$104M spent annually lobbying Beacon Hill. 8 lobbyists per lawmaker. 82% of their donations at exactly $200 — the legal cap. All from public records.
Step 1: Organization receives taxpayer funding (MassHealth contracts, grants, state procurement).
Step 2: Organization hires lobbying firm to maintain and increase that funding ($104M/year).
Step 3: Firm's lobbyists each donate $200 to every key politician — systematically, across all leadership.
Step 4: Organization's executives also donate personally to the same politicians.
Step 5: Lobbyists and executives donate unlimited amounts to lawmakers' personal nonprofits (legal, no disclosure).
Step 6: Politicians vote to maintain or increase the organization's funding.
Step 7: Repeat annually. Taxpayers fund the entire cycle.
| # | Organization | Total Spent | Sector |
|---|---|---|---|
| 1 | MA Health & Hospital Association | $7,414,139 | Health |
| 2 | MA Association of Health Plans | $6,499,713 | Health |
| 3 | Association for Behavioral Healthcare | $4,461,402 | Health |
| 4 | MA Biotechnology Council (MassBio) | $4,371,545 | Health |
| 5 | MA Teachers Association | $3,890,866 | Labor |
| 6 | MA Nurses Association | $3,775,296 | Health |
| 7 | Retired State/County/Muni Employees Assoc. | $3,670,853 | Labor |
| 8 | Blue Cross Blue Shield of MA | $3,626,072 | Health |
| 9 | MA Assn of Health Plans (2nd filing) | $3,444,644 | Health |
| 10 | MA Municipal Association | $3,410,125 | Gov't |
| 11 | Partners Healthcare System (MGB) | $3,240,888 | Health |
| 12 | SEIU Local 32BJ | $3,216,014 | Labor |
| 13 | Eversource Energy | $3,065,502 | Energy |
| 14 | Verizon Communications | $2,876,224 | Telecom |
| 15 | Associated Industries of MA | $2,840,782 | Business |
| 16 | MA Property Insurance Underwriting Assoc. | $2,757,990 | Insurance |
| 17 | National Grid USA | $2,705,993 | Energy |
| 18 | Harvard Pilgrim Health Care | $2,685,839 | Health |
| 19 | Eli Lilly & Co | $2,618,267 | Pharma |
| 20 | MA Medical Society | $2,565,024 | Health |
These firms earn millions lobbying politicians — then their employees personally donate to those same politicians. OCPF records from just 3 firms reveal 4,298 individual donations totaling $822,463.
| # | Lobbyist | Firm | Total Given | # Donations | Avg Amount |
|---|---|---|---|---|---|
| 1 | David Shapiro | Bay State Strategies | $72,100 | 392 | $184 |
| 2 | Michael Costello | Smith Costello & Crawford | $59,550 | 298 | $200 |
| 3 | Jim/James Smith | Smith Costello & Crawford | $53,240 | 272 | $196 |
| 4 | Jennifer Crawford | Smith Costello & Crawford | $44,350 | 225 | $197 |
| 5 | Carlo Basile | Smith Costello & Crawford | $24,250 | 122 | $199 |
| 6 | Francis Shea | Bay State Strategies | $17,450 | 75 | $233 |
| 7 | Jay Youmans | Smith Costello & Crawford | $17,100 | 86 | $199 |
| 8 | Stephen Tocco | ML Strategies | $14,725 | 67 | $220 |
| 9 | Robert Bernstein | Bay State Strategies | $10,600 | 55 | $193 |
| 10 | Stephen Silveira | ML Strategies | $10,575 | 59 | $179 |
Every top politician in Massachusetts receives donations from ALL THREE major lobbying firms. The amounts are modest — but the pattern is what matters.
| # | Politician | Total | # Donations | Source Firms |
|---|---|---|---|---|
| 1 | Robert DeLeo (Former Speaker) | $21,200 | 111 | All 3 |
| 2 | Maura Healey (Governor) | $19,736 | 96 | All 3 |
| 3 | John Lawn | $17,250 | 90 | All 3 |
| 4 | Aaron Michlewitz (Budget Chair) | $16,800 | 85 | All 3 |
| 5 | Mark James Cusack | $16,400 | 82 | All 3 |
| 6 | Charlie Baker (Former Governor) | $15,500 | 59 | All 3 |
| 7 | Karyn Polito (Former Lt. Gov.) | $14,000 | 67 | All 3 |
| 8 | Barry Finegold | $12,450 | 67 | All 3 |
| 9 | Michael Moran | $12,000 | 62 | All 3 |
| 10 | James Murphy | $12,000 | 62 | All 3 |
| 11 | Bruce Tarr (Senate Minority Leader) | $11,400 | 58 | All 3 |
| 12 | Mitt Romney | $11,400 | 39 | ML Strategies |
| 13 | Dem Senate PAC | $10,925 | 60 | All 3 |
| 14 | Karen Spilka (Senate President) | $10,825 | 57 | Bay State, ML |
| 15 | Ronald Mariano (Speaker) | $10,800 | 51 | All 3 |
| 16 | Therese Murray | $10,500 | 58 | Bay State, ML |
| 17 | Daniel Ryan | $10,000 | 51 | All 3 |
| 18 | Michael Day | $9,750 | 49 | All 3 |
| 19 | Jeffrey Roy (Energy Chair) | $9,100 | 46 | All 3 |
| 20 | Marjorie Decker | $8,950 | 47 | All 3 |
| 21 | Daniel Hunt | $8,925 | 50 | All 3 |
| 22 | Kimberley Driscoll (Lt. Gov.) | $8,500 | 41 | All 3 |
| 23 | Dem House PAC | $8,225 | 43 | All 3 |
| 24 | Martin Walsh (Former Mayor) | $7,725 | 42 | All 3 |
| 25 | Brendan Crighton | $7,700 | 39 | All 3 |
This is only the direct campaign donations from employees of three lobbying firms — it doesn't include the $76.7M in lobbying fees their clients paid, the unlimited donations to lawmaker nonprofits, or the fourth largest firm (O'Neill & Partners, $13.6M earned) whose OCPF data is unsearchable. The real money flowing through this system is orders of magnitude larger than what OCPF captures. And that's exactly how it's designed.
| Channel | Limit | Disclosure | Oversight |
|---|---|---|---|
| Individual to Candidate | $1,000/year | Public (OCPF) | OCPF enforcement |
| Lobbyist to Candidate | $200/year | Public (OCPF) | OCPF enforcement |
| Lobbyist to PAC | $200/year | Public (OCPF) | OCPF enforcement |
| Lobbyist to Lawmaker Nonprofit | UNLIMITED | NONE | NONE |
| To Ballot Question Committee | Unlimited | Public (OCPF) | Limited |
Christopher Philbin is VP of Government Affairs at Mass General Brigham — the state's largest hospital system. MGB receives billions from MassHealth. Philbin earned $93,128 in lobbying compensation (2021–2025). He then personally donated $5,600 to 28 politicians in 2024 — exactly $200 each (the legal maximum). Recipients include Gov. Healey, Senate President Spilka, AG Campbell, Mayor Wu, and Budget Chair Michlewitz. MGB employees collectively gave $19,522 to politicians in 2024 across 46 donors. This is one hospital system, one year. The pattern repeats across every major healthcare organization in the state.
| Branch of Government | Massachusetts | Most Other States |
|---|---|---|
| Governor's Office | ❌ EXEMPT | ✅ Subject to records law |
| Legislature | ❌ EXEMPT | ✅ Subject to records law |
| Judiciary | ❌ EXEMPT | ✅ Subject to records law (most) |
| Lawmaker Nonprofit Donors | ❌ NO DISCLOSURE | Varies |
| Audit Cooperation | ❌ VOLUNTARY | ✅ Mandatory (most) |
| Records Enforcement | ❌ NO AUTHORITY | ✅ Enforcement power |
Massachusetts has constructed a system where $104 million flows annually from special interests to lobbying firms, from lobbyist pockets to politician campaigns (at exactly $200 a pop), and from lobbyist checkbooks to lawmaker nonprofits (unlimited, undisclosed). All three branches of government are exempt from the public records law that would allow citizens to see how decisions are made. The state auditor cannot compel cooperation. The campaign finance database can't even search one of the top four firms. This isn't a loophole — it's architecture.