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PeerBasis
Compensation Comparability Determination

American Council On Education

Executive Director / CEO

EIN 530196573
DC · NTEE B030
FY ending 2023-09-30
June 9, 2026

This analysis benchmarks the total compensation of Theodore Mitchell, Executive Director / CEO ($845,534) against every comparable organization that fit the selection criteria — 705 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 96th percentile of comparable organizationsabove the 90th percentile — board review recommended

Benchmarked executive: Theodore Mitchell — reported title “PRESIDENT, EX OFFICIO”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

705 organizations qualified on sector, size, and geography 705 within the band form the benchmarked peer set.

Distribution of comparable compensation

$1,181 total compensation of comparable organizations → $1,648,500 $845,534
$151,33410th
$223,83225th
$337,285Median
$491,60675th
$679,69790th
$845,534This org · 96th
p10$151,334
p25$223,832
p50$337,285
p75$491,606
p90$679,697
$845,534

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
Utah Valley University Foundation Inc UT$39,712,490 Ceo Until Sep 2022 $57,801 $67,414 2023
Wilson College PA$39,687,709 President $326,603 $360,507 2024
The Winsor School MA$39,776,141 Head Of School $724,466 $741,875 2023
The Park School Of Baltimore MD$39,793,878 Head Of School $452,664 $482,261 2023
King University TN$39,796,591 President; Ex-officio $388,270 $451,742 2024
🔒 700 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 DC cost of living and 2023 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 default96th
Total compensation (D + F), as reported (no adjustments)97th
Reportable pay only (column D), adjusted97th
All sources (D + E + F), adjusted95th

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 705-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.