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PeerBasis
Compensation Comparability Determination

Needle Exchange Emergency Distribution

Executive Director / CEO

EIN 260529276
CA · NTEE E70
FY ending 2024-06-30
June 9, 2026

This analysis benchmarks the total compensation of Bolton Littlefield, Executive Director / CEO ($36,772) against every comparable organization that fit the selection criteria — 124 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 21st percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Bolton Littlefield — reported title “Director”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

124 organizations qualified on sector, size, and geography 124 within the band form the benchmarked peer set.

Distribution of comparable compensation

$119 total compensation of comparable organizations → $331,050 $36,772
$14,14910th
$47,41225th
$87,313Median
$112,54575th
$148,38690th
$36,772This org · 21st
p10$14,149
p25$47,412
p50$87,313
p75$112,545
p90$148,386
$36,772

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 CA 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
Wisconsin Northern Highland Ahec Inc WI$314,699 Executive Dir. $100,928 $118,921 2025
Breastfeeding Outreach For Our OH$313,880 Executive Di $151,218 $185,481 2024
His Healing Hands CA$311,958 Ceo $93,936 $93,936 2024
Intercultural Center For Health Research And Wellness TX$318,990 President $96,011 $114,508 2023
Starting Hearts CO$310,830 Executive Director $92,000 $105,179 2023
November Project Inc MA$319,483 Executive Dir. $110,000 $117,854 2023
La Casa De La Salud VA$319,985 Officer $43,000 $48,081 2024
Midwest Street Medicine SD$308,652 Medical Director $30,000 $37,355 2025
Upstream Public Health OR$308,414 Executive Director $55,500 $59,688 2024
The Fairfield County Medical Association CT$321,696 Executive Director Through 5/1/24 $129,977 $141,132 2024
Nevada Medical Center Inc NV$305,650 President $85,800 $97,031 2025
Boone County Hospital Foundation IA$298,829 Executive Dir. $26,449 $32,673 2025
Trust Chw TX$331,457 Founder $10,935 $12,668 2024
Faith Hope & Love Christian Ministr GA$297,330 Medical Dire $136,500 $158,944 2024
Northwest Pa Area Health Education Cente PA$296,918 Executive Dir. $74,279 $83,571 2025
Community Access To Coordinated NE$333,588 Executive Di $61,792 $79,240 2023
Playmakers Fitness Foundation Inc MI$333,631 Executive Director $118,046 $141,104 2024
Integrated Center For Group Medical MA$334,755 Director $21,578 $22,455 2024
Azcert AZ$295,291 Coo $151,000 $173,143 2023
American Migraine Foundation Inc NY$294,663 Executive Director $1,000 $1,046 2024
Holistic Health Community Inc NY$294,421 Executive Director $85,200 $89,159 2024
Family Voices Of Minnesota MN$293,977 Executive Director $70,686 $80,887 2024
Mundo De Ninos Academy CA$293,914 President $16,647 $16,647 2024
Hueman Partnership MN$292,159 Executive Director $103,442 $118,370 2024
Arts And Healing Initiative CA$339,180 Executive Direc $119 $119 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to CA 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 CA 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 default21st
Total compensation (D + F), as reported (no adjustments)23rd
Reportable pay only (column D), adjusted23rd
All sources (D + E + F), adjusted16th

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 (Bolton Littlefield) 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 124 similarly situated organizations (Same NTEE sector (E70), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $36,772 is reasonable (approximately the 21st 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.