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PeerBasis
Compensation Comparability Determination

American Legion Post 159

Executive Director / CEO

EIN 541209080
VA · NTEE W30
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Randy Mills, Executive Director / CEO ($29,608) against every comparable organization that fit the selection criteria — 79 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 35th percentile of comparable organizationswithin the typical range

Benchmarked executive: Randy Mills — reported title “VICE COMMANDER”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

79 organizations qualified on sector, size, and geography 79 within the band form the benchmarked peer set.

Distribution of comparable compensation

$1,341 total compensation of comparable organizations → $606,149 $29,608
$11,27310th
$20,19525th
$43,224Median
$66,48475th
$97,81490th
$29,608This org · 35th
p10$11,273
p25$20,195
p50$43,224
p75$66,484
p90$97,814
$29,608

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
Veterans Of Foreign Wars Post 629 WV$307,683 Manager $29,030 $31,620 2024
Minnesota Association Of County Veterans MN$302,004 Executive Director $64,350 $63,965 2024
Marineparentscom Inc MO$301,967 President $82,551 $87,957 2024
American Legion NY$301,875 Commander $2,100 $1,909 2024
Chief Warrant And Warrant IL$301,849 Executive Dir. $78,000 $79,420 2023
Operation Rebuild Hope OR$309,385 Coo $37,600 $35,126 2024
George N Althouse Memorial Association PA$299,782 Vice President $14,400 $14,446 2024
82d Airborne Division Association Inc NC$310,900 Executive Director $65,500 $68,083 2024
Veterans Of Foreign Wars Of The Us Dpt Of Virginia VA$311,633 Quartermaster $28,600 $27,063 2025
Veterans Of Foreign Wars Dept Vfw Ky KY$314,084 Quartermaster $31,000 $32,640 2025
Texas National Guard Family Support Foundation TX$317,202 Executive Director/grant Manager $28,806 $28,988 2024
Honor Bell Foundation Inc CO$319,693 Executive Di $43,541 $42,000 2024
The Navigation Center Fka Military SC$290,266 Executive Di $54,253 $56,937 2024
National Guard Association Of MN$289,665 Executive Di $25,200 $25,049 2024
Midwest Region Laborers Veterans IL$324,882 Legislative Director $139,724 $138,185 2024
The Heroes Project CA$285,068 Director $697,799 $606,149 2024
American Legion Post 286 Inc FL$326,398 Past Command $18,820 $17,327 2025
Department Of Illinois Vfw Auxiliary Inc IL$326,983 Secretary $14,600 $14,866 2023
Veterans Of Foreign Wars Post 8794 OH$282,624 Chaplain $48,288 $50,124 2025
Veterans Of Foreign Wars Of The United PA$281,123 Treasurer/secretary $54,074 $54,247 2024
New Hampshire Veterans Association NH$280,385 President $1,950 $1,811 2024
Vallejo Veterans Building Council CA$340,530 Building Manager $22,500 $20,122 2023
Paralyzed Veterans Of America North Cent SD$268,925 Executive Director - Left 08/2024 $86,077 $95,564 2024
Bourn Free Foundation NV$267,799 Cfo Treasure $9,000 $9,075 2024
Idaho Veterans Chamber Of Commerce ID$343,929 President $80,640 $88,845 2023

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 default35th
Total compensation (D + F), as reported (no adjustments)37th
Reportable pay only (column D), adjusted37th
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 (Randy Mills) 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 79 similarly situated organizations (Same NTEE sector (W30), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $29,608 is reasonable (approximately the 35th 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.