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PeerBasis
Compensation Comparability Determination

Legacy Health

Executive Director / CEO

EIN 237426300
OR · NTEE E210
FY ending 2024-03-31
June 9, 2026

This analysis benchmarks the total compensation of Kathryn Correia, Executive Director / CEO ($3,861,658) against every comparable organization that fit the selection criteria — 22 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 68th percentile of comparable organizationswithin the typical range

Benchmarked executive: Kathryn Correia — reported title “President & CEO”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

22 organizations qualified on sector, size, and geography 22 within the band form the benchmarked peer set.

Distribution of comparable compensation

$26,112 total compensation of comparable organizations → $12,142,791 $3,861,658
$91,41610th
$651,31325th
$1,514,122Median
$3,980,41775th
$4,839,72790th
$3,861,658This org · 68th
p10$91,416
p25$651,313
p50$1,514,122
p75$3,980,417
p90$4,839,727
$3,861,658

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 OR 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
Alegent Creighton Health NE$510,743,051 President Cumc-bergan Mercy (Termed 3/4/23) $890,021 $1,061,257 2023
Mclaren Greater Lansing MI$516,858,010 Board Member, Pres./ceo Mhcc Flint $44,181 $49,106 2024
Wheeling Hospital Inc WV$524,903,541 President/ceo $507,273 $608,911 2023
Centura Health Corporation CO$527,619,633 President & Ceo $4,562,270 $4,849,889 2023
Pasco-pinellas Hillsborough Community FL$482,549,066 Dir/chair/ceo Heartland Region $166,168 $168,095 2024
🔒 17 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 OR 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 OR 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 default68th
Total compensation (D + F), as reported (no adjustments)82nd
Reportable pay only (column D), adjusted73rd
All sources (D + E + F), adjusted68th

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 22-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.