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PeerBasis
Compensation Comparability Determination

Freedom Center For

Executive Director / CEO

EIN 510413247
DE · NTEE B99
FY ending 2024-09-30
June 9, 2026

This analysis benchmarks the total compensation of Jody Hougentogler, Executive Director / CEO ($53,200) against every comparable organization that fit the selection criteria — 446 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 40th percentile of comparable organizationswithin the typical range

Benchmarked executive: Jody Hougentogler — reported title “EXECUTIVE DI”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

446 organizations qualified on sector, size, and geography 446 within the band form the benchmarked peer set.

Distribution of comparable compensation

$129 total compensation of comparable organizations → $326,607 $53,200
$15,16210th
$35,99025th
$61,835Median
$88,49375th
$118,13090th
$53,200This org · 40th
p10$15,162
p25$35,990
p50$61,835
p75$88,493
p90$118,130
$53,200

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 DE 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
Murray Education Foundation UT$394,832 Director $13,541 $14,154 2024
Stark Education Partnership Inc OH$395,046 President $196,358 $218,674 2023
Cumberland County Bar Association PA$395,243 Executive Di $76,065 $77,469 2024
Adult Learning Center SC$394,287 Director $100,455 $104,271 2025
Aamva Region Ii Inc VA$395,339 Director, Regions I & Ii $15,357 $15,591 2023
Communities In Schools Of Candler Co Inc GA$395,553 Director $36,575 $36,590 2025
Sunshine Academy Summer School VA$396,640 President $20,000 $20,305 2023
The Nobelity Project TX$392,021 Executive Director $96,336 $101,325 2023
Kiilys Kids Incoporated FL$390,256 President $110,000 $105,536 2024
Arts Media And Entertainment Institute Inc CA$399,515 Executive Director $82,378 $72,648 2024
Eduguide MI$399,810 President $120,679 $127,213 2024
Epilepsy Foundation Of Missouri MO$399,900 Executive Di $73,977 $80,021 2024
One Solution Foundation Inc IL$400,202 Executive Director $61,004 $63,060 2023
Colorado High School Coaches Association Inc CO$400,414 Executive Director $72,141 $70,647 2024
The Public Education Foundation Inc IN$389,005 Executive Director $48,767 $54,073 2023
Vermilion Sea Institute WA$388,248 Exeutive Director & Treasurer $31,340 $28,656 2024
Safe Schools South Florida FL$387,647 Executive Di $33,010 $32,606 2023
District Twelve Educators' Association CO$386,999 President $134,965 $132,170 2024
Invasive Species Action Network MT$386,496 Executive Di $68,333 $77,448 2023
American Achievement Testing Inc DC$386,410 Ceo $152,925 $137,053 2024
The Upward Project MA$386,090 Executive Director $100,889 $92,590 2024
Shaking The Tree Inc OR$403,550 President $53,500 $52,239 2023
Look Ahead America Inc DC$403,844 President $43,737 $40,355 2023
City Learners Inc Dba My City School CA$403,881 Executive Dir. $100,223 $88,385 2024
Compass For Affordable Housing CA$404,252 Executive Director $65,697 $59,649 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to DE 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 DE 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 default40th
Total compensation (D + F), as reported (no adjustments)42nd
Reportable pay only (column D), adjusted42nd
All sources (D + E + F), adjusted35th

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 (Jody Hougentogler) 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 446 similarly situated organizations (Same NTEE sector (B99), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $53,200 is reasonable (approximately the 40th 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.