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PeerBasis
Compensation Comparability Determination

Holy Ghost Association Inc

Executive Director / CEO

EIN 042054657
MA · NTEE S20
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Emily Freeman-miller, Executive Director / CEO ($18,221) against every comparable organization that fit the selection criteria — 322 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 8th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Emily Freeman-miller — reported title “ASST TREASURER”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

322 organizations qualified on sector, size, and geography 322 within the band form the benchmarked peer set.

Distribution of comparable compensation

$659 total compensation of comparable organizations → $269,604 $18,221
$21,46110th
$47,41925th
$73,030Median
$93,86475th
$126,94590th
$18,221This org · 8th
p10$21,461
p25$47,419
p50$73,030
p75$93,864
p90$126,945
$18,221

Comparable organizations

Each figure is Form 990 Part VII columns D + F (reportable pay plus other compensation and benefits; column F may include amounts from related organizations), normalized to MA cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateRevenueMatched titleComp
(reported)
Comp
(adjusted)
FY
The Montgomery Institute MS$402,323 President $52,000 $62,600 2024
Whitestone Community Association AK$402,005 Secretary $13,824 $14,285 2024
Ripley County Caring Community MO$403,145 Executive Di $50,715 $58,060 2024
Hamilton Partnership For Paterson Inc NJ$403,168 Former Exec Dir $72,000 $69,484 2024
Stuart Main Street Assoc Inc FL$401,086 Executive Director $66,090 $67,109 2024
Engage Winona MN$404,673 Executive Director $68,000 $72,627 2024
Anacostia Trails Heritage Area Inc MD$405,305 Executive Director $84,612 $83,299 2025
Watershed Human And Community Development Agency Inc AR$399,384 Treasurer $30,034 $37,569 2023
Westown Community Development Corp OH$398,892 Executive Di $84,078 $96,256 2024
Streets Are For Everyone CA$406,388 Executive Dir. $27,375 $25,551 2024
One Wake NC$407,238 Executive Director $109,791 $122,620 2024
The Tatanka Funds Incorporated SD$396,706 Executive Director (Thru July 24) $69,954 $83,449 2024
Friends Of Finland And Community MN$396,245 Executive Director $38,628 $41,257 2024
Renewall Inc WV$396,012 Executive Dir. $42,700 $51,449 2023
Staten Island Urban Center Inc NY$409,827 Ceo & Founder $78,430 $78,867 2023
West Indianapolis Development Corp IN$410,024 Executive Director $114,000 $133,783 2023
Associated Neighborhood Centers OH$410,835 Executive Director $48,500 $55,525 2024
Star-tec Enterprises Inc FL$410,918 President Ceo $200,000 $197,849 2025
New Birth Community Development CA$411,445 Board President, Executive Director $22,155 $21,289 2023
Dineh Cooperatives Incorporated AZ$411,616 Interim President & Ceo (Thru 09/24) $122,805 $127,659 2024
Southern Palmetto Foundation SC$392,774 President And Ceo $79,281 $89,400 2024
Seedleaf Inc KY$392,362 Executive Director $65,000 $75,483 2024
Adult Care Center Of The Northern VA$412,644 Executive Director $56,073 $60,249 2023
Compassion Ministries Of Waco TX$413,125 Executive Director $67,000 $74,582 2023
Seymour Main Street Inc IN$413,471 Executive Director $49,275 $57,826 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MA cost of living and 2023 dollars. Click any organization to verify the figure on ProPublica.

Methodology

Comparable organizations were drawn from electronically filed IRS Form 990 returns and matched on sector (NTEE code), budget (a size-adaptive revenue band that tightens as the organization grows), and geography (same-state first, broadening only when too few peers qualify); every organization within the band forms the peer set. To compare fairly across regions and years, peer compensation is normalized to MA cost of living (BEA Regional Price Parities, 2023) and to the subject's filing year (CPI-U). The figure benchmarked is Form 990 Part VII, Section A, columns D + F — reportable pay plus other compensation, benefits, and deferred amounts (column F may include amounts from related organizations) — with the chief executive matched by role. Related-organization amounts (column E) and institutional trustees are excluded. Full methodology: peerbasis.org/methodology.

Sample, role match & sensitivity

Sensitivity — the subject's percentile under alternative compensation definitions:

BasisSubject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default8th
Total compensation (D + F), as reported (no adjustments)9th
Reportable pay only (column D), adjusted12th
All sources (D + E + F), adjusted7th

If the percentile moves materially across these definitions, the result is sensitive to methodology choices, and the board should weigh which basis best fits its facts.

Rebuttable presumption of reasonableness · 26 CFR 53.4958-6

Compensation paid by a tax-exempt organization is presumed reasonable — shifting the burden to the IRS — when three requirements are met. This report supplies the comparability data for the second. The board should record the following in its minutes concurrently with its decision:

Draft board minutes — executive compensation

  1. The compensation of the Executive Director / CEO (Emily Freeman-miller) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
  2. Prior to its determination, the authorized body obtained and relied upon appropriate comparability data, namely the PeerBasis Compensation Comparability Determination dated June 9, 2026, comparing compensation against 322 similarly situated organizations (Same NTEE sector (S20), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $18,221 is reasonable (approximately the 8th percentile of comparable organizations) and documented the basis for this determination concurrently, on [date], by a vote of [__ for / __ against].

Sources: IRS Form 990 e-file data (apps.irs.gov); IRS Business Master File (NTEE classification). Every figure traces to an original public filing — click any organization above to verify it on ProPublica. PeerBasis is a service of Prismind Analytics; its methodology is published, was commissioned for independent adversarial review, and discloses its own limitations. This report is comparability data to support a board's good-faith determination under IRC 4958; it is not legal or tax advice. Generated by PeerBasis on June 9, 2026.