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PeerBasis
Compensation Comparability Determination

Citizens Telephone Cooperative

Executive Director / CEO

EIN 540169578
VA · NTEE Y22
FY ending 2024-12-31
June 13, 2026

This analysis benchmarks the total compensation of Donna Smith, Executive Director / CEO ($207,328) against every comparable organization that fit the selection criteria — 52 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 75th percentile of comparable organizationswithin the typical range

Benchmarked executive: Donna Smith — reported title “CEO/GENERAL MANAGER”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

52 organizations qualified on sector, size, and geography 52 within the band form the benchmarked peer set.

Distribution of comparable compensation

$3,331 total compensation of comparable organizations → $828,859 $207,328
$22,83910th
$35,31525th
$86,407Median
$181,79675th
$315,28990th
$207,328This org · 75th
p10$22,839
p25$35,315
p50$86,407
p75$181,796
p90$315,289
$207,328

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 VA 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
Bluestem Electric Cooperative Inc KS$19,004,266 General Manager $295,216 $330,314 2024
Afognak Native Corporation AK$18,887,295 Trustee $20,059 $19,862 2024
Directemployers Association Inc IN$18,810,427 Executive Director-exit 8/2024 $758,896 $828,859 2024
Plumbers & Pipefitters Local No 333 MI$19,457,996 Former Chair $81,251 $86,857 2024
Free & Accepted Masons Of Florida Most FL$18,695,352 Mas. Home Admin $120,000 $113,744 2025
🔒 47 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 VA 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 VA 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 default75th
Total compensation (D + F), as reported (no adjustments)75th
Reportable pay only (column D), adjusted81st
All sources (D + E + F), adjusted29th

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 52-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 13, 2026.