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PeerBasis
Compensation Comparability Determination

Bay Aging Apartments Middlesex Inc

Executive Director / CEO

EIN 731676722
VA · NTEE L22
FY ending 2025-03-31
June 9, 2026

This analysis benchmarks the total compensation of Kathy E Vesley, Executive Director / CEO ($267,673) against every comparable organization that fit the selection criteria — 263 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: Kathy E Vesley — reported title “PRESIDENT”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

263 organizations qualified on sector, size, and geography 263 within the band form the benchmarked peer set.

Distribution of comparable compensation

$468 total compensation of comparable organizations → $452,415 $267,673
$10,53510th
$22,04025th
$39,866Median
$62,54075th
$85,37290th
$267,673This org · 99th
p10$10,535
p25$22,040
p50$39,866
p75$62,540
p90$85,372
$267,673

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
Ucc Iii Inc OH$345,339 Treasurer $34,230 $39,680 2023
Elmore Area Concerned Christians Inc OH$346,983 Chief Executive Director $92,614 $104,280 2024
Ridge Oak Management Inc NJ$342,077 Executive Director $255,355 $236,127 2025
Mcauley Manor Inc CO$348,558 Director $37,575 $38,303 2024
Charles Street Village Inc CA$348,676 Ceo $34,300 $32,416 2023
El Mirage Senior Village CO$348,997 Vice President $34,402 $36,104 2023
The Wartburg Residential Community Inc NY$349,539 President $90,025 $86,481 2024
Brook Oaks Senior Residences Inc OH$350,229 President $48,755 $54,897 2024
Lutheran Social Services Of Central Ohio OH$340,026 President & Ceo $9,088 $10,535 2023
Buffalo Mercy Housing Development Fund NY$339,655 Board Member/board President $25,080 $24,804 2023
John Marvin Tower FL$350,924 Vice Preside $72,591 $72,496 2024
Afton Manor Inc IA$339,377 Manager $13,360 $16,011 2023
Miracle Mile Senior Citizen Housing Corp CA$351,502 President $7,646 $6,838 2025
Capitol Lakes Foundation Inc WI$351,636 Administrative Director $50,245 $55,784 2024
Wisconsin Care Systems Inc WI$353,395 President $89,000 $101,731 2023
Peninsula Housing Development Inc Xviii FL$336,692 Director $25,136 $25,103 2024
Gault Street Senior Housing CO$353,940 President $25,195 $26,442 2023
Manitowoc Rhf Housing Inc CA$354,889 President/ceo $68,128 $62,540 2024
Community For Affordable Senior MN$335,417 Evp Of Commonbond Housing $18,918 $20,459 2023
Rosewood Court Inc MN$355,963 Ceo Of Bhs $158,313 $171,213 2023
Lutheran Housing Services 18 Inc OH$332,392 President/ce $62,368 $72,299 2023
Ridge Oak Iii Inc NJ$331,830 Executive Director $61,663 $57,020 2025
Snhs Elderly Housing Inc NH$331,493 Treasurer $53,564 $51,224 2025
Plymouth Place Inc CA$329,741 President/ceo $68,128 $62,540 2024
Shepherd Oaks West Apartments Inc MN$361,165 President/ceo/administrato $26,425 $27,758 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 2025 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 default99th
Total compensation (D + F), as reported (no adjustments)99th
Reportable pay only (column D), adjusted100th
All sources (D + E + F), adjusted52nd

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 (Kathy E Vesley) 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 263 similarly situated organizations (Same NTEE sector (L22), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $267,673 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.