Retirement – Teacher – Summer work

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Where a petitioner chose to teach for two extra weeks during the summer of 2024, the payments for those two weeks were not regular compensation.

Accordingly, the Massachusetts Teachers’ Retirement System’s decision not to include the two extra weeks toward the petitioner’s retirement calculation is affirmed.

“Pursuant to G.L.c. 32, §16(4), petitioner Margaret Sheehan appealed respondent Massachusetts Teachers’ Retirement System’s decision not to include towards her retirement calculation pay for two weeks during which she chose to work at a summer school program. …

“Before she retired in 2024, Ms. Sheehan was a teacher for the LABBB Collaborative (Collaborative). …

“Ms. Sheehan was a member of the LABBB Collaborative Education Association Unit A and was subject to the terms of a collective bargaining agreement (CBA). …

“The payments for Ms. Sheehan’s extra time were not a part of her fixed salary. She received these additional payments only if she worked the extra time. The Collaborative could not know from year to year whether, who, or for how long any of the teachers might choose to work. … Thus, the unpredictable and irregular nature of the extra work means that the payments for those two weeks were not regular compensation. …

“In addition to analyzing a teacher’s regular compensation under the usual rules, it is also important to determine whether Ms. Sheehan’s extra summer work constituted ‘additional services.’ …

“The work that Ms. Sheehan performed did not occur during the school year; it occurred outside of the 11 months that LABB required her to work. Therefore, the work that Ms. Sheehan performed fails to satisfy MTRS’ regulatory requirements for additional services. …

“Ms. Sheehan chose to work the extra two weeks with only the best of intentions; she was concerned about her students’ learning and overall well-being. However, the fact that she opted to take on the extra work, which was neither part of her core teaching duties nor qualified as additional services and which occurred outside of the school year, means that the payment for that work is not part of her regular compensation and should not be part of her retirement calculation.”

Sheehan v. Massachusetts Teachers’ Retirement System (Lawyers Weekly No. 27-033-26) (8 pages) (Goldberg, Administrative Magistrate) (Division of Administrative Law Appeals) Nathan Robinson for the petitioner; Ashley Freeman for the petitioner (Docket No. CR-25-0106) (March 20, 2026).

Click here to read the full text of the opinion.