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PeerBasis
Compensation Comparability Determination

Expect Miracles Foundation

Executive Director / CEO

EIN 204127495
MA · NTEE T30
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Frank Heavey, Executive Director / CEO ($333,698) against every comparable organization that fit the selection criteria — 130 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 95th percentile of comparable organizationsabove the 90th percentile — board review recommended

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

How comparable organizations were selected

130 organizations qualified on sector, size, and geography 130 within the band form the benchmarked peer set.

Distribution of comparable compensation

$5,057 total compensation of comparable organizations → $1,024,017 $333,698
$29,46210th
$56,88425th
$129,324Median
$196,54575th
$258,77890th
$333,698This org · 95th
p10$29,462
p25$56,884
p50$129,324
p75$196,545
p90$258,778
$333,698

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
Education Foundation Of Collier County FL$3,538,445 Ceo/president $185,704 $194,137 2024
The Hawn Foundation CA$3,527,941 Managing Director $215,652 $213,346 2023
Seattle International Foundation WA$3,572,123 Sif Executive Director $41,628 $42,700 2023
Opencollective Foundation CA$3,517,192 General Manager Finance $158,845 $152,638 2024
Mara Elephant Project Usa Inc IN$3,600,184 Exec Director, Secretary, Asst Treasurer $68,000 $82,158 2023
🔒 125 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 MA cost of living and 2024 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 default95th
Total compensation (D + F), as reported (no adjustments)95th
Reportable pay only (column D), adjusted96th
All sources (D + E + F), adjusted79th

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 130-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.