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PeerBasis
Compensation Comparability Determination

The Heritage Foundation

Executive Director / CEO

EIN 237327730
DC · NTEE W050
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Kevin Roberts, Executive Director / CEO ($779,903) against every comparable organization that fit the selection criteria — 18 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 39th percentile of comparable organizationswithin the typical range

Benchmarked executive: Kevin Roberts — reported title “PRESIDENT”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

18 organizations qualified on sector, size, and geography 18 within the band form the benchmarked peer set.

Distribution of comparable compensation

$226,557 total compensation of comparable organizations → $6,959,383 $779,903
$441,72410th
$646,79925th
$931,602Median
$1,147,55075th
$2,840,47890th
$779,903This org · 39th
p10$441,724
p25$646,799
p50$931,602
p75$1,147,550
p90$2,840,478
$779,903

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 DC 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
Georgia Energy Cooperative GA$131,314,285 Ceo $615,121 $704,813 2024
Whatcom Educational Credit Union WA$138,092,209 President & Ceo $945,067 $992,693 2023
Empeople Credit Union IL$129,009,062 President $1,051,327 $1,212,616 2023
Judicial Watch Inc DC$127,656,836 President, Director $1,076,883 $1,076,883 2024
American Eagle Financial Credit Union CT$127,109,502 President/ceo $854,686 $913,204 2024
🔒 13 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 DC 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 DC 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 default39th
Total compensation (D + F), as reported (no adjustments)44th
Reportable pay only (column D), adjusted39th
All sources (D + E + F), adjusted50th

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 18-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.