Compensation Comparability

This analysis benchmarks the total compensation of Kelly Bull, Executive Director / CEO ($39,875) against every comparable organization that fit the selection criteria — 135 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 29^th percentile of comparable organizationswithin the typical range

How comparable organizations were selected

Distribution of comparable compensation

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 CO cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

Organization	State	Total revenue	Total comp	Source
Peak Research Institute	CO	$247,400	$30,360	990
Onelife For Life Inc	MI	$247,631	$68,316	990
Florida Preborn Rescue Inc	FL	$245,779	$121,966	990
Second Chance Education Inc	CA	$245,689	$55,173	990
Anewvista Community Services	CA	$248,249	$51,236	990
Harleys Dream	CO	$245,039	$52,000	990
Literacy Chippewa Valley	WI	$244,707	$49,889	990
Iowa City Unesco City Of Literature	IA	$244,011	$123,693	990
Marion County Literacy Council Inc	FL	$249,959	$63,085	990
Association For Machine Learning And Applications	CA	$251,017	$54,032	990
Run Hard Rest Well Inc	IN	$253,340	$67,936	990
Midcoast Literacy	ME	$239,926	$44,380	990
International Mentoring Foundation For	MA	$256,372	$65,024	990
Gull Island Institute Inc	MA	$237,443	$38,986	990
Collaborative Law Institute Of Texas	TX	$237,143	$82,212	990
First Place 4 Health	TX	$257,264	$65,563	990
Echo Collective	NE	$257,406	$43,499	990
National Coalition For Dialogue & Deliberation	PA	$236,025	$17,988	990
Kenosha Literacy Council	WI	$234,765	$57,992	990
Literacy Volunteers Of Broome-tioga	NY	$233,980	$45,397	990
Life Enrichment Center Of Norfolk	VA	$260,932	$110,849	990
Growing Oaks Association	OK	$232,819	$83,830	990
You Can Make It Home Ownership Ctr	TN	$261,432	$71,311	990
Minnesota Teachers Of English To Speakers Of Other Languages	MN	$231,475	$15,921	990
Skyline Agility Club Inc	NY	$229,644	$8,246	990

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 CO 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:

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

Basis	Subject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default	29^th
Total compensation (D + F), as reported (no adjustments)	30^th
Reportable pay only (column D), adjusted	33^rd
All sources (D + E + F), adjusted	22^nd

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

The compensation of the Executive Director / CEO (Kelly Bull) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
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 135 similarly situated organizations (Same NTEE sector (B60), nationwide + budget 0.67–1.5× revenue).
The authorized body determined that total compensation of $39,875 is reasonable (approximately the 29^th percentile of comparable organizations) and documented the basis for this determination concurrently, on [date], by a vote of [__ for / __ against].