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PeerBasis
Compensation Comparability Determination

First Literacy Inc

Executive Director / CEO

EIN 042997446
MA · NTEE B190
FY ending 2023-06-30
June 9, 2026

This analysis benchmarks the total compensation of Theresa B Witherell, Executive Director / CEO ($150,000) against every comparable organization that fit the selection criteria — 59 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 92nd percentile of comparable organizationsabove the 90th percentile — board review recommended

Benchmarked executive: Theresa B Witherell — reported title “EXECUTIVE DIRECTOR”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

59 organizations qualified on sector, size, and geography 59 within the band form the benchmarked peer set.

Distribution of comparable compensation

$2,455 total compensation of comparable organizations → $244,150 $150,000
$9,28410th
$37,57725th
$69,721Median
$99,00475th
$142,68790th
$150,000This org · 92nd
p10$9,284
p25$37,577
p50$69,721
p75$99,004
p90$142,687
$150,000

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
Mathkind Global Inc NC$490,407 Executive Director $120,850 $138,958 2023
Kansas Educational Technology KS$486,444 Consortium D $109,162 $127,472 2024
Harvard Dedicated Energy Limited MA$495,351 Vice President And Treasurer $69,721 $69,721 2023
Mandela Ii Housing Development NY$497,717 Vice President $4,935 $4,696 2025
Rcs Building Corporation CO$477,851 President $2,453 $2,543 2024
Florida Emergency Medicine Teaching Alliance Inc TX$474,929 President $60,000 $64,874 2024
Aaron Academy TN$473,804 Principal $80,184 $91,103 2024
Virtual Properties MN$521,635 Secretary $113,122 $124,388 2023
Florida Charter School Alliance Inc FL$459,055 Executive Director $109,366 $114,332 2023
Allentown School District Foundation PA$524,154 Executive Director $57,288 $61,751 2024
Missouri Council Of Administrators MO$525,276 Executive Di $56,429 $66,510 2023
The Village Method CA$527,776 Executive Dir. $89,143 $85,660 2023
Sun Scholars Inc CT$450,377 Executive Director $73,886 $77,092 2023
Cal Poly Humboldt Real Estate Holdings CA$448,190 President, Secretary $112,869 $105,347 2024
Brooklyn Book Festival Inc NY$534,571 Vice President $75,000 $75,418 2023
Resources For Indian Student Education CA$535,363 Executive Director $74,500 $69,535 2024
Mcny Bronx Inc NY$540,285 President $15,038 $14,688 2024
New York Coalition For Healthy School NY$440,629 Executive Director $94,987 $92,776 2024
Southwestern Ohio Instructional OH$440,077 President & Ceo $20,050 $22,954 2024
Cuny Graduate School Auxiliary NY$547,987 Member $55,971 $56,283 2023
Wisconsin Automotive And Truck Education WI$429,207 Executive Director $63,858 $74,215 2023
Bio-link Depot Inc CA$556,805 Executive Director $82,500 $77,002 2024
Beex Foundation OH$558,067 Program Director $36,000 $41,214 2024
The 4c Foundation Inc GA$562,173 Ceo/the 4c A $36,006 $38,124 2025
Wings Homeschool Group MN$565,438 President $93,609 $99,978 2024

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 default92nd
Total compensation (D + F), as reported (no adjustments)93rd
Reportable pay only (column D), adjusted97th
All sources (D + E + F), adjusted73rd

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 (Theresa B Witherell) 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 59 similarly situated organizations (Same NTEE sector (B19), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $150,000 is reasonable (approximately the 92nd 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.