Fiduciary Retirement Planning for MA Physicians: Coordinating 403(b) Rollovers, IRMAA, and Social Security
Fiduciary · 1940 Act
Serves only you
Investment adviser, fee-based or fee-only, held to a continuous duty of care.
Broker · 1934 Act
Serves you and their firm
Best Interest standard, commission-based, limited to their firm's product shelf.
By Tim Hayes, Financial Advisor for the Public and Not-for-Profit Sector
Fiduciary Duty
As part of my fiduciary duty, I carefully analyze your Social Security options at various ages, considering breakeven points and survivor benefits so you can feel confident in your choices. For IRMAA, I review income tables and thoughtfully develop strategies to reduce its impact, such as Roth conversions and managing capital gains when appropriate, giving you peace of mind that your interests are put first.
When considering rollovers, my fiduciary responsibilities include comparing fees and investment options in your current retirement account with those of a potential IRA rollover, prioritizing your specific retirement income goals and long-term financial security. Together, we'll determine the best approach, and I will design your retirement portfolio to help you build confidence and peace of mind.
The Fundamental Choice: Fiduciary Advisor or Broker?
| Standard / Law | Entity Type | Role / Professional | Compensation Model |
|---|---|---|---|
| Best Interest / 1934 Act | Broker-Dealer or Insurance Company | Financial Professional | Commission |
| Fiduciary / 1940 Act | Investment Advisor | Financial Advisor / Financial Planner / Investment Adviser Representative | Fee-Based or Fee-Only |
Financial Planning
For Massachusetts doctors and senior nonprofit executives, a comfortable retirement doesn't arrive as a single event. It arrives as a set of decisions that don't all happen at once — and interact with each other in ways that most advisors handle separately, if at all.
Social Security timing
When the higher earner should claim, spousal benefit coordination, and what the wrong decision costs you.
IRMAA
What you will actually pay in Medicare surcharges, and whether Roth conversions or charitable giving can help.
Asset allocation
Which assets belong in your Roth and which stay in your 403(b) or rollover IRA.
403(b) rollover
What to look for, and what it costs you to get it wrong.
As an independent fiduciary financial advisor, I focus on all four — not just the rollover.
Retirement Income Planning for Doctors and Nonprofit Executives
A Fiduciary Standard
If you choose a rollover, you gain a fee-only advisor held to the fiduciary standard. I design your retirement portfolio to align with your goals, recommend Roth, traditional, or combined accounts tailored to your needs, and select funds with the lowest expense ratios — passing on institutional pricing and index-fund savings directly to you.
Social Security Timing for Massachusetts Physicians and Nonprofit Executives
For physicians and nonprofit executives without a pension, Social Security is your primary guaranteed income source. The Stanford Center on Longevity found that delaying to 70 produces the best outcomes in the majority of retirement income scenarios.
The years between retirement and age 70 also create a window. Your income is lower relative to what's coming when Social Security, RMDs, and investment income stack up. That window is when Roth conversions make the most sense — claiming Social Security early closes it.
For married couples, spousal benefit coordination adds another layer. The higher earner delaying to 70 also maximizes the survivor benefit — often the most consequential number in the analysis.
IRMAA: Budget for It, Then See If You Can Reduce It
IRMAA is the Medicare income surcharge. It is based on your Modified Adjusted Gross Income from two years prior — which means RMDs, Social Security, and investment income all count. For physicians and nonprofit executives approaching Medicare eligibility, IRMAA is likely in your future; the question is which tier.
It is hard to get out of IRMAA at physician or executive income levels. Budget for it. If Roth conversions or Qualified Charitable Distributions can reduce future exposure or lower your bracket, that is worth knowing — but it is not a guarantee.
2026 IRMAA Brackets
2026 IRMAA Brackets: Married
| Income Level | Part B Per person, per month | Part D Per person, per month |
|---|---|---|
| $218,000 or less | $202.90 | Your plan premium plus $0 |
| Above $218,000 up to $274,000 | $284.10($202.90 + $81.20) | Your plan premium plus $14.50 |
| Above $274,000 up to $342,000 | $365.30($202.90 + $162.40) | Your plan premium plus $37.60 |
| Above $342,000 up to $410,000 | $446.40($202.90 + $243.50) | Your plan premium plus $60.80 |
| Above $410,000 up to $750,000 | $527.50($202.90 + $324.60) | Your plan premium plus $84.00 |
| $750,000 and above | $609.90($202.90 + $407.00) | Your plan premium plus $91.00 |
IRMAA is a cliff, not a ramp. One dollar over a threshold triggers the full surcharge for that tier. Based on 2024 income.
2026 IRMAA Brackets
2026 IRMAA Brackets: Single
| Income Level | Part B Per month | Part D Per month |
|---|---|---|
| $109,000 or less | $202.90 | Your plan premium plus $0 |
| Above $109,000 up to $137,000 | $284.10($202.90 + $81.20) | Your plan premium plus $14.50 |
| Above $137,000 up to $171,000 | $365.30($202.90 + $162.40) | Your plan premium plus $37.60 |
| Above $171,000 up to $205,000 | $446.40($202.90 + $243.50) | Your plan premium plus $60.80 |
| Above $205,000 up to $500,000 | $527.50($202.90 + $324.60) | Your plan premium plus $84.00 |
| $500,000 and above | $609.90($202.90 + $407.00) | Your plan premium plus $91.00 |
Single filer thresholds are approximately half the married filing jointly thresholds.
Which Retirement Assets Go Where
Asset location — which investments sit in which retirement accounts — is one of the highest-value decisions in a large 403(b) rollover and one of the most consistently overlooked.
Pick your retirement allocation. Remember to allocate the investments with the highest growth potential to the Roth.
I Immediately Felt I Was in Good Hands
"I was fortunate to get a recommendation for Tim Hayes from a colleague many years ago, and I have benefitted greatly from our partnership. At our first meeting, I immediately felt that I was in good hands. Tim is a wonderful listener, and he asked great questions that allowed me to focus my long-term financial goals. He has always been very responsive to any questions I have had and keeps me informed about the impact the vagaries of the investment world have on my portfolio while, at the same time, giving me advice on our next steps. Both his knowledge and his thoroughness are refreshingly impressive."
Phyllis Gleason
Client
Testimonial Disclosure: Testimonials are based on individual client experiences and may not represent the experiences of all clients. They are not a guarantee of future performance. Each client's situation is unique. No compensation has been provided for these testimonials.
The 403(b) Rollover: What You're Actually Sitting In
You didn't pick the fund lineup in your 403(b). A plan administrator or an advisor did. The question worth asking before you roll over is whether those funds — and the fees attached to them — are competitive with what's available in a rollover IRA.
The second question is whether your current plan has the right fund types for the next phase. A 403(b) built for accumulation — heavy on growth funds — may not have sufficient options for distribution: bonds, dividend-focused equity, income-oriented funds. If those options aren't there, and the IRA fees are lower, the rollover makes the case for itself. Tim's analysis covers both.
Retirement Planning Analysis $800
A one-time, flat fee of $800 covers all four pieces below.
Social Security Scenarios
Tim runs dollar-amount projections for multiple claiming scenarios based on your actual Social Security earnings record — full retirement age versus age 70, with spousal benefit options where applicable. You receive a printed breakeven analysis for each scenario.
IRMAA Projection
Tim provides an estimate of what you are on track to pay in Medicare surcharges based on your desired retirement income and projected RMDs, and reviews whether Roth conversions or Qualified Charitable Distributions could reduce your exposure....reviews whether Roth conversions or Qualified Charitable Distributions could reduce your exposure. See how Roth conversions affect IRMAA specifically →
Asset Allocation
Tim runs a side-by-side comparison of your current fund fees and performance with what is available in a rollover IRA, and assesses whether your current lineup has sufficient options for the distribution phase — bonds and dividend-focused funds — and whether aggressive growth options are available for any Roth portion.
403(b) Rollover Analysis
Tim will run a best-interest analysis, now required by the DOL for any rollover recommendations from a financial professional, that compares the pros and cons of staying in the defined contribution plan versus rolling it over.
$800 might be one of the best retirement investments you could make.
Financial Advisor Disclaimer
If you decide to roll over your 403(b) with Tim, there are additional charges: an advisory fee if you want Tim to manage your IRA investments, or a one-time commission if you decide to use a brokerage account. Or if you stay in the plan, you can pay Tim an hourly fee to help manage the account. Either way, the best-interest analysis guides us. Furthermore, the $800 analysis requires no obligation to use Tim's retirement planning services in the future.
Deeper Background
Understanding the Fiduciary Standard
Everything above is what most clients need to make a decision. If you want to understand exactly how the fiduciary standard came to exist, how it differs from a broker's Best Interest obligation, and why I'm registered the way I am, that's below.
The Rules Have Changed: Fiduciary Duty vs Best Interest Standard
After the introduction of a new rule from the Securities and Exchange Commission (SEC), with a new interpretation from the Department of Labor (DOL) of an old law, the Employee Retirement Income Security Act (ERISA), the duties that financial advisors, financial professionals, ERISA fiduciaries, and financial planners owe to their clients have converged.
However, a key difference still exists in whom they serve: a fiduciary serves only you, whereas a broker can serve both their firm's interests and yours.
A broker-dealer (B/D) is a firm that buys and sells securities, operating as both a broker and a dealer, depending on the transaction. Fidelity, Charles Schwab, and TD Ameritrade are the three largest B/Ds. In addition, many regional and independent B/Ds exist, such as LPL Financial, Ameriprise, Cambridge Investment Research (my broker-dealer), and Raymond James.
Their advisors are called registered representatives or financial professionals, who are usually paid a commission for selling financial products. They are not fiduciaries, but they are required to recommend a suitable product to their clients. Best Interest replaced suitability as the required standard in 2020.
Investment advisers differ from broker-dealers. With a fiduciary duty to their clients, investment advisers operate under the 1940 Act and follow a distinct business model. They typically receive fees rather than commissions.
Three federal acts regulate financial advisors: the first is the Securities Exchange Act of 1934, the second is the Investment Advisers Act of 1940, and the third is the 1974 retirement protection law called ERISA. The 1934 act regulates broker-dealers, the 1940 act regulates investment advisers, and ERISA governs retirement plans. (State laws also regulate them, and most insurance products are regulated at the state level.)
Fee-Only, Fee-Based, Financial Planner: What These Titles Really Mean
Around the time advisors were switching to fee-based, the financial industry began embracing personal computers. As a result, some firms started charging clients fees to develop a comprehensive financial plan. First, the client filled out a lengthy questionnaire. Second, the financial planner inputted the data into a software program and then printed the client's financial plan, usually presented in a fancy binder.
Most plans presumably ended up in the filing cabinets of clients, recalling President Eisenhower's line about plans: "I have always found that plans are useless, but planning is indispensable."
There is no "financial planner" in the regulations. Instead, there are investment advisor representatives and registered representatives. "Financial planner" is more of an industry term for someone who looks at your entire financial picture. Some financial planners are fiduciaries, and others are not. Some charge a fee, some are compensated through a commission, and some receive both.
A private organization offers a designation, certified financial planner. Since 2018, all holders of that designation are required by the organization to be fiduciary. But the 40 Act determines if someone is acting as a fiduciary, so the organization requires that anyone who wants to hold that designation be willing to fall under the 40 Act.
There is also an organization called the National Association of Personal Financial Advisors (NAPFA), a directory where you can find a fee-only advisor in your area. Financial advisors pay annual dues of $249 to belong to NAPFA, plus a one-time, non-refundable processing fee.
The Dodd-Frank law emerged from the 2008 financial crisis. Its main objective was to shore up the banking system. Dodd-Frank, however, also tasked the SEC with studying whether changes needed to be made to the rules regulating financial advisors. The goal was to ensure the public was benefiting from having two silos' commissions and fees, and if it behooved brokers to become more like investment advisors (fiduciaries).
After extensive discussions, the SEC established a new rule called Regulation Best Interest. This rule requires brokers to act in your "best interest," but it does not mandate that they become fiduciaries. Instead, brokers can continue to serve as agents of their firms, which often restricts their recommendations to a limited selection of proprietary products.
Remember, financial advisors are either registered representatives affiliated with B/Ds or investment advisor representatives working for investment advisors. I am dual-registered — that is, I am a registered representative of a B/D and an investment advisor representative of an investment advisor.
Today's Rulebook: SEC Regulation Best Interest and Fiduciary Duties Explained
The Department of Labor (DOL), which oversees retirement plans, has established its own Best Interest standard that applies to rollovers of retirement accounts, including 403(b) and 457 plans for public employees. This rule is distinct from the SEC's Regulation Best Interest. It applies to both brokers and investment advisors who receive compensation for providing advice on rollovers.
The DOL's new fiduciary rule strengthens fiduciary obligations for rollover advice, closing a gap that previously exempted one-time recommendations from fiduciary law and the duty of care.
The goal of this regulation is to address the challenges posed by courts that have consistently upheld the strict and narrow limitations of the 1975 five-part test for defining a fiduciary, which often exempted one-time rollover advice from the fiduciary standard.
Firms are also removing conflicts of interest to align with the new Best Interest Standard. The DOL also now uses that standard in their interpretation of who is a fiduciary advisor under ERISA. When the investing public works with an advisor, they benefit from having a similar standard for conduct, as Best Interest aligns closely with the fiduciary responsibilities in the 40 Act.
What the Fiduciary Standard Means for Your 403(b), IRA, or Rollover Decision
If you have an IRA and work with a financial advisor, now is an excellent time to review the financial planning arrangement — fee or commission, best interest, or fiduciary. Also, if you are thinking of rolling over a 401(k) or 403(b), ensure your decision is consistent with the new rule.
Suppose you happen to administer a retirement plan for an employer: ensure that any advisor compensation is aligned with the new interpretation from the DOL and the new rule from the SEC.
Why I Am (and Choose to Remain) Dual-Registered
I remain registered as an investment adviser representative and as a registered representative. Most of my business is as a fee-only investment advisor representative, where I charge a client a fee or an hourly rate for my advice. I like this arrangement because it is not product-based, and I can get paid to provide ongoing advice to my clients.
However, I keep my registered representative license because when I compare a commission product, it sometimes makes more sense for the client. For example, a new client who is 25 years old wants to contribute $6,000 to a Roth IRA — I cannot imagine charging them a fee for the next 40 years.
Also, I like to use American Funds for some clients with big 401(k) or 403(b) accounts, if I recommend that they roll over their money. If their 403(b) or 401(k) account balance is over a million, they pay no sales charge. And American Funds has some of the lowest management fees for actively managed funds. They also offer excellent funds for customers interested in generating retirement income. But I need to have a registered representative license to provide this option.
How Compensation Models Have Evolved
Having been a financial advisor and financial planner for over thirty years, I have witnessed many financial advisors' changing compensation structure. For example, according to a review of their financial situations, most personal financial advisors were paid commissions from selling a financial product or investment when I started.
About midway through my career, the compensation in the marketplace began changing. More and more advisors began moving to a fee-based or fee-only financial planning compensation arrangement. So, instead of charging commissions from the sale of an investment, the financial advisor usually charges an ongoing fee, a percentage of the client's investment, for financial planning services.
The hope is that by disconnecting the compensation from the product, the client would receive better advice. However, another concern was that the planners were less inclined to provide ongoing advice when compensated from an initial product sale.
Your Independent, Dual-Registered Fiduciary Advisory
I'm an Investment Adviser Representative with Cambridge Investment Research Advisors, Inc. (RIA) and a Registered Representative with Cambridge Investment Research, Inc. (broker-dealer). My practice is independent and locally operated — so you work directly with me — while I'm supported by a national compliance, technology, and service platform.
Serving Boston & surrounding: North Shore, South Shore, Merrimack Valley, MetroWest, Cape & Islands, and the South Coast.
Tim Hayes
I am a fiduciary financial advisor with over 35 years of experience helping retirees with retirement planning, including 403(b) plans. I offer transparent, fee-based advice tailored to each client's goals and needs.
"My goal is to ensure your retirement plan is built on your best interests, not a product sale."
Ready to get started? Book your $800 retirement analysis — no call center, no hand-off, just me.
These are the opinions of Financial Advisor Tim Hayes and not necessarily those of Cambridge Investment Research. They are for informational purposes only and should not be construed or acted upon as individualized investment advice. Content provided via links to third-party sites should not be considered an endorsement of content that we cannot verify the completeness or accuracy of.