Live preview — download the board-ready PDF to attach to your minutes.Download the free PDF
Email yourself a copy:
PeerBasis
Compensation Comparability Determination

Free To Smile Foundation Inc

Executive Director / CEO

EIN 263538922
OH · NTEE F99
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Seth Conley, Executive Director / CEO ($120,260) against every comparable organization that fit the selection criteria — 49 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 98th percentile of comparable organizationsabove the 90th percentile — board review recommended

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

How comparable organizations were selected

49 organizations qualified on sector, size, and geography 49 within the band form the benchmarked peer set.

Distribution of comparable compensation

$5,126 total compensation of comparable organizations → $128,485 $120,260
$25,14610th
$48,71425th
$68,470Median
$85,31675th
$106,40190th
$120,260This org · 98th
p10$25,146
p25$48,714
p50$68,470
p75$85,316
p90$106,401
$120,260

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 OH 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
First Aid Arts WA$304,007 Board Member $62,694 $54,561 2023
Alliance180 Inc NY$306,877 Founder And Director $48,461 $42,566 2023
Breaking The Silence New Mexico NM$309,573 Executive Dir. $63,057 $64,034 2024
Employee Assistance Program Of Warren NY$312,220 Executive Dir. Effective $108,890 $95,644 2023
The Ark Foundation CA$297,592 President $62,219 $50,726 2024
California Chaplain Corps CA$313,397 Exec. Director $76,310 $62,214 2024
How To Read Your Baby CO$295,443 Executive Director $88,620 $80,230 2024
Mental Health News Education Inc MA$290,736 Executive Di $103,219 $85,316 2025
Faithbridge Portland OR$320,862 President $129,162 $116,593 2023
Intentions NC$289,140 Director $30,000 $30,131 2023
Operation Happy Nurse VA$286,417 Founder/principal Officer $39,000 $36,603 2023
St Bernard Parish Adult Drug Court Inc LA$324,421 Daigle $58,811 $62,948 2023
Comeback Yoga CO$325,609 Executive Director $106,420 $96,345 2024
Itp International CA$284,778 President $86,742 $72,807 2023
Mental Health Services Of Snohomish WA$283,668 President/ceo, Compass Health $29,848 $25,231 2024
Intouch Outreach Resource Ctr IN$280,000 Executive Director For Programs $108,000 $110,708 2023
Lower Shore Friends Inc MD$277,577 Executive Director $64,911 $58,989 2023
Unity Hall CA$275,819 Chairperson $112,628 $94,535 2023
Healing Hoofbeats Of Ct Inc CT$271,558 Executive Director $78,000 $71,089 2023
Dmax Foundation PA$269,972 Executive Di $100,719 $97,632 2023
Insight Treatment Program Inc AL$350,179 Executive Di $67,192 $68,536 2024
Kevins Song A Nonprofit Community MI$351,952 Executive Dir. $54,087 $52,709 2024
Made Of Millions Foundation Inc NY$242,670 Executive Director/chair Of The Board $29,073 $24,804 2024
Project Be Free A Nonprofit Corporation WA$371,130 Executive Director (Co-founder) $53,216 $46,313 2023
Nami Yolo County CA$237,958 Executive Director $87,400 $73,360 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to OH 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 OH 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 default98th
Total compensation (D + F), as reported (no adjustments)96th
Reportable pay only (column D), adjusted94th
All sources (D + E + F), adjusted96th

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 (Seth Conley) 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 49 similarly situated organizations (Same NTEE sector (F99), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $120,260 is reasonable (approximately the 98th 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.