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PeerBasis
Compensation Comparability Determination

Public Policy And Education Fund

Executive Director / CEO

EIN 133364209
NY · NTEE W00F
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Rosemary Rivera, Executive Director / CEO ($90,204) against every comparable organization that fit the selection criteria — 161 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 12th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Rosemary Rivera — reported title “CO-EXEC DIR”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

161 organizations qualified on sector, size, and geography 161 within the band form the benchmarked peer set.

Distribution of comparable compensation

$656 total compensation of comparable organizations → $871,229 $90,204
$84,28410th
$140,30325th
$214,981Median
$300,89775th
$396,68890th
$90,204This org · 12th
p10$84,284
p25$140,303
p50$214,981
p75$300,897
p90$396,688
$90,204

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 NY 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
Kansas Fairgrounds Foundation KS$6,375,915 Executive Di $84,800 $98,474 2024
Club For Growth DC$6,233,764 President $923,638 $871,229 2024
Florida Rural Water Association FL$6,227,398 Executive Di $201,764 $209,757 2023
The Utility Reform Network CA$6,407,107 Executive Dir. $277,951 $265,609 2023
Combat Marine Outdoors Inc TX$6,205,231 Executive Di $117,000 $125,802 2024
🔒 156 more comparable organizations — included in the purchased report

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to NY 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 NY 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 default12th
Total compensation (D + F), as reported (no adjustments)12th
Reportable pay only (column D), adjusted13th
All sources (D + E + F), adjusted11th

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:

Ready-to-adopt board minutes — executive compensation

🔒 The complete minutes language — three numbered resolutions pre-filled with this organization, the 161-organization comparison, the date, and the percentile finding, ready to paste into your minutes — is included in the purchased report.

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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.