Live preview — download the board-ready PDF to attach to your minutes.Download the free PDF

PeerBasis

Compensation Comparability Determination

The Esther R Sanger Center For

Executive Director / CEO

EIN 042798929
MA · NTEE P85Z
FY ending 2023-06-30
June 9, 2026

This analysis benchmarks the total compensation of Herbert Newell, Executive Director / CEO ($17,704) against every comparable organization that fit the selection criteria — 7 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 43^rd percentile of comparable organizationswithin the typical range

How comparable organizations were selected

SectorOrganizations sharing the subject's NTEE classification (P85Z).
BudgetTotal revenue between $157 and $628 — 0.50× to 2.00× the subject's $314 (the band tightens as size grows).
GeographySame NTEE major group (P), nationwide + budget 0.5–2× revenue.

7 organizations qualified on sector, size, and geography → 7 within the band form the benchmarked peer set.

Distribution of comparable compensation

$7,11010th

$10,50325th

$29,219Median

$48,43375th

$66,05390th

$17,704This org · 43rd

p10$7,110

p25$10,503

p50$29,219

p75$48,433

p90$66,053

$17,704

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.

Organization	State	Total revenue	Total comp	Source
Paul Outreach Services Inc	AL	$301	$10,405	990
Donna & Michael Maddin Support	MI	$260	$29,219	990
Green River Independent Living-ii Inc	KY	$197	$31,201	990
Queens Housing And Immigration Center	NY	$478	$66,634	990
Shekahn Inc	NY	$500	$2,168	990
Bahia Foundation	CA	$511	$10,601	990
Eastview Unity Apartments Inc	WV	$524	$65,665	990

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

Peer count7 organizations — below 15; treat the percentiles as indicative, not precise. Compensation range $2,168–$66,634; filing years 2022–2024.
Size basisMatched on total revenue ($314); for reference, expenses $1,383 and assets $562,688. Revenue and expenses diverge this year — revenue may misrepresent operating size; weigh the expense-based view.
Role matchHerbert Newell, reported title "BOARD PRESID", benchmarked as Executive Director / CEO. Selected as the organization's highest-paid individual without an exact title match — the board should confirm this is a comparable role.
Related-org pay4 peers report related-organization compensation (column E), which the D + F benchmark does not fully capture; review where material.

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

Basis	Subject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default	43^rd
Total compensation (D + F), as reported (no adjustments)	43^rd
Reportable pay only (column D), adjusted	0^th
All sources (D + E + F), adjusted	43^rd

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

The compensation of the Executive Director / CEO (Herbert Newell) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
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 7 similarly situated organizations (Same NTEE major group (P), nationwide + budget 0.5–2× revenue).
The authorized body determined that total compensation of $17,704 is reasonable (approximately the 43^rd 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). 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.