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PeerBasis
Compensation Comparability Determination

Milestone Of Tn

Executive Director / CEO

EIN 208854937
TN · NTEE J22
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Judith M Pugh, Executive Director / CEO ($64,000) against every comparable organization that fit the selection criteria — 38 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 71st percentile of comparable organizationswithin the typical range

Benchmarked executive: Judith M Pugh — reported title “President”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

38 organizations qualified on sector, size, and geography 38 within the band form the benchmarked peer set.

Distribution of comparable compensation

$490 total compensation of comparable organizations → $139,114 $64,000
$9,56810th
$20,28725th
$43,409Median
$65,72075th
$89,12190th
$64,000This org · 71st
p10$9,568
p25$20,287
p50$43,409
p75$65,720
p90$89,121
$64,000

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 TN 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
Daytona Beach Electrical Joint Apprenticeship FL$208,382 Training Director / Ex. Direct $43,618 $40,133 2023
Woodwork Career Alliance Of North America VA$206,820 Scott Nelson President $48,575 $44,620 2024
Anders & Anders Foundation CA$204,545 Executive Director $37,175 $29,752 2025
Ibew Local 17 Joint 6-17-b Training MI$213,549 Trustee $60,174 $60,833 2023
Jobs For Americas Graduates Of Pennsylvania PA$200,009 Director $89,038 $82,295 2025
Fmha Empowerment Institute Llc NC$217,699 Secretary $9,469 $9,308 2024
Evvaylois Foundation TX$219,359 Ceo $24,605 $24,107 2023
Ri Hospitality Education Foundation RI$219,579 President/ceo $21,536 $20,226 2023
Auto Repair Transformation WA$223,137 Executive Dir. $50,834 $43,298 2024
International Association Of Heat & 53 A LA$227,422 Training Director $82,417 $86,337 2024
Eldreds Nursery Foundation TX$230,855 Board Member $500 $490 2023
Edu-tech Enterprises Inc GA$185,700 Director/program $73,900 $72,778 2023
Automotive Industry Apprenticeship Trust CA$232,917 Administrator $113,057 $95,618 2023
Baltimore Green Justice Workers MD$236,775 President $67,608 $60,132 2024
Montgomery Electrical Joint AL$179,875 Training Director $12,246 $12,586 2024
Insulators Local 37 Joint Apprenticeship IN$238,754 Director/administrator $79,709 $82,330 2023
West Central Ohio Manufacturing OH$244,260 Managing Director $56,700 $57,132 2024
Nsca Education Foundation IA$170,678 Executive Director $21,088 $21,967 2024
Friends Of The Gallatin National Forest MT$249,311 Treasurer $9,913 $10,166 2024
Bridge Of Tiftarea Inc GA$250,868 Director $34,327 $32,836 2024
Seattle Area Roofers WA$256,089 Trustee $24,032 $20,469 2024
Lake Superior Community Ptnrshp Foundation MI$157,791 Vice President $9,574 $9,679 2023
Plasterers & Cement Masons OH$262,365 Instructor $55,037 $57,095 2023
Tranzed Apprenticeship Ventures Inc MD$153,973 Chief Executive Officer $9,134 $8,364 2023
Internat'l Union Of Operating Engineers NY$264,242 Administrator $134,575 $119,107 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to TN 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 TN 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 default71st
Total compensation (D + F), as reported (no adjustments)68th
Reportable pay only (column D), adjusted79th
All sources (D + E + F), adjusted55th

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 (Judith M Pugh) 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 38 similarly situated organizations (Same NTEE sector (J22), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $64,000 is reasonable (approximately the 71st 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.