457(b) Plans for Physicians: Governmental vs. Non-Governmental, and What Happens If Your Hospital Fails

The short answer: a 457(b) is a deferred compensation plan that lets you set aside salary before tax, on top of your 403(b) or 401(k). At a public employer it works much like a 403(b), with two extras: no 10% early-withdrawal tax and, if the plan offers it, a Roth option. At a private nonprofit hospital it is a different thing. Federal law requires that plan to stay unfunded, so the balance is a promise from the hospital, and if the hospital fails you stand in line with its other unsecured creditors.

A reader asked our Ask tool, "Should I roll over my 403(b) if my employer is struggling?" The question is a good one, but it points at the wrong account. This guide explains which account carries the risk, what the rules allow you to do about it, and how to decide whether a non-governmental 457(b) is worth using at all. Every rule below links to the IRS, the tax code or regulations, or the reporting it comes from; where we could not verify something, we left it out and say so.

What a 457(b) Plan Is

A 457(b) is an "eligible deferred compensation plan" under section 457 of the Internal Revenue Code (26 U.S.C. 457). Only two kinds of employers can sponsor one: state and local governments and their agencies, and organizations exempt from tax under section 501(c), such as a nonprofit hospital. Churches and church-controlled organizations as the Code defines them can't (IRS). A for-profit hospital company can't offer a 457(b) at all; its deferred compensation plans are a different kind of nonqualified plan.

You choose to defer part of your salary into the plan. The deferral isn't subject to income tax withholding when you make it (IRS Notice 2003-20), and the money is taxed when it comes out. The annual cap counts everything that goes in except earnings: the plan's limit is the lesser of 100% of your includible compensation or the dollar limit, and any employer contribution to the 457(b) uses up part of that same limit (IRS; IRS). That is unlike a 403(b), where employer money has its own, larger limit.

The 457(b) limit is not combined with your 403(b) or 401(k) deferrals (IRS). That separate limit is why hospitals offer it: a physician who already maxes the 403(b) can defer the same amount again. Our retirement contribution limits guide shows how every account's limit stacks.

Governmental vs. Non-Governmental 457(b)

The same section of the tax code produces two plans that behave very differently. The IRS publishes a side-by-side comparison; these are the differences that matter to a physician.

The participation rule explains the creditor rule. A non-governmental plan has to be limited to a "top-hat" group because that is what exempts it from ERISA's funding requirements; if the plan let everyone in, ERISA would require it to be funded, and a funded plan fails the 457(b) requirement that a tax-exempt employer's plan stay unfunded (IRS). Physicians are usually in the top-hat group, which is why the plan is offered to you and not to most of the hospital's staff.

Which One Do You Have?

The plan type follows the legal employer that sponsors the plan, not the name on the building. A physician who works at a public hospital but is employed by a separate nonprofit physician group or foundation is in that group's plan, and if the group is a private tax-exempt organization, its 457(b) is non-governmental. Check before you elect:

1. Read the plan document or summary. A non-governmental plan will describe itself as unfunded, or as a plan for a select group of management or highly compensated employees, and will usually say you have the rights of a general unsecured creditor. A governmental plan will say its assets are held in trust, custodial accounts or annuity contracts for participants, as section 457(g) requires (26 CFR 1.457-8).
2. Look at who is eligible. If nurses, staff and residents can all join, the plan is very likely governmental. If only physicians and executives above a pay level can join, it is very likely non-governmental.
3. Look at the options. A Roth option or an age-50 catch-up means a governmental plan; non-governmental plans can have neither.
4. Ask HR one question in writing: "Is this a governmental 457(b) with assets held in trust under section 457(g), or a tax-exempt employer's 457(b) held as the employer's general assets or in a rabbi trust?"

Public systems with physician-specific plan rules are covered in our UT System TRS vs. ORP guide and UC retirement choice guide. For large private nonprofit employers, see the Mayo Clinic and Baylor Scott & White benefit guides, or start from our physician employer guides.

Who Owns the Money

Governmental plans

Section 457(g) says a governmental employer's plan isn't an eligible plan unless all of its assets and income are held in trust for the exclusive benefit of participants and their beneficiaries (26 U.S.C. 457(g)). The regulations require the trust to make it impossible, until every participant is paid, for the assets to be used for anything else, and require deferrals to reach the trust within a reasonable time (26 CFR 1.457-8). The employer's creditors have no claim on those assets.

Non-governmental plans

The rule runs the other way. The IRS says a non-governmental 457(b) must remain unfunded, and its assets are not held in trust for employees but "remain the property of the employer," available to its general creditors in litigation or bankruptcy (IRS). The regulations go further: a funding arrangement that sets assets aside for the exclusive benefit of participants would break the rule and can make the deferrals immediately taxable (26 CFR 1.457-8). In other words, the hospital is not allowed to protect your balance from its creditors, and the plan's tax deferral depends on it not doing so.

Many hospitals hold the money in a rabbi trust, an irrevocable trust that keeps the employer from spending the assets on itself. It doesn't change the outcome in a bankruptcy. The IRS notes that a rabbi trust is funded but its assets remain available to the employer's creditors (IRS). Your plan statement shows an account balance and the investments you picked, but legally it records what the hospital owes you.

For comparison: the 403(b)

A 403(b) is funded through annuity contracts or custodial accounts, and contributions must be transferred to the insurer or custodian within a reasonable time. A 403(b)(7) custodial account must make it impossible for its assets to be used for anything other than the exclusive benefit of participants (26 CFR 1.403(b)-8). If your 403(b) is an ERISA plan (governmental and church plans aren't), ERISA also says plan assets "shall never inure to the benefit of any employer" (29 U.S.C. 1103(c)).

What Happens to Your 457(b) If Your Hospital Fails

If a nonprofit hospital with a non-governmental 457(b) files for bankruptcy, your balance becomes a general unsecured claim against the estate. You file a proof of claim like any other creditor, and you are paid whatever unsecured creditors recover, which may be little or nothing. Our hospital bankruptcy guide walks through the payment order, the claim deadlines, and the other exposures, such as unpaid wages and tail coverage.

The closest real case: Steward Health Care

Steward Health Care, a for-profit hospital system, filed for Chapter 11 in the U.S. Bankruptcy Court for the Southern District of Texas on May 6, 2024 (WBUR). Steward had been owned by the private equity firm Cerberus (Boston Globe). As a for-profit company it couldn't sponsor a 457(b); its deferred compensation plans were nonqualified plans funded through two rabbi trusts. That puts participants in the same legal position as in a non-governmental 457(b), whose assets, even when held in a rabbi trust, remain reachable by the employer's creditors.

A group of Steward doctors objected that Steward hadn't shown the plans were exempt from ERISA's protections (Bloomberg Law). Steward argued that the plans were exempt and that the money was company property. According to WBUR's May 1, 2025 report, the bankruptcy court sided with Steward, ordered the plans dissolved, and directed that almost $60 million from them be transferred to Steward to pay its creditors. WBUR quoted one of the plan documents: "If Steward Health Care becomes insolvent, Steward's creditors will have access to your plan account. You will have the rights of a general unsecured creditor in such event." The participants appealed; we did not find a reported outcome of that appeal (WBUR).

A non-governmental 457(b) at a nonprofit hospital carries the same disclosure in substance. The Steward case shows what that sentence means when an employer actually fails.

Other hospital bankruptcies

Two other failures physicians often mention were also for-profit, so no 457(b) was involved. Hahnemann University Hospital in Philadelphia, bought from Tenet Healthcare in early 2018 by a company led by California businessman Joel Freedman, filed for Chapter 11 starting June 30, 2019 (Philadelphia Inquirer). Prospect Medical Holdings, majority-owned by the private equity firm Leonard Green from 2010 to 2021, filed on January 11, 2025 (Fierce Healthcare). We found no public reporting on deferred compensation losses in either case, so we don't describe any.

We also looked for a documented case of a private nonprofit hospital's bankruptcy in which non-governmental 457(b) participants lost money, and didn't find one in court records or major news coverage we could verify. That is not evidence the risk is small; the plan's legal structure guarantees the exposure, and Steward shows a court applying that structure. What it does tell you is where to look: the risk is greatest at an employer whose finances are weak, which is why the checklist below starts with the employer's financial statements.

What you can and can't do when your employer struggles

• You can stop new deferrals. Every dollar you don't defer from now on is a dollar not at risk. Ask HR how and when a change to your deferral election takes effect.
• You generally can't take the balance out while you are employed. A 457(b) can make money available only after you leave the employer, in the calendar year you reach 70 and a half (59 and a half in a governmental plan), or for an unforeseeable emergency (26 CFR 1.457-6; Notice 2020-68). An unforeseeable emergency means a severe financial hardship from an illness or accident, a casualty loss, or a similar extraordinary event beyond your control; your employer's finances don't qualify.
• Leaving starts the payout schedule you elected. The balance remains at risk until each payment is actually made, so a 10-year installment plan keeps most of it exposed to the old employer for years.
• Payments shortly before a filing can be challenged. A bankruptcy trustee can sue to recover certain payments to creditors made in the 90 days before the filing, or up to a year before for insiders (11 U.S.C. 547). Whether that would reach a 457(b) payout depends on the facts; if your employer is close to filing, ask a bankruptcy attorney before you count on money already received.
• If the employer files, file a claim. Put your 457(b) balance in your proof of claim, with your latest statement and the plan document, before the bar date.

"Should I Roll Over My 403(b) If My Employer Is Struggling?"

Usually there is no need, and usually you can't while you still work there. Here is the reasoning, step by step.

1. Your vested 403(b) isn't the hospital's property. It sits in annuity contracts or custodial accounts held for you, with the exclusive-benefit rules described above (26 CFR 1.403(b)-8; 29 U.S.C. 1103(c)). A hospital bankruptcy doesn't make it available to the hospital's creditors, and moving it to an IRA wouldn't make it safer from them.
2. You generally can't move it anyway. 403(b) elective deferrals can't be distributed before you reach 59 and a half, leave the employer, die, become disabled, or have a financial hardship, and a plan doesn't have to offer all of those (IRS Publication 571). A hardship withdrawal can't be rolled over (IRS), so it would be taxed. If you are 59 and a half or older and your plan allows in-service withdrawals, a direct rollover to an IRA is possible, but the reason to do it would be investment choice or fees, not creditor protection.
3. The real 403(b) exposure is money in transit. Pay withheld from your paycheck that hasn't yet reached the custodian, and an employer match that was promised but not deposited, are where 403(b) participants can lose money when an employer collapses. Compare your pay stubs with the deposits on your 403(b) statement every quarter; a growing gap is an early warning. Our hospital bankruptcy guide covers how those claims are treated.
4. The account that is exposed is the non-governmental 457(b). It is the hospital's property until paid, and it can't be rolled to an IRA or moved while you are employed. If you are worried, the move is to stop new deferrals and, if you are leaving, to know exactly how and when your elected payout schedule pays you.

One caution on church-affiliated hospitals: some religious health systems sponsor 403(b) or pension plans as "church plans" that aren't covered by ERISA. The 403(b) custodial-account rules above still apply to the tax side, but ERISA's protections may not. The hospital bankruptcy guide covers the church plan issue for pensions.

2026 Limits and Catch-Up Contributions

The IRS sets the 457(b) deferral limit each year at the same dollar amount as the 401(k) and 403(b) limit. For 2026 it is $24,500 (Notice 2025-67; IR-2025-111). The 2027 limits had not been announced as of November 5, 2026; last year's announcement came on November 13, 2025. Figures you may see for 2027 are projections, not IRS numbers. We will add the 2027 limits when the IRS publishes them.

Age 50 and ages 60 to 63

Only a governmental 457(b) can offer the age-50 catch-up; a non-governmental plan can't (IRS). The higher catch-up for people who turn 60, 61, 62 or 63 during the year, $11,250 in 2026 instead of $8,000, applies to governmental 457 plans along with 401(k) and 403(b) plans and the TSP, if the plan offers it (IRS). So a 61-year-old at a public hospital can defer up to $35,750 to the 457(b) in 2026, and the same again to a 403(b).

The special final-three-years catch-up

Both kinds of 457(b) may allow a larger limit in the last three taxable years ending before the plan's normal retirement age. The limit is the lesser of twice the regular limit ($49,000 in 2026) or the regular limit plus whatever you left unused in earlier years you were eligible for the plan. If you maxed out every year, it gives you nothing extra. Normal retirement age is set by the plan within the range the rules allow: generally starting at the earlier of 65 or the age at which you could retire with full benefits under the employer's pension plan, and no later than 70 and a half (IRS).

You can't use the special catch-up and the age-50 catch-up in the same year. In a governmental plan that offers both, you get whichever produces the larger amount (IRS; IRS).

The Roth catch-up rule for high earners

SECURE 2.0 requires that catch-up contributions be Roth if your FICA wages from the employer sponsoring the plan were over $150,000 in the prior year (2026 threshold; IRS). For 457(b) plans:

• Governmental 457(b): the rule applies to the age-50 and ages 60 to 63 catch-ups. Most attending physicians are over the threshold, so expect catch-ups to be Roth. If the plan has no Roth option, the IRS says an affected participant can't make the age-50 catch-up at all (IRS).
• The special final-three-years catch-up is not covered; the IRS says it may still be made before tax (IRS).
• Non-governmental 457(b): the rule has nothing to apply to, because these plans have no age-50 catch-up and no Roth option.
• No FICA wages, no rule. The test uses Social Security wages in box 3 of your W-2. The final regulations say this deliberately leaves out state and local government employees whose pay isn't subject to Social Security tax (final regulations, 90 FR 44527).

The final regulations apply from 2027, with later dates for some governmental plans; for 2026, plans may follow a reasonable, good-faith reading of the law (IR-2025-91).

Getting the Money Out: Penalties, Rollovers, Elections and Taxes

No 10% early-withdrawal tax, with one exception

The 10% additional tax on early distributions applies to a "qualified retirement plan" as defined in section 4974(c): 401(a) plans, 403(a) and 403(b) annuities, and IRAs (26 U.S.C. 4974(c)). A 457(b) isn't on that list, so a payout after you leave the employer isn't subject to the 10% tax at any age (IRS information letter 2001-0099). The exception: money you rolled into a governmental 457(b) from a 401(k), 403(b) or IRA keeps the 10% tax when it comes out, and plans usually keep it in a separate account (IRS Topic 558; 26 U.S.C. 72(t)(9)). That makes a 457(b) the most useful account for a physician who plans to stop working before 59 and a half.

Rollovers: governmental yes, non-governmental no

When you leave a public employer, a governmental 457(b) can be rolled to a traditional IRA, a 401(k), a 403(b) or another governmental 457(b) (IRS rollover chart; IRS). A non-governmental 457(b) can't be rolled to any of them. The IRS says distributions from a tax-exempt employer's 457(b) can't be rolled over, and an attempted rollover is treated as an excess contribution to the receiving account, subject to the excise tax under section 4973 (IRS).

The one way to move a non-governmental balance is a plan-to-plan transfer to another tax-exempt employer's 457(b). The regulations allow it only if both plans provide for it, your balance isn't reduced by the transfer, and you have left the old employer and work for the employer that sponsors the new plan (26 CFR 1.457-10(b)). A transfer between a non-governmental and a governmental plan isn't allowed in either direction. If your next job is at another nonprofit hospital, ask both plans whether they accept transfers; many don't.

Distribution elections in a non-governmental plan

This is where most of the planning happens. A non-governmental 457(b) is taxed when the money is paid or made available to you (Notice 2003-20). To keep money from being treated as made available, the plan sets an election period, and that period has to close before the first time any of the money would be considered available (26 CFR 1.457-7(c)(2)). In practice:

• Your initial election sets when and how you are paid, usually a lump sum or annual installments over a set number of years, starting at separation or at a later date the plan allows. Plans set their own menus and deadlines, so check whether yours offers installments at all.
• You get one more chance to delay. Section 457(e)(9)(B) lets a tax-exempt plan offer one additional election to defer the start of payments, made after the money becomes available and before payments begin. It can only push the start later, not earlier, and the IRS says it doesn't open a new payment option (26 U.S.C. 457(e)(9); 26 CFR 1.457-7(c)(2)(iii); Notice 98-8).
• The default can be a lump sum. If you never made an election and the plan's default is a single payment at separation, the whole balance is taxed in one year, often the year you start a new job at full salary. The worked example below shows what that costs.

Read the distribution section of your plan document before you enroll, and keep a copy of every election you file. A governmental 457(b) doesn't have this problem in the same way: it is taxed only when actually paid (Notice 2003-20), and you can roll it to an IRA and control the timing yourself.

How payouts are taxed and reported

• Ordinary income. Pre-tax 457(b) money is taxed as ordinary income when paid; there is no capital gains treatment.
• Non-governmental payouts are wages on a W-2. Notice 2003-20 says payouts to a participant from a tax-exempt employer's 457(b) are wages reported on Form W-2 (Notice 2003-20).
• Governmental payouts go on Form 1099-R, not Form W-2 (IRS Instructions for Forms 1099-R and 5498).
• Roth money in a governmental plan comes out tax-free in a qualified distribution, which generally requires five years of participation and age 59 and a half (IRS).

State tax if you move

A federal law, 4 U.S.C. 114, bars a state from taxing the retirement income of someone who is not a resident or domiciliary of that state, and its definition of retirement income includes payments from an eligible deferred compensation plan under section 457 (4 U.S.C. 114). So if you leave a hospital in a high-tax state and move to a state without an income tax before your 457(b) pays out, the state where you earned the money generally can't tax those payments. Your new state's rules apply instead.

Worked Example: The Balance at Risk and the Payout Tax

Assumptions

• An attending at a private nonprofit hospital defers the 2026 limit, $24,500, to a non-governmental 457(b) every year, credited at year-end.
• The account earns an assumed 5% a year. That is an assumption for illustration, not a forecast; the limit is also held at the 2026 amount.
• Taxes: married filing jointly, 2026 federal brackets in every payout year, federal income tax only (no state tax), and the balance stops growing once payouts begin.

How much is exposed

After 10 years, $245,000 of deferrals has grown to about $308,158, all of it an unsecured promise from one employer. After 20 years it is $810,116. That concentration is the thing to weigh: the longer you defer and the larger the balance, the more of your net worth depends on a single hospital staying solvent until the last payment.

Lump sum vs. installments

Now take the $308,158 balance and pay it out three ways, in two situations: you have moved to a new full-time job ($350,000 of other taxable income), or you have retired or cut back ($100,000 of other taxable income).

While you are still earning, the lump sum costs $24,740 more in federal tax than 10 annual payments, because it pushes most of the balance into the 32% and 35% brackets instead of leaving it in the 24% bracket. In retirement, with lower other income, the gap shrinks to $5,024. Two lessons follow:

1. A non-governmental 457(b) pays off when the money comes out at a lower rate than you saved at. If you will leave for another full-time job and the plan only offers a lump sum, much of the benefit is gone.
2. Spreading payouts lowers the tax but keeps the balance exposed to the old employer for longer. With a strong employer that is a good trade; with a weak one, it may not be.

To see how a 457(b) deferral changes your paycheck, try the take-home pay calculator, which has a 457(b) field.

Should You Contribute to a Non-Governmental 457(b)?

A governmental 457(b) is an easy yes for most physicians who have the cash flow: it is held in trust, it rolls to an IRA, and it has no 10% early-withdrawal tax. A non-governmental 457(b) needs a decision. Work through these in order.

1. Fund the safer accounts first

The usual order for a hospital-employed physician: take the full 403(b) or 401(k) match, fund an HSA if you are on a qualifying high-deductible plan, max the 403(b), and do a backdoor Roth IRA. If your 403(b) or 401(k) allows after-tax contributions with in-plan conversions, a mega backdoor Roth is also ahead of a non-governmental 457(b) for most people, because that money is protected and grows tax-free. The non-governmental 457(b) comes next, if the rest of this checklist holds up.

2. Check the employer's finances

You don't need inside information. Nonprofit hospitals publish a lot:

• EMMA. A nonprofit health system that borrows through tax-exempt bonds, issued on its behalf by a state or local conduit agency, files continuing disclosures as the obligated borrower on the MSRB's EMMA website (MSRB). Search the system's name. Annual filings often include audited financial statements, and some systems also post quarterly results.
• Event notices. Under SEC Rule 15c2-12, notices of events such as missed principal or interest payments, rating changes, and bankruptcy or insolvency have to be filed within 10 business days (MSRB). A downgrade or a notice about a covenant waiver is a reason to stop deferring.
• Form 990. Nonprofit hospitals file an annual Form 990 with the IRS, and the filings are public; ProPublica Nonprofit Explorer posts them, with revenue, expenses and net assets by year.
• What to look for: operating losses year after year, shrinking cash, a recent downgrade, missed or delayed payments to vendors or to the 403(b), hospital closures or sales of service lines, and news of a sale-leaseback of the hospital's buildings. The hospital bankruptcy guide lists the warning signs that preceded recent failures.

3. Read the payout options

If the plan only pays a lump sum at separation, it works only if you expect to retire from that employer or move to a much lower income. If it offers installments over five or ten years and a later start date, you have room to manage the tax. Find out what happens by default if you don't elect.

4. Compare your tax rate now with your rate at payout

Deferring at a 35% federal rate and receiving the money at 24% is the whole case for the plan. Deferring at 24% and receiving it in a lump sum at 35% is a loss compared with a taxable account. If you expect to move from a high-tax state to a lower-tax one before the payouts start, the federal source-tax rule above adds to the benefit.

5. Check the investments and fees

Look at the fund menu and each fund's expense ratio, and any administrative fee charged to your account. A plan with only high-cost options eats into the tax benefit, especially if you will be there only a few years.

6. Think about how long you will stay

A physician who expects to leave in two or three years for another full-time job will likely be paid out, or start installments, while earning a full salary, which is the worst tax case in the example above. A physician planning to retire from the system, or to step down to part-time work there, gets the most from the plan.

The bottom line

Use a governmental 457(b) like a second 403(b). Use a non-governmental 457(b) only after the protected accounts are full, only with an employer whose public filings look sound, only with payout options that let you spread the income, and only in amounts you could afford to lose if the employer failed. Revisit the decision every year at open enrollment. If the balance becomes a large part of your net worth, our estate planning guide covers naming beneficiaries on accounts like this one.

Sources

1. 26 U.S.C. 457, Deferred compensation plans of State and local governments and tax-exempt organizations (Cornell LII). Eligible employers, trust requirement for governmental plans (457(g)), additional deferral election (457(e)(9)).
2. 26 CFR 1.457-6 (timing of distributions, unforeseeable emergencies), 1.457-7 (taxation of distributions, election timing), 1.457-8 (funding rules), and 1.457-10 (plan-to-plan transfers).
3. Non-governmental 457(b) deferred compensation plans, IRS. Unfunded requirement, employer ownership, rabbi trusts, top-hat participation.
4. Comparison of tax-exempt 457(b) plans and governmental 457(b) plans, IRS. Its dollar figures are from earlier years; the rules are current.
5. IRC 457(b) deferred compensation plans, IRS. Special catch-up and the Roth catch-up rule.
6. IRC section 457(b) eligible deferred compensation plan: written plan requirements, IRS. Eligible employers and the church exclusion.
7. Issue snapshot: section 457(b) plan of governmental and tax-exempt employers, catch-up contributions, IRS. Special catch-up, normal retirement age, employer contributions within the limit.
8. Issue snapshot: 457(b) plan of tax-exempt entity, tax consequences of noncompliance, IRS. No rollovers from tax-exempt plans.
9. Retirement topics: 457(b) contribution limits and How much salary can you defer if you're eligible for more than one retirement plan?, IRS.
10. Notice 2025-67: 2026 amounts relating to retirement plans and IRAs and IR-2025-111, IRS, November 13, 2025.
11. Retirement topics: catch-up contributions, IRS.
12. Catch-up contributions, final regulations, 90 FR 44527, September 16, 2025, and IR-2025-91, IRS.
13. Topic 558: additional tax on early distributions from retirement plans other than IRAs, IRS; Information letter INFO 2001-0099, IRS; 26 U.S.C. 72(t) and 26 U.S.C. 4974(c) (Cornell LII).
14. Notice 2003-20: eligible deferred compensation plans under section 457, IRS. Taxation when paid or made available; W-2 reporting.
15. Notice 98-8, IRS. The additional deferral election.
16. Notice 2020-68, IRS. In-service distributions at 59 and a half for governmental 457(b) plans.
17. Instructions for Forms 1099-R and 5498 (2026), IRS.
18. Rollover chart and Rollovers of retirement plan and IRA distributions, IRS.
19. Publication 571: tax-sheltered annuity plans (403(b) plans), IRS; 26 CFR 1.403(b)-8 (funding).
20. 29 U.S.C. 1103 (ERISA section 403), 4 U.S.C. 114, and 11 U.S.C. 547 (Cornell LII).
21. Steward Health Care seeks bankruptcy protections, WBUR, May 6, 2024; Judge allows bankrupt Steward to keep employee retirement funds, WBUR, May 1, 2025.
22. Steward doctors launch fight over deferred compensation plans, Bloomberg Law.
23. Cerberus, former Steward Health Care private equity owner, settles with creditors, Boston Globe, July 30, 2026.
24. Will Hahnemann's bankruptcy pave the way for a stable St. Christopher's children's hospital?, Philadelphia Inquirer, July 1, 2019; Prospect Medical Holdings files for Chapter 11 bankruptcy, Fierce Healthcare, January 2025.
25. EMMA, SEC Rule 15c2-12: continuing disclosure, and The conduit issuer's guide to continuing disclosures, Municipal Securities Rulemaking Board.

Rules and limits checked November 5, 2026.