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PeerBasis
Compensation Comparability Determination

White Earth Tribal & Community College

Executive Director / CEO

EIN 411954988
MN · NTEE B11
FY ending 2024-09-30
June 9, 2026

This analysis benchmarks the total compensation of Anna Sheppard, Executive Director / CEO ($13,679) against every comparable organization that fit the selection criteria — 8 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 25th percentile of comparable organizationswithin the typical range

Benchmarked executive: Anna Sheppard — reported title “COLLEGE PRESIDENT”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

8 organizations qualified on sector, size, and geography 8 within the band form the benchmarked peer set.

Distribution of comparable compensation

$2,677 total compensation of comparable organizations → $495,977 $13,679
$7,38410th
$22,79625th
$67,089Median
$124,11675th
$246,21890th
$13,679This org · 25th
p10$7,384
p25$22,796
p50$67,089
p75$124,116
p90$246,218
$13,679

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
Cougar Property Holdings WA$823 Secretary And Treasurer $55,667 $50,439 2024
1846 Enterprises Inc IN$790 Chair $78,462 $83,738 2024
Os Complex Inc FL$1,525 President $146,393 $139,179 2024
Digilearn Digital Learning Institute NC$1,574 Executive Director $2,560 $2,677 2024
Frederick Douglass Entrepreneurial IL$1,650 Director Of Operations $119,700 $119,095 2024
Benton Harbor Promise Foundation MI$1,703 Executive Director $9,000 $9,401 2024
Virginia State University Research Foundation VA$2,000 Chairman $521,000 $495,977 2025
University Technology Development Corporation NE$2,029 President $25,045 $27,261 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 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 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 default25th
Total compensation (D + F), as reported (no adjustments)25th
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted38th

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 (Anna Sheppard) 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 8 similarly situated organizations (Same NTEE major group (B), nationwide + budget 0.5–2× revenue).
  3. The authorized body determined that total compensation of $13,679 is reasonable (approximately the 25th 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.