1)(C)): Acting “by diversifying the investments of the plan so as to minimize the risk of large losses, unless under the circumstances it is clearly prudent not to do so.”
• Plan Documents (Section 404(a)(1)(D)): Acting “in accordance with the documents and instruments governing the plan insofar as such documents and instruments are consistent with the provisions of this subchapter and subchapter III.”

Section 404 prevents MGB from establishing prudence through investment performance alone. MGB’s fiduciaries must act solely for participants, follow a prudent process, diversify against large losses, obey the governing documents, and monitor the investments they retain. MGB cannot cure an imprudent process or disloyal purpose merely by earning a profit.

ERISA Section 406(a): Transactions Between a Plan and a Party in Interest

The provisions of Section 406(a) most relevant to this inquiry state that a fiduciary shall not cause a plan to enter a transaction if the fiduciary “knows or should know” that the transaction constitutes a direct or indirect:

• Section 406(a)(1)(A): “sale or exchange, or leasing, of any property between the plan and a party in interest”.
• Section 406(a)(1)(C): “furnishing of goods, services, or facilities between the plan and a party in interest”.
• Section 406(a)(1)(D): “transfer to, or use by or for the benefit of a party in interest, of any assets of the plan”.

The Master Trust’s manager relationships belong inside that inquiry.

ERISA Section 406(b): Transactions Between a Plan and a Fiduciary

Section 406(b) separately provides that a fiduciary shall not:

• Section 406(b)(1): “deal with the assets of the plan in his own interest or for his own account”.
• Section 406(b)(2): “in his individual or in any other capacity act in any transaction involving the plan on behalf of a party (or represent a party) whose interests are adverse to the interests of the plan or the interests of its participants or beneficiaries”.
• Section 406(b)(3): “receive any consideration for his own personal account from any party dealing with such plan in connection with a transaction involving the assets of the plan”.

Section 406 draws two related boundaries. Section 406(a) governs transactions between the plan and the broad category of parties in interest. Section 406(b) governs fiduciaries using their authority for themselves, representing adverse interests, or receiving personal consideration.

Section 408 provides exemptions for certain transactions otherwise prohibited by Section 406, including necessary services furnished under reasonable arrangements for no more than reasonable compensation. Those exemptions do not erase Section 404’s fiduciary duties, and the ordinary service provider exemption under Section 408(b)(2) does not protect against fiduciary self-dealing prohibited by Section 406(b). For any transaction that Section 406 otherwise prohibits, MGB must therefore identify the applicable exemption and demonstrate that every condition was satisfied.

MGB’s ERISA obligations therefore converge on the MGB ERISA Master Trust. MGB must identify the responsible fiduciaries and parties in interest, demonstrate a prudent process governed exclusively by participant interests, and account for every direct or indirect transaction involving pension assets. If any Master Trust allocation, manager relationship, or transaction caused pension assets to serve MGB or another party in interest, the legal question extends beyond an unusual investment strategy to a potential violation of ERISA’s trust, fiduciary duty, and prohibited transaction provisions.³²

Enforcement in Boston

As we continue, I want to remind you that the name of the Master Trust is “MGB ERISA Master Trust,” which comes directly from the first page of its FY2025 federal Form 5500. MGB does not bury ERISA in a footnote; the law appears inside the Master Trust’s formal name. ERISA provides the measuring stick for every Master Trust transaction.

A measuring stick implies a firm and unwavering hand. For ERISA, that hand has a name — the Employee Benefits Security Administration (EBSA), the arm of the U.S. Department of Labor that enforces ERISA’s Title I protections. EBSA sorts what it finds into two piles, and it is worth understanding each pile.

The civil side of enforcement does not depend on any one participant filing a complaint: ERISA authorizes investigation of actual or potential violations, and a participant complaint is one route by which information can reach EBSA. If an investigation reveals a civil violation, EBSA seeks correction and promotes voluntary compliance whenever possible. When voluntary compliance is not achieved, EBSA may send a litigation recommendation to the Solicitor of Labor. The remedies are not gentle: through voluntary compliance, settlement, or litigation, the Department can seek restoration of plan losses, disgorgement of improper profits, reversal of prohibited transactions, removal of fiduciaries, and injunctions barring individuals from future fiduciary service. I’m not able to prove any case because I don’t have the power of subpoena, but the facts established here ask the Department to look.

The criminal side of enforcement raises the stakes because EBSA investigates ERISA’s criminal provisions and Title 18 offenses involving employee benefit plans. EBSA investigators contact the appropriate United States Attorney’s Office early in a criminal investigation, and U.S. Attorneys’ Offices handle any resulting prosecution. Those investigations have put plan officials, corporate officers, and service providers under indictment. I want to be precise: I don’t know that any of MGB’s actions have been criminal, but the machinery needed to investigate that possibility exists; whether the federal government moves is neither mine to forecast nor the point.

The part that matters for the ninety thousand people whose retirement rides on the Master Trust is this: none of it lives only in Washington, D.C., and none of it runs on any one person’s political post. The office serving New England participants sits in Boston — EBSA is located in the JFK Federal Building on Sudbury Street, right across the street from District A-1 of the Boston Police Department. EBSA investigators and auditors conduct the agency’s investigations, the Office of the Solicitor of Labor has primary responsibility for civil ERISA litigation, and U.S. Attorneys’ offices handle criminal prosecutions. Any participant can call the Department at (866) 444-3272 or contact the Boston Regional Office about an ERISA pension plan. Those routes remain available no matter who sits on MGB’s Board of Directors.³³

The Boardroom Without a Nurse

The questions I am left with are not rhetorical, and they are not only my questions. They should be the questions of everyone who’s ever been a participant in a pension or retirement plan. They are also the questions an EBSA examiner could put to this structure, each one measured against a duty ERISA already names:

• What prudent, documented process produced an 80% concentration in Page 126’s partnership and joint venture line while MGB’s audited statements report 32.9% in private equity and $1.243 billion in unfunded commitments — and where is the analysis that justified it under Section 404?
• Who are the named fiduciaries actually exercising authority over the Master Trust, and what conflict and recusal controls apply when their own financial interests enter the room?
• Did MGB apply its own conflict policy — the competitive proposals, the recusals, the written fair-and-reasonable determinations — to the Master Trust’s manager selections and renewals, and if it did, why is none of it public?
• When a manager whose funds the Master Trust holds also has ties to a director, an MGB fund, or an MGB licensee, which body reviewed that overlap? Who recused, and where is the record showing how Section 406 and MGB’s own policy were satisfied?
• Whose interests did each of those decisions finally serve — the participants the laws name, or the institution that selected the managers and controlled separate investment and licensing programs?

I go back, finally, to the boardroom above these decisions.

I count all twenty-six chairs. The board found room for a large bloc of finance professionals — including five directors tied through current public records to four manager platforms representing $928.6 million of Master Trust assets — room for a former First Lady of the Commonwealth who was a partner at one of the state’s most powerful law firms, room for captains of industry and a full measure of prestige. That board found room for exactly one voice that’s been attached to organized labor, but it found no room for a nurse from the Massachusetts Nurses Association.

That one labor voice is worth naming because he’s the hinge that encompasses this issue. Martin “Marty” Walsh sits on this board — a former mayor of Boston, and before that a Laborers’ Union Local 223 President and later the General Agent of the Boston Building Trades Council. He was also the 29th Secretary of Labor of the United States. From 2021 to 2023, he ran the department that houses EBSA, the office I just spent time describing; he led the department responsible for enforcing ERISA’s Title I protections. If we do the math, MGB’s board — above the committee that oversees its ERISA pension assets — found a chair for the man who recently ran ERISA’s enforcer and represented construction labor, while its Vice Chair’s construction company received the largest interested person payment reported on MGB’s FY2024 Form 990; it found no chair at all for the nurses whose retirement assets the Master Trust supports. I will not tell you what that arrangement means. I will only ask why a board facing these questions is built to look like an answer to them.³⁴

I opened this piece by telling you that my partner — I generally refer to her as my wife these days — has saved me from certain death. I meant it literally: she kept me alive while I was abusing alcohol, and her tough love helped me to finally quit that addiction more than ten years ago. So when I traced the pension pool supporting her retirement benefit and found it run this way — four-fifths of Page 126’s itemized current value is reported as partnership and joint venture interests while her own pension growth is pinned to a formula based on Treasury bills — the reading stopped being a project. My wife is an award-winning neonatal intensive care unit (NICU) nurse at Brigham and Women’s, and she is one of the ninety thousand participants and beneficiaries of Plan 499. Every single question I’ve asked is, in the end, one question about whether the retirement she has earned will be there when she reaches the end of her career.

The nurses outside Brigham and Women’s Hospital (BWH) carried signs decrying working conditions while demanding competitive wages, affordable health insurance, and greater investment in permanent staffing. Those signs were raised far away from the office building where a pool of money with their names on it is overseen by a board with room for everyone but them. That pool is governed by a law written into its own title, and the law is enforced by an office reached by a direct Green Line ride from Brigham Circle Station to Government Center Station. So, I’m asking all Mass General Brigham employees to reach out to the Boston office of the U.S. Department of Labor’s Employee Benefits Security Administration. My wife is only one nurse among more than ninety thousand participants and beneficiaries who rely on Plan 499’s continued solvency and on the assets held in the MGB ERISA Master Trust to support the plan’s promised benefits, and every one of them deserves an answer.³⁵

1. Massachusetts Nurses Association, Brigham Nurses Return to Patients Following Historic Strike and Lockout, July 13th, 2026; Brigham and Women’s Hospital, Nursing Union Updates; Jonathan Bowen, Kate Higgins’ Keynote at the 2015 Brigham and Women’s Partners in Excellence Awards, January 13th, 2015; Brigham Bulletin, 19th Annual Partners in Excellence Awards at BWH, February 5th, 2015; Massachusetts Bay Transportation Authority, Green Line E schedule. The MNA describes a one-day strike followed by a four-day employer lockout and identifies the nurses’ demands as competitive wages, affordable health insurance, and greater investment in permanent nurses. BWH’s page presents the hospital’s account of the work stoppage and bargaining. The award records identify Kate Higgins as a Brigham NICU nurse and Partners in Excellence speaker or honoree. The Green Line E serves both Brigham Circle and Government Center without a transfer; temporary service changes may affect any particular trip. ↩︎
2. Massachusetts Nurses Association, Brigham Nurses Return to Patients Following Historic Strike and Lockout, July 13th, 2026; Brigham and Women’s Hospital, Nursing Union Updates; Jonathan Bowen, Kate Higgins’ Keynote at the 2015 Brigham and Women’s Partners in Excellence Awards, January 13th, 2015; Brigham Bulletin, 19th Annual Partners in Excellence Awards at BWH, February 5th, 2015; Massachusetts Bay Transportation Authority, Green Line E schedule. The MNA describes a one-day strike followed by a four-day employer lockout and identifies the nurses’ demands as competitive wages, affordable health insurance, and greater investment in permanent nurses. BWH’s page presents the hospital’s account of the work stoppage and bargaining. The award records identify Kate Higgins as a Brigham NICU nurse and Partners in Excellence speaker or honoree. The Green Line E serves both Brigham Circle and Government Center without a transfer; temporary service changes may affect any particular trip. ↩︎
3. Mass General Brigham, Anne Klibanski, Chris Coburn, and Mass General Brigham Ventures — About. MGB describes itself as Massachusetts’s largest private employer, with approximately 85,000 employees and $22 billion in annual revenue. Its official biographies say that its innovation platform has helped create more than 300 companies, employs a 140-person business-development group, and includes a venture fund approaching $500 million. The Ventures page separately describes more than $450 million in capital from internal and external sources and an investment strategy centered on intellectual property created within MGB’s research community. Those figures describe institutional scale and commercialization activity; they do not establish that the ERISA Master Trust financed any particular MGB-created company. ↩︎
4. Mass General Brigham, Contact Us, Working at the Assembly Row Campus, Locations, Mass General Brigham Healthcare Center in Portsmouth, Wentworth-Douglass Hospital, and Spaulding Rehabilitation Center. Spaulding Rehabilitation, Spaulding Outpatient Center at Kent Hospital | East Greenwich. Mass General Brigham, Consolidated Audited Financial Statements for Fiscal Years 2025 and 2024, Note 13, “Leases,” 32–35. MGB’s current contact page identifies its corporate headquarters as the Prudential Center in Boston. Its Assembly Row page describes an 800,000-square-foot campus in Somerville. MGB’s location records identify facilities in Massachusetts, New Hampshire, and South Berwick, Maine, while Spaulding, an MGB member, identifies an outpatient center at Kent Hospital in East Greenwich, Rhode Island. For FY2025, Note 13 reports $872.2 million in lease assets across its operating and finance categories and $321.9 million in total lease expense. Together, these records document MGB’s real estate and clinical presence across Massachusetts, New Hampshire, Maine, and Rhode Island. They do not identify the ownership or lease status of every individual site. ↩︎
5. Mass General Brigham, Anne Klibanski, Chris Coburn, and Mass General Brigham Ventures — About. MGB describes itself as Massachusetts’s largest private employer, with approximately 85,000 employees and $22 billion in annual revenue. Its official biographies say that its innovation platform has helped create more than 300 companies, employs a 140-person business-development group, and includes a venture fund approaching $500 million. The Ventures page separately describes more than $450 million in capital from internal and external sources and an investment strategy centered on intellectual property created within MGB’s research community. Those figures describe institutional scale and commercialization activity; they do not establish that the ERISA Master Trust financed any particular MGB-created company. ↩︎
6. U.S. Department of Labor, Consolidated Cash Balance Program of Mass General Brigham and Member Organizations — Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026; Mass General Brigham, Consolidated Audited Financial Statements for fiscal years 2025 and 2024. The Form 5500 identifies Plan 499 as the Consolidated Cash Balance Program, reports 96,507 participants and beneficiaries at the end of the plan year, and reports 62,951 active participants. MGB’s audited statements report $11.586 billion in defined benefit pension assets, $9.292 billion in benefit obligations, and a $2.294 billion funded surplus as of September 30th, 2025. Mass General Brigham, Consolidated Cash Balance Program Summary Plan Description; Mass General Brigham, Benefits; U.S. Department of Labor, Cash Balance Pension Plans. The summary plan description states that the annual interest-crediting rate generally equals the one-year Treasury bill rate for September of the preceding calendar year plus one percentage point and that the rate will never be less than 5% or more than 12%. MGB’s public benefits page describes a guaranteed minimum annual interest credit of 5% but does not state the Treasury bill formula or the 12% cap. ↩︎
7. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026. The filing identifies the trust by its formal name, reports its financial information and service providers, and includes the Schedule H, Line 4i attachment itemizing its year-end assets. The filing reports positions by issuer or vehicle; it does not provide a complete look-through into every pooled fund or disclose the decision process behind each manager selection. ↩︎
8. Mass General Brigham Incorporated, Form 990 for fiscal year 2024, Schedule L and Schedule O; Internal Revenue Service, Instructions for Schedule L (Form 990). MGB’s filing identifies business transactions involving interested persons tied to John Fish, Jonathan Kraft, and Phillip Ragon. The reported payments were $48.96 million to Suffolk Construction for construction services, $8.21 million to NPP Development for a lease, $1.50 million to NPS LLC for marketing, and $0.71 million to InterSystems for products and services, totaling $59.38 million. Schedule O describes MGB’s conflict process, including disclosure, complete recusal, consideration of disinterested competitive proposals when appropriate, written fair-and-reasonable findings, and independent review of particularly significant conflicts. Schedule L reports relationships and transactions; it does not itself determine that a transaction was improper. ↩︎
9. Suffolk Construction, John Fish; Brigham and Women’s Hospital, A Historic Gift for Caregivers; Partners HealthCare and Mass General Brigham Forms 990 for fiscal years 2013, 2014, 2015, 2016, 2017, 2018, 2020, 2021, 2022, 2023, and 2024. Fish’s official biography identifies him as Suffolk’s Chairman and CEO and an MGB Vice Chairman. The reconciled public filings report $469,719,826 in payments to Suffolk across the eleven listed fiscal years; the series combines independent-contractor disclosures and Schedule L interested-person transactions, and no FY2019 amount was located in the records reviewed. The FY2024 group filing reports $34.39 million, while MGB Incorporated’s separate parent filing reports $48.96 million for a different reporting population; those amounts are not added together. Brigham’s giving page states that John and Cyndy Fish have contributed more than $19.3 million. Payments and philanthropy are separate relationships and do not establish improper consideration. ↩︎
10. The Kraft Group, Jonathan Kraft; Massachusetts General Hospital, Robert Kraft and the Kraft Center, Record Gift From Kraft Family to Support Community Health and Health Equity, and Myra Kraft; Brigham and Women’s Hospital, Brigham Health Opens Expanded Center in Foxborough; Mass General Brigham, Center for Sports Performance and Research; Arrowstreet, Partners at Patriot Place. The records identify Jonathan Kraft as President of The Kraft Group and document a longstanding combination of property, healthcare, sponsorship, and philanthropy relationships involving the Kraft family and MGB institutions. The official giving records identify a $25 million 2011 pledge for the Kraft Center and a $50 million 2022 gift to Massachusetts General Hospital; Brigham’s record documents the 2019 Patriot Place expansion. These sources do not disclose the complete lease economics, procurement process, or relationship between the gifts and the separately reported NPP Development and NPS LLC transactions. ↩︎
11. InterSystems, Phillip T. “Terry” Ragon; Massachusetts General Hospital, The History of Pathology at Massachusetts General Hospital; MIT News, Alum’s $100 Million Gift Targets AIDS Vaccine, February 4th, 2009; Massachusetts General Hospital, Mass General Receives $200 Million for Ragon Institute, May 2nd, 2019, and Rising at a Pivotal Moment. MGH’s history identifies MUMPS as the Massachusetts General Hospital Utility Multi-Programming System and traces its development to the hospital’s clinical laboratories in the 1960s. InterSystems identifies Ragon as its Founder and CEO. The official gift records document a $100 million founding commitment in 2009 and a $200 million endowment gift in 2019 for the Ragon Institute, totaling $300 million specifically committed to the Institute. MGH separately describes a gift toward the Phillip and Susan Ragon Building but does not disclose its amount. Those philanthropic relationships remain distinct from the FY2024 InterSystems products-and-services transaction. ↩︎
12. Mass General Brigham Incorporated, Form 990 for fiscal year 2024, Schedule L and Schedule O; Internal Revenue Service, Instructions for Schedule L (Form 990). MGB’s filing identifies business transactions involving interested persons tied to John Fish, Jonathan Kraft, and Phillip Ragon. The reported payments were $48.96 million to Suffolk Construction for construction services, $8.21 million to NPP Development for a lease, $1.50 million to NPS LLC for marketing, and $0.71 million to InterSystems for products and services, totaling $59.38 million. Schedule O describes MGB’s conflict process, including disclosure, complete recusal, consideration of disinterested competitive proposals when appropriate, written fair-and-reasonable findings, and independent review of particularly significant conflicts. Schedule L reports relationships and transactions; it does not itself determine that a transaction was improper. ↩︎
13. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025; Archdiocese of Boston, Campaign for Catholic Schools Announces New Board Leadership, January 31st, 2024; U.S. Securities and Exchange Commission, Adage Capital Management Schedule 13G, filed in 2026; Bain Capital, John Connaughton and Paul Edgerley; Thrive Capital, Nitin Nohria Joins Thrive Capital, January 14th, 2022; Berkshire Partners, Carol Vallone. The Master Trust filing lists Adage, Bain, Thrive, and Berkshire issuer rows totaling $928.6 million. The separate official records establish the directors’ current affiliations with those manager families. The overlap establishes a relationship requiring scrutiny; the public records do not establish that any director participated in a Master Trust selection, renewal, valuation, or recusal decision. ↩︎
14. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025; Material Impact, Carmichael Roberts, and Introducing Material Impact. The Master Trust filing lists four North Bridge positions totaling approximately $7.8 million. Material Impact’s records identify Roberts as its Co-Founder and Managing Partner and describe his former role as a General Partner at North Bridge Venture Partners. The connection is historical and does not establish Roberts’s participation in any current Master Trust decision. ↩︎
15. Choate Wealth, Lanny Thorndike; GBH, Benjamin A. Gomez; Breachway Capital, Jason Krantz; Mass General Brigham, Leadership and Governance. Choate identifies Thorndike as President of Choate Investment Advisors with responsibility for investment strategy and daily operations. GBH identifies Gomez as Managing Director of Pilot House Associates, a family investment office. Breachway identifies Krantz as its Founder and Managing Partner and describes the firm as a venture-capital and growth-equity investor. MGB lists all three as current directors. No Choate, Pilot House, or Breachway issuer or manager name was located in the reviewed FY2025 Master Trust filing; their inclusion in the article’s board classification reflects disclosed outside investment roles, not a claimed Master Trust mandate. ↩︎
16. Thermo Fisher Scientific, Thermo Electron and Partners HealthCare Launch Research Collaboration, October 18th, 2002, and 2024 Proxy Statement; Brigham and Women’s Hospital, Form 990 for fiscal year 2009; Mass General Brigham, New Urine Test Can Detect Kidney Transplant Rejection, February 28th, 2025, and Biobank Genomics Core — Genotyping. Thermo’s records document a 2002 research collaboration with Partners HealthCare. Brigham’s FY2009 Schedule L reports $11,235,649 in Thermo products tied to then-trustee Jim Manzi. Thermo’s proxy identifies MGB Chairman Scott Sperling as Thermo’s Lead Director and MGB director Marc Casper as Thermo’s Chairman and CEO. MGB’s 2025 release states that its ExoTRU technology was licensed to Thermo Fisher, while the Genomics Core page says that requested TaqMan assays must be available on demand from Thermo Fisher. The records establish a research, procurement, governance, and licensing sequence; they do not disclose complete contract terms, pricing, exclusivity, recusals, or personal benefit. ↩︎
17. Ropes & Gray, Diane B. Patrick; U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025, Schedule C. Ropes & Gray identifies Patrick as a former Co-Managing Partner of its Boston office. The Master Trust filing reports $225,596 paid to Ropes & Gray for legal services. The affiliation is historical, and the filing does not identify the matters handled, Patrick’s participation, or any personal compensation. ↩︎
18. Mass General Brigham, Leadership and Governance; U.S. Department of Labor, Hall of Secretaries: Martin J. Walsh; National Hockey League Players’ Association, Martin J. Walsh. MGB’s current board page lists Walsh as a director. The Labor Department identifies him as the 29th U.S. Secretary of Labor, serving from March 2021 through March 2023, and recounts his Local 223 and Boston Building and Construction Trades Council history. The NHLPA identifies him as its Executive Director and describes his prior union leadership. These records establish the roles discussed in the article; they do not establish Walsh’s participation in any Master Trust decision. ↩︎
19. Mass General Brigham, Leadership and Governance, accessed July 2026. The current roster identifies Scott Sperling as Chairman, John Fish and Jonathan Kraft as Vice Chairmen, and Robert Atchinson, John Connaughton, Paul Edgerley, Nitin Nohria, Carmichael Roberts, and Carol Vallone among the organization’s twenty-six directors. Because the roster is a changing corporate page, the article’s board count reflects the page as reviewed during July 2026. The board-role percentages in the article are derived from MGB’s twenty-six-member current board roster and the role and transaction sources identified in Notes 3–6 and 18–23. Three of twenty-six directors are tied to interested-person transactions reported in MGB’s FY2024 Form 990; twelve have current private-equity, venture-capital, family-office, investment-management, or identified historical manager affiliations; two hold Thermo Fisher leadership roles; one is a former Ropes & Gray Boston Co-Managing Partner; and one has led a Massachusetts construction union and union trade group. Accounting for overlapping categories, those classifications encompass sixteen distinct directors, or 61.5%, rounded in the article to 62%. This is a classification of publicly disclosed roles and relationships, not a finding that every classified director exercised authority over the Master Trust or participated in any challenged transaction. ↩︎
20. U.S. Department of Labor, Consolidated Cash Balance Program of Mass General Brigham and Member Organizations — Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026; Mass General Brigham, Consolidated Audited Financial Statements for fiscal years 2025 and 2024. The Form 5500 identifies Plan 499 as the Consolidated Cash Balance Program, reports 96,507 participants and beneficiaries at the end of the plan year, and reports 62,951 active participants. MGB’s audited statements report $11.586 billion in defined benefit pension assets, $9.292 billion in benefit obligations, and a $2.294 billion funded surplus as of September 30th, 2025. Mass General Brigham, Consolidated Cash Balance Program Summary Plan Description; Mass General Brigham, Benefits; U.S. Department of Labor, Cash Balance Pension Plans. The summary plan description states that the annual interest-crediting rate generally equals the one-year Treasury bill rate for September of the preceding calendar year plus one percentage point and that the rate will never be less than 5% or more than 12%. MGB’s public benefits page describes a guaranteed minimum annual interest credit of 5% but does not state the Treasury bill formula or the 12% cap. ↩︎
21. U.S. Department of Labor, Consolidated Cash Balance Program of Mass General Brigham and Member Organizations — Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026; Mass General Brigham, Consolidated Audited Financial Statements for fiscal years 2025 and 2024. The Form 5500 identifies Plan 499 as the Consolidated Cash Balance Program, reports 96,507 participants and beneficiaries at the end of the plan year, and reports 62,951 active participants. MGB’s audited statements report $11.586 billion in defined benefit pension assets, $9.292 billion in benefit obligations, and a $2.294 billion funded surplus as of September 30th, 2025. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026. The filing identifies the trust by its formal name, reports its financial information and service providers, and includes the Schedule H, Line 4i attachment itemizing its year-end assets. The filing reports positions by issuer or vehicle; it does not provide a complete look-through into every pooled fund or disclose the decision process behind each manager selection. ↩︎
22. U.S. Department of Labor, Consolidated Cash Balance Program of Mass General Brigham and Member Organizations — Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026; Mass General Brigham, Consolidated Audited Financial Statements for fiscal years 2025 and 2024. The Form 5500 identifies Plan 499 as the Consolidated Cash Balance Program, reports 96,507 participants and beneficiaries at the end of the plan year, and reports 62,951 active participants. MGB’s audited statements report $11.586 billion in defined benefit pension assets, $9.292 billion in benefit obligations, and a $2.294 billion funded surplus as of September 30th, 2025. ↩︎
23. Partners HealthCare System and Mass General Brigham, consolidated audited financial statements for fiscal years 2016 and 2015, 2018 and 2017, 2019 and 2018, 2021 and 2020, 2023 and 2022, 2024 and 2023, and 2025 and 2024. The article’s Master Trust return ratio for each fiscal year equals the reported actual return on defined benefit pension plan assets divided by the beginning fair value of those assets. The employee comparison series uses the Plan 499 calendar-year interest-crediting rates; fiscal-year investment returns and calendar-year pension growth rates are aligned by ending year and are not the same accounting measure. The ten-year compounding and scale figures are derived illustrations using the annual series documented above. Compounding $100 through the Master Trust return ratios produces $250.46; compounding $100 through the Plan 499 interest-crediting rates produces $165.19, a difference of $85.28 per $100. Applying the same two no-flow growth paths to the Master Trust’s FY2016 opening asset value produces $10.85 billion and $7.16 billion, respectively, a difference of $3.69 billion. Dividing that difference by the 60,621 active participants reported at the beginning of Plan 499’s FY2025 Form 5500 produces approximately $60,900 per active participant. These figures do not account for contributions, distributions, transfers, expenses, or other cash flows and are not an accounting of benefits owed to any participant. ↩︎
24. Mass General Brigham, Consolidated Cash Balance Program Summary Plan Description; Mass General Brigham, Benefits; U.S. Department of Labor, Cash Balance Pension Plans. The summary plan description states that the annual interest-crediting rate generally equals the one-year Treasury bill rate for September of the preceding calendar year plus one percentage point and that the rate will never be less than 5% or more than 12%. MGB’s public benefits page describes a guaranteed minimum annual interest credit of 5% but does not state the Treasury bill formula or the 12% cap. ↩︎
25. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026. The filing identifies the trust by its formal name, reports its financial information and service providers, and includes the Schedule H, Line 4i attachment itemizing its year-end assets. The filing reports positions by issuer or vehicle; it does not provide a complete look-through into every pooled fund or disclose the decision process behind each manager selection. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025, Schedule H and the Line 4i attachment; WTW, 2023 Asset Allocations in Fortune 1000 Pension Plans, April 30th, 2025. WTW divides pension assets into cash, public equity, debt, and alternatives and reports alternative-investment benchmarks of 10.3% across the plans studied, 13.2% among larger plans, and 17.9% on an asset-weighted basis. Applying those classifications to Page 126’s reported line items produces $949.4 million in interest-bearing cash, U.S. government securities, corporate debt, corporate stock, and mortgage loans; the remaining partnership and joint venture interests, common and collective trusts, and registered investment companies total $10.50 billion, or 91.7% of Page 126’s itemized current value. This is a line-item comparison using the categories as filed; it does not look through the investment vehicles, and WTW’s reported figures are empirical benchmarks rather than legal ceilings. ↩︎
26. Defendants’ Answer to the Amended Complaint in Belknap v. Partners HealthCare System, Inc., filed September 9th, 2020; U.S. Department of Labor, Plan 499 Forms 5500 for fiscal years 2024 and 2025. In paragraph 55 of the Answer, the MGB defendants admitted that Towers Watson, now Willis Towers Watson, had been the plan’s actuary since before 2014. Paragraph 77 states that WTW was hired to calculate plan liabilities incorporated into MGB’s audited financial statements. Plan 499’s FY2024 Schedule C reports $434,428 in direct compensation to WTW, and the FY2025 Schedule SB identifies WTW-enrolled actuary Jennifer S. Collier as the signer of the plan’s funding schedule. These records establish a longstanding actuarial engagement; they do not establish that WTW selected, approved, or controlled the Master Trust’s investment allocation. ↩︎
27. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025, Schedule H and the Line 4i attachment; WTW, 2023 Asset Allocations in Fortune 1000 Pension Plans, April 30th, 2025. WTW divides pension assets into cash, public equity, debt, and alternatives and reports alternative-investment benchmarks of 10.3% across the plans studied, 13.2% among larger plans, and 17.9% on an asset-weighted basis. Applying those classifications to Page 126’s reported line items produces $949.4 million in interest-bearing cash, U.S. government securities, corporate debt, corporate stock, and mortgage loans; the remaining partnership and joint venture interests, common and collective trusts, and registered investment companies total $10.50 billion, or 91.7% of Page 126’s itemized current value. This is a line-item comparison using the categories as filed; it does not look through the investment vehicles, and WTW’s reported figures are empirical benchmarks rather than legal ceilings. ↩︎
28. Harvard T.H. Chan School of Public Health, Jeff Levin-Scherz; The Commonwealth Fund, Jeffrey Levin-Scherz; WTW, Monthly Healthcare Insights, January 9th, 2025. Harvard identifies Levin-Scherz as a WTW managing director and Population Health Leader who helps large employers develop and evaluate health-management strategies. WTW identifies him as its Population Health Leader. The Commonwealth Fund’s historical biography identifies him as Chief Medical Officer of Partners Community HealthCare. Those records establish the former Partners role and later WTW role; they do not establish that Levin-Scherz worked on MGB’s pension plan, Master Trust, actuarial engagement, or any MGB client matter at WTW. ↩︎
29. The ten-year compounding and scale figures are derived illustrations using the annual series documented above. Compounding $100 through the Master Trust return ratios produces $250.46; compounding $100 through the Plan 499 interest-crediting rates produces $165.19, a difference of $85.28 per $100. Applying the same two no-flow growth paths to the Master Trust’s FY2016 opening asset value produces $10.85 billion and $7.16 billion, respectively, a difference of $3.69 billion. Dividing that difference by the 60,621 active participants reported at the beginning of Plan 499’s FY2025 Form 5500 produces approximately $60,900 per active participant. These figures do not account for contributions, distributions, transfers, expenses, or other cash flows and are not an accounting of benefits owed to any participant. ↩︎
30. U.S. Department of Labor, ERISA Advisory Council, Report of the Working Group on Prudent Investment Process, 2006; CFA Institute, Liability-Driven and Index-Based Strategies, Symmetric Cash Matching, and Contingent Immunization—Part I: Risk Control Procedures; Society of Actuaries, Asset-Liability Management. The Labor Department advisory report recommends actuarial projections, cash-flow projections, asset-liability projections, review of the Investment Policy Statement, and documented risk measurement as fiduciary best practices, while noting that the report does not necessarily represent the Department’s position. CFA Institute and Society of Actuaries materials describe cash-flow matching, duration matching or immunization, contingent immunization, and hybrid approaches that combine near-term matching with longer-term total-return management. CFA defines contingent immunization as active management conducted above a protective threshold, followed by a switch to immunization when necessary to preserve a promised minimum return. These sources support the article’s explanation of ALM techniques; they do not establish that ERISA mandates any single named ALM or Liability Driven Investment strategy. ↩︎
31. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026. The filing identifies the trust by its formal name, reports its financial information and service providers, and includes the Schedule H, Line 4i attachment itemizing its year-end assets. The filing reports positions by issuer or vehicle; it does not provide a complete look-through into every pooled fund or disclose the decision process behind each manager selection. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025, Schedule H and the Line 4i attachment; WTW, 2023 Asset Allocations in Fortune 1000 Pension Plans, April 30th, 2025. WTW divides pension assets into cash, public equity, debt, and alternatives and reports alternative-investment benchmarks of 10.3% across the plans studied, 13.2% among larger plans, and 17.9% on an asset-weighted basis. Applying those classifications to Page 126’s reported line items produces $949.4 million in interest-bearing cash, U.S. government securities, corporate debt, corporate stock, and mortgage loans; the remaining partnership and joint venture interests, common and collective trusts, and registered investment companies total $10.50 billion, or 91.7% of Page 126’s itemized current value. This is a line-item comparison using the categories as filed; it does not look through the investment vehicles, and WTW’s reported figures are empirical benchmarks rather than legal ceilings. Mass General Brigham, Consolidated Audited Financial Statements for fiscal years 2025 and 2024, Notes 6 and 17. MGB reports $10.219 billion of its $11.586 billion in FY2025 defined-benefit pension assets as private partnerships and commingled funds valued using net asset value as a practical expedient. It reports a 32.9% private-equity allocation and $1.243 billion in unfunded defined-benefit-plan commitments. The audit states that private partnerships generally have limited redemption options and may impose gates, lockups, or other restrictions; it also says alternative investments are valued using amounts reported by fund managers and evaluated by management. These audited figures support the valuation, liquidity, and commitment discussion. They do not establish that every Page 126 partnership or pooled vehicle is private equity, leveraged, illiquid, or imprudent. ↩︎
32. Mass General Brigham, Consolidated Audited Financial Statements for fiscal years 2025 and 2024; Electronic Code of Federal Regulations, 29 C.F.R. § 2550.404a-1 — Investment duties; U.S. Department of Labor, Advisory Opinion 2006-08A, October 3rd, 2006; ERISA Advisory Council, Report of the Working Group on Prudent Investment Process, 2006. MGB’s audited statements describe a total-return objective that considers plan liabilities, funded status, projected cash flows, market assumptions, and MGB’s ability and willingness to bear market risk; they also assign pension-asset oversight and external-manager selection to the Board Investment Committee. The current investment-duty regulation requires consideration of diversification, liquidity, and current return relative to anticipated cash-flow requirements, projected return relative to funding objectives, and investment horizons consistent with plan objectives and funding policy. Advisory Opinion 2006-08A confirms that fiduciaries may account for benefit liabilities in a prudent investment strategy. The Advisory Council report recommends cash-flow and asset-liability projections and review of the Investment Policy Statement as best practices, but expressly states that its report does not necessarily represent the Department of Labor’s position. No public Investment Policy Statement, formal Asset Liability Matching study, or Liability Driven Investment framework for the Master Trust was located in the records reviewed; that is a disclosure limitation, not proof that those documents do not exist. ↩︎
33. Office of the Law Revision Counsel, U.S. House of Representatives, current United States Code provisions for ERISA Section 3 — Definitions, 29 U.S.C. § 1002, Section 402 — Establishment of Plan, 29 U.S.C. § 1102, Section 403 — Establishment of Trust, 29 U.S.C. § 1103, Section 404 — Fiduciary Duties, 29 U.S.C. § 1104, and Section 406 — Prohibited Transactions, 29 U.S.C. § 1106. These are the statutory sources for the article’s quoted definitions, written-plan requirements, trust and anti-inurement rules, fiduciary duties, and prohibited-transaction provisions. The article quotes selected provisions relevant to its inquiry rather than reproducing every statutory exception or qualification. Office of the Law Revision Counsel, U.S. House of Representatives, ERISA Section 408 — Exemptions From Prohibited Transactions, 29 U.S.C. § 1108; Electronic Code of Federal Regulations, 29 C.F.R. § 2550.408b-2 — General statutory exemption for services or office space. Section 408(b)(2) permits necessary plan services under reasonable arrangements for no more than reasonable compensation. The implementing regulation requires covered providers to disclose services and direct and indirect compensation to the responsible plan fiduciary and states that the exemption does not cover the fiduciary self-dealing acts described in Section 406(b) or erase the duties imposed by Section 404. The existence of a service relationship is therefore not itself prohibited; the relevant questions include necessity, reasonableness, compensation, disclosure, fiduciary loyalty, and satisfaction of every applicable exemption condition. ↩︎
34. U.S. Department of Labor, Employee Benefits Security Administration, Enforcement and Regional Offices. EBSA identifies using plan assets to benefit related parties, failing to value or hold assets properly, failing to follow plan terms, and failing to select and monitor service providers properly among the violations it investigates. Its current enforcement page also says that investigators examine risky or unsuitable strategies, systemic portfolio risk, conflicts of interest, efforts to increase compensation, and investments directed to affiliated funds. Civil corrections can include restoration of losses and disgorgement of profits; criminal matters involving embezzlement, kickbacks, or false statements are prosecuted by U.S. Attorneys’ offices. The Boston Regional Office is in the JFK Federal Building at 15 Sudbury Street, Room 575, Boston, Massachusetts 02203; its telephone number is (617) 565-9600, and EBSA’s national participant line is (866) 444-3272. ↩︎
35. Mass General Brigham, Leadership and Governance, accessed July 2026. The current roster identifies Scott Sperling as Chairman, John Fish and Jonathan Kraft as Vice Chairmen, and Robert Atchinson, John Connaughton, Paul Edgerley, Nitin Nohria, Carmichael Roberts, and Carol Vallone among the organization’s twenty-six directors. Because the roster is a changing corporate page, the article’s board count reflects the page as reviewed during July 2026. U.S. Department of Labor, MGB ERISA Master Trust — Form 5500 for the plan year ending September 30th, 2025; Archdiocese of Boston, Campaign for Catholic Schools Announces New Board Leadership, January 31st, 2024; U.S. Securities and Exchange Commission, Adage Capital Management Schedule 13G, filed in 2026; Bain Capital, John Connaughton and Paul Edgerley; Thrive Capital, Nitin Nohria Joins Thrive Capital, January 14th, 2022; Berkshire Partners, Carol Vallone. The Master Trust filing lists Adage, Bain, Thrive, and Berkshire issuer rows totaling $928.6 million. The separate official records establish the directors’ current affiliations with those manager families. The overlap establishes a relationship requiring scrutiny; the public records do not establish that any director participated in a Master Trust selection, renewal, valuation, or recusal decision. Mass General Brigham, Leadership and Governance; U.S. Department of Labor, Hall of Secretaries: Martin J. Walsh; National Hockey League Players’ Association, Martin J. Walsh. MGB’s current board page lists Walsh as a director. The Labor Department identifies him as the 29th U.S. Secretary of Labor, serving from March 2021 through March 2023, and recounts his Local 223 and Boston Building and Construction Trades Council history. The NHLPA identifies him as its executive director and describes his prior union leadership. These records establish the roles discussed in the article; they do not establish Walsh’s participation in any Master Trust decision. The board-role percentages in the article are derived from MGB’s twenty-six-member current board roster and the role and transaction sources identified in Notes 3–6 and 18–23. Three of twenty-six directors are tied to interested-person transactions reported in MGB’s FY2024 Form 990; twelve have current private-equity, venture-capital, family-office, investment-management, or identified historical manager affiliations; two hold Thermo Fisher leadership roles; one is a former Ropes & Gray Boston Co-Managing Partner; and one has led a Massachusetts construction union and union trade group. Accounting for overlapping categories, those classifications encompass sixteen distinct directors, or 61.5%, rounded in the article to 62%. This is a classification of publicly disclosed roles and relationships, not a finding that every classified director exercised authority over the Master Trust or participated in any challenged transaction. ↩︎
36. U.S. Department of Labor, Employee Benefits Security Administration, Enforcement and Regional Offices. EBSA identifies using plan assets to benefit related parties, failing to value or hold assets properly, failing to follow plan terms, and failing to select and monitor service providers properly among the violations it investigates. Its current enforcement page also says that investigators examine risky or unsuitable strategies, systemic portfolio risk, conflicts of interest, efforts to increase compensation, and investments directed to affiliated funds. Civil corrections can include restoration of losses and disgorgement of profits; criminal matters involving embezzlement, kickbacks, or false statements are prosecuted by U.S. Attorneys’ offices. The Boston Regional Office is in the JFK Federal Building at 15 Sudbury Street, Room 575, Boston, Massachusetts 02203; its telephone number is (617) 565-9600, and EBSA’s national participant line is (866) 444-3272. Massachusetts Nurses Association, Brigham Nurses Return to Patients Following Historic Strike and Lockout, July 13th, 2026; Brigham and Women’s Hospital, Nursing Union Updates; Jonathan Bowen, Kate Higgins’ Keynote at the 2015 Brigham and Women’s Partners in Excellence Awards, January 13th, 2015; Brigham Bulletin, 19th Annual Partners in Excellence Awards at BWH, February 5th, 2015; Massachusetts Bay Transportation Authority, Green Line E schedule. The MNA describes a one-day strike followed by a four-day employer lockout and identifies the nurses’ demands as competitive wages, affordable health insurance, and greater investment in permanent nurses. BWH’s page presents the hospital’s account of the work stoppage and bargaining. The award records identify Kate Higgins as a Brigham NICU nurse and Partners in Excellence speaker or honoree. The Green Line E serves both Brigham Circle and Government Center without a transfer; temporary service changes may affect any particular trip. ↩︎