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PeerBasis
Compensation Comparability Determination

Freedom Center

Executive Director / CEO

EIN 540736349
VA · NTEE N20
FY ending 2023-06-30
June 9, 2026

This analysis benchmarks the total compensation of Paul Gernhardt, Executive Director / CEO ($40,000) against every comparable organization that fit the selection criteria — 38 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 76th percentile of comparable organizationswithin the typical range

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

How comparable organizations were selected

38 organizations qualified on sector, size, and geography 38 within the band form the benchmarked peer set.

Distribution of comparable compensation

$1,018 total compensation of comparable organizations → $85,326 $40,000
$3,03010th
$13,08125th
$26,739Median
$37,49675th
$58,50790th
$40,000This org · 76th
p10$3,030
p25$13,081
p50$26,739
p75$37,496
p90$58,507
$40,000

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
Seeker Springs Ministry Inc LA$144,919 Executive Director $16,692 $19,036 2023
Camp Pattersonville Inc NY$146,633 Director $40,000 $36,361 2024
Friends Of Wisconsin Camp Tapawingo Corporation WI$143,915 Camp Director, Board Member $51,998 $54,629 2024
Friendly Hills Charitable Foundation Inc OH$151,457 President $4,992 $5,476 2023
Kaneco Association IL$152,576 Secretary/treasurer $12,317 $12,541 2023
Fort Hope Inc CA$137,759 President $37,000 $33,090 2023
The Kentucky State Police Foundation Inc KY$135,860 Executive Director $77,415 $83,669 2024
Greater Hamilton Homes Inc MD$133,766 Treasurer $28,731 $27,021 2024
Monroe County Education Foundation Inc WV$133,506 Administrator $19,210 $21,542 2023
Humanity In Unity Inc CO$158,643 Board Member $26,640 $26,456 2023
Eagle River United Methodist Camp AK$130,545 Camp Manager $2,600 $2,500 2024
College Of Diplomates Of The American IL$130,025 Director $1,000 $1,018 2023
Backwoods Christian Camp Inc AL$162,108 Managing Director $28,800 $31,300 2024
Glad Tidings Bible Camp Inc NE$129,102 Executive Dir. $30,749 $34,252 2023
Chicagami MN$129,091 Camp Director $28,674 $28,502 2024
Emilie M Bullowa Memorial Endowment Of NY$169,431 Scout Executive/ceo $18,549 $16,862 2024
Camp Kids Are Kids Chicago IL$121,024 Director $30,000 $29,669 2024
Horses N Heroes Of Marion County Inc FL$171,832 Executive Director $7,800 $7,371 2024
Reach Therapeutic Riding Center TX$172,591 Executive Director $41,083 $41,341 2024
Pacesetters Baseball Inc NE$176,383 President/dean Of Coaches $10,200 $11,362 2023
Christian Youth Fellowship Inc CT$114,726 President $46,800 $45,446 2023
Camp Caleb Christian Association Inc KY$114,624 Director/ Key Employee(jan-aug) $22,012 $24,493 2023
Kids At Heart CO$177,637 President $66,000 $63,663 2024
Midcourse Correction Challenge Campinc MI$177,960 Vice President $3,000 $3,115 2024
Kids & Pros Inc FL$178,598 Executive Director $50,050 $47,299 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to VA 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 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 default76th
Total compensation (D + F), as reported (no adjustments)74th
Reportable pay only (column D), adjusted76th
All sources (D + E + F), adjusted68th

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 (Paul Gernhardt) 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 38 similarly situated organizations (Same NTEE sector (N20), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $40,000 is reasonable (approximately the 76th 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.