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PeerBasis
Compensation Comparability Determination

Citizens For Prison Reform

Executive Director / CEO

EIN 455617939
MI · NTEE I40
FY ending 2024-09-30
June 9, 2026

This analysis benchmarks the total compensation of Lois Pullano, Executive Director / CEO ($52,515) 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 59th percentile of comparable organizationswithin the typical range

Benchmarked executive: Lois Pullano — reported title “EXECUTIVE DI”, 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

$418 total compensation of comparable organizations → $163,717 $52,515
$9,38810th
$25,26125th
$49,367Median
$71,56575th
$99,17790th
$52,515This org · 59th
p10$9,388
p25$25,261
p50$49,367
p75$71,565
p90$99,177
$52,515

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 MI 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
Freer Records Inc NY$159,647 Co Exec Dire $45,356 $39,708 2024
Stephens Place PA$157,670 Executive Director $14,604 $14,526 2023
Bethany House Ministries Inc MA$175,854 President $60,000 $52,237 2024
Circle Of Hope Ministries Inc SC$144,339 President And Executive Director $13,920 $14,069 2024
The Starts Within Organization OH$132,733 Executive Director $37,500 $39,617 2023
Ekolu Mea Nui HI$198,570 President $23,444 $20,936 2023
Black Liberation Fund SC$203,633 President $120,000 $121,288 2024
Getpaid Inc PA$204,940 Executive Vice President $45,523 $43,982 2024
Reaching Out From Within Inc KS$209,688 Executive Director $68,125 $73,410 2023
Taking Action For Good TN$115,785 Founder & Ceo $150,000 $163,717 2022
Greater Falls Community Justice Center VT$212,483 Executive Director $49,920 $48,680 2024
New Life Mission Inn - Missouri MO$212,605 Executive Di $36,193 $38,236 2023
Sustainable Alamance NC$215,496 Director $50,000 $50,053 2024
Haiti Prison And Rehabilitation Ministry TX$218,379 Chairman $9,150 $8,868 2024
On My Grind Reentry Services Inc CA$218,608 President & Ceo $7,360 $6,339 2023
The Rise Partnership Inc NY$220,000 Director/president $68,554 $61,789 2023
The Help MO$220,300 President $97,812 $100,369 2024
Inside Out Network Inc AZ$225,997 President And Executive Director $89,165 $83,080 2024
Ronnies House CA$230,126 Executive Director $500 $418 2024
Jumpstart SC$239,883 President $85,000 $88,450 2023
Battered But Not Broken SC$245,008 Executive Director And Founde $50,485 $52,534 2023
Women Of Hope Inc OH$245,629 Executive Director $62,500 $66,028 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MI 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 MI 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 default59th
Total compensation (D + F), as reported (no adjustments)59th
Reportable pay only (column D), adjusted59th
All sources (D + E + F), adjusted55th

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 (Lois Pullano) 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 (I40), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $52,515 is reasonable (approximately the 59th 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.