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PeerBasis
Compensation Comparability Determination

Women's Refugee Commission Inc

Executive Director / CEO

EIN 463668128
NY · NTEE P80
FY ending 2024-09-30
June 9, 2026

This analysis benchmarks the total compensation of Sarah Costa, Executive Director / CEO ($292,059) against every comparable organization that fit the selection criteria — 119 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 92nd percentile of comparable organizationsabove the 90th percentile — board review recommended

How comparable organizations were selected

119 organizations qualified on sector, size, and geography 119 within the band form the benchmarked peer set.

Distribution of comparable compensation

$9,959 total compensation of comparable organizations → $751,831 $292,059
$83,80510th
$122,42225th
$147,068Median
$209,44775th
$265,20390th
$292,059This org · 92nd
p10$83,805
p25$122,422
p50$147,068
p75$209,447
p90$265,203
$292,059

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

OrganizationStateTotal revenueTotal compSource
Journey Home IncCT $6,332,935$179,780 990
The Boston Foundation For Sight IncMA $6,318,864$374,268 990
Futures Unlimited IncKS $6,303,854$208,015 990
Disability Rights LouisianaLA $6,267,653$22,458 990
Creative Living Options IncCA $6,427,381$150,901 990
🔒 114 more comparable organizations — included in the purchased report

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 NY 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 default92nd
Total compensation (D + F), as reported (no adjustments)95th
Reportable pay only (column D), adjusted89th
All sources (D + E + F), adjusted90th

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:

Ready-to-adopt board minutes — executive compensation

🔒 The complete minutes language — three numbered resolutions pre-filled with this organization, the 119-organization comparison, the date, and the percentile finding, ready to paste into your minutes — is included in the purchased report.

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Sources: IRS Form 990 e-file data (apps.irs.gov); IRS Business Master File (NTEE classification). 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.