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PeerBasis
Compensation Comparability Determination

Garden Terrace Commons Senior Housing

Executive Director / CEO

EIN 300003273
MN · NTEE L22
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Thomas Adams, Executive Director / CEO ($18,918) 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 5th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Thomas Adams — reported title “EXECUTIVE VICE PRESIDENT”, 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

$2,191 total compensation of comparable organizations → $158,313 $18,918
$18,91810th
$23,38925th
$52,250Median
$64,35275th
$65,57990th
$18,918This org · 5th
p10$18,918
p25$23,389
p50$52,250
p75$64,352
p90$65,579
$18,918

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 MN 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
Hudson Senior Housing Inc MN$256,839 President/tr $68,006 $64,352 2025
Cheyenne Senior Housing Inc MN$250,150 President/tr $68,006 $64,352 2025
Bozeman Senior Housing Inc MN$268,145 President/tr $68,006 $64,352 2025
Catholic Eldercare At St Hedwig's MN$242,381 President/ceo $33,545 $32,583 2024
Asi Freeport Senior Housing Inc MN$227,228 President/tr $65,715 $63,830 2024
Ebenezer Lakes Senior Housing MN$225,186 President $77,189 $77,189 2023
New Richmond Senior Housing Inc MN$286,056 President & Ceo $41,871 $40,670 2024
River Town Heights Inc MN$224,666 President And Ceo $41,871 $40,670 2024
Franklin Senior Housing MN$223,134 Executive Vp Of Commonbond Housing $18,918 $18,918 2023
Independent Living Waipahu Inc MN$288,164 President/tr $65,715 $65,715 2023
Clark County Supportive Housinginc MN$221,935 President/tr $68,006 $64,352 2025
Owatonna Senior Housing Inc MN$221,450 President/tr $68,006 $64,352 2025
Boulevard Gardens Senior Housing MN$291,169 Eexecutive Vp Commonbond Housing $18,918 $18,918 2023
Wellstone Commons Senior Housing MN$218,737 Executive Vice President $18,918 $18,918 2023
Good Shepherd Senior Apartments MN$215,235 Administrator $2,256 $2,191 2024
Asi Dakota County Inc MN$188,708 President/tr $68,006 $64,352 2025
Community For Affordable Senior MN$335,417 Evp Of Commonbond Housing $18,918 $18,918 2023
Tonopah Lamb Senior Housing Inc MN$172,831 President/tr $68,006 $64,352 2025
Rosewood Court Inc MN$355,963 Ceo Of Bhs $158,313 $158,313 2023
Shepherd Oaks West Apartments Inc MN$361,165 President/ceo/administrato $26,425 $25,667 2024
Centennial Square MN$363,314 Ceo $39,249 $39,249 2023
Riverview Apartments Senior Housing MN$365,928 Executive Vp Of Commonbond $23,297 $22,629 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MN cost of living and 2023 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 MN 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 default5th
Total compensation (D + F), as reported (no adjustments)5th
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted14th

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 (Thomas Adams) 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 22 similarly situated organizations (Same NTEE sector (L22) + MN + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $18,918 is reasonable (approximately the 5th 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.