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PeerBasis
Compensation Comparability Determination

Securities And Exchange Commission

Executive Director / CEO

EIN 522213646
DC · NTEE A54
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Kathleen Graham, Executive Director / CEO ($194,516) against every comparable organization that fit the selection criteria — 98 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 99th percentile of comparable organizationsabove the 90th percentile — board review recommended

Benchmarked executive: Kathleen Graham — reported title “EXECUTIVE DIRECTOR”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

98 organizations qualified on sector, size, and geography 98 within the band form the benchmarked peer set.

Distribution of comparable compensation

$4,273 total compensation of comparable organizations → $203,555 $194,516
$30,53810th
$50,20625th
$65,247Median
$84,67375th
$102,51990th
$194,516This org · 99th
p10$30,538
p25$50,206
p50$65,247
p75$84,673
p90$102,519
$194,516

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 DC 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
Russian History Foundation NY$449,129 Executive Director $54,240 $55,853 2024
Kenosha Military Museum Ltd IL$436,579 Vice President $74,720 $83,711 2024
Dunham Tavern Museum & Gardens OH$453,355 Executive Di $73,008 $88,119 2024
Lompoc Museum Associates Inc CA$433,480 Director $53,068 $50,874 2025
Poplar Grove Foundation Inc NC$430,892 Executive Dir. $50,750 $61,522 2023
Museum Of American Heritage CA$428,902 Former Executive Director $80,588 $79,300 2024
Minnesota Masonic Historical Society And MN$426,374 President/ceo - Charities $34,208 $39,656 2023
Whiteside Museum Of Natural History TX$425,462 Museum Curator $71,000 $80,934 2024
National Food And Beverage Foundation LA$424,500 President/ceo $22,600 $28,359 2024
William Fremont Harn Gardens Inc OK$419,254 Executive Director $46,505 $58,355 2024
Burlesque Hall Of Fame Inc NV$469,581 Executive Director $62,130 $70,969 2024
Cleveland Coordinating Committee For Cod Inc OH$416,348 President $40,000 $47,034 2025
Moffat Road Railroad Museum Association CO$406,818 Executive Director $53,200 $58,132 2024
Tangier American Legation Institute For Moroccan Studies MD$481,242 Executive Director $150,094 $159,908 2024
New York City Fire Museum NY$488,444 Former Executive Director $120,934 $124,531 2024
Historic Crab Orchard Museum VA$489,648 Executive Director $52,814 $58,111 2024
National Native American Hall Of Fame MT$395,664 Executive Director $30,000 $36,851 2024
Fort Chadbourne Foundation TX$395,333 Director $45,510 $53,410 2023
King Manor Assoc Of Long Island Inc NY$393,329 Executive Director $68,720 $70,764 2024
Dekalb County History Center IL$392,710 Executive Di $62,577 $72,177 2023
Duluth Children's Museum Inc MN$495,301 Executive Director $27,270 $30,706 2024
El Paso Holocaust Museum TX$495,728 Executive Dir. $83,152 $94,786 2024
American Museum Tort Law Inc CT$391,615 Executive Director $71,635 $76,540 2024
Niles Essanay Silent Film Museum Inc CA$391,377 President/historian (Started 1/7/24) $18,000 $17,712 2024
Mcminn County Living Heritage TN$498,328 Executive Di $45,000 $53,903 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to DC 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 DC 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 default99th
Total compensation (D + F), as reported (no adjustments)100th
Reportable pay only (column D), adjusted99th
All sources (D + E + F), adjusted98th

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 (Kathleen Graham) 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 98 similarly situated organizations (Same NTEE sector (A54), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $194,516 is reasonable (approximately the 99th 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.