Executive Director / CEO
This analysis benchmarks the total compensation of Virginia Foulkrod, Executive Director / CEO ($163,644) against every comparable organization that fit the selection criteria — 74 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.
Compensation sits at approximately the 72nd percentile of comparable organizationswithin the typical range
Benchmarked executive: Virginia Foulkrod — reported title “EXECUTIVE DI”, a direct title match to the Executive Director / CEO role.
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.
| Organization | State | Revenue | Matched title | Comp (reported) | Comp (adjusted) | FY |
|---|---|---|---|---|---|---|
| Oklahoma Indian Legal Services Inc | OK | $2,439,151 | Executive Director | $147,406 | $174,472 | 2024 |
| Counsel For Defense Of Chelan County | WA | $2,438,857 | Executive Dir. | $227,380 | $225,286 | 2023 |
| Legal Services Of Northern Michigan | MI | $2,450,146 | Executive Director | $132,821 | $147,362 | 2024 |
| Delaware Volunteer Legal Services Inc | DE | $2,460,602 | Executive Director | $159,455 | $167,826 | 2024 |
| Heart Of Missouri Casa | MO | $2,406,137 | Exceutive Director | $95,031 | $105,402 | 2025 |
| 🔒 69 more comparable organizations — included in the purchased report | ||||||
Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to NY cost of living and 2023 dollars. Click any organization to verify the figure on ProPublica.
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.
Sensitivity — the subject's percentile under alternative compensation definitions:
| Basis | Subject percentile |
|---|---|
| Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default | 72nd |
| Total compensation (D + F), as reported (no adjustments) | 77th |
| Reportable pay only (column D), adjusted | 66th |
| All sources (D + E + F), adjusted | 70th |
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.
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 74-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). 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.