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PeerBasis
Compensation Comparability Determination

St Luke Community Healthcare Foundation

Executive Director / CEO

EIN 810539096
MT · NTEE E112
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Steve Todd, Executive Director / CEO ($23,323) against every comparable organization that fit the selection criteria — 94 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 27th percentile of comparable organizationswithin the typical range

How comparable organizations were selected

94 organizations qualified on sector, size, and geography 94 within the band form the benchmarked peer set.

Distribution of comparable compensation

$3,567 total compensation of comparable organizations → $668,262 $23,323
$10,67410th
$23,14225th
$43,071Median
$88,40675th
$189,18190th
$23,323This org · 27th
p10$10,674
p25$23,142
p50$43,071
p75$88,406
p90$189,181
$23,323

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 MT cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateTotal revenueTotal compSource
Friends Of New York City Nurse FamilyNY $389,558$73,282 990
Bellin Gundersen Health System IncWI $399,871$224,189 990
Newark-wayne Community HospitalNY $387,172$51,113 990
St Jude's Ranch For ChildrenNV $385,324$4,998 990
Longs Peak Hospital FoundationCO $384,611$34,222 990
Restoration Storehouse CenterGA $403,267$91,879 990
Genesys VolunteersMI $383,251$23,398 990
Lehigh Qalicb IncFL $383,066$132,741 990
Daughters Of Charity Services Of NewLA $382,360$18,157 990
Roh Investment Co IncTN $381,158$187,732 990
Ucmc Title Holding CorporationIL $406,220$192,756 990
The Health Source GroupMO $380,579$53,246 990
Spring Creek Health CooperativeGA $407,073$89,033 990
Asa Charitable FoundationIL $412,202$80,982 990
Smh FoundationLA $374,390$119,586 990
Towner County Living CenterND $415,871$21,677 990
St Thomas Foundation IncLA $368,438$20,539 990
Minnesota Center For Health Care EthicsMN $367,552$149,982 990
Rush To Crush CancerPA $421,261$8,943 990
Pennsylvania Medical Society CharitablePA $422,746$52,594 990
Glendive Medical Center FoundationMT $423,759$19,847 990
Obcc Othello QalicbWA $363,286$25,768 990
Catholic Health Initiatives NationalCO $426,095$45,748 990
Macomb County Ems MedicalMI $426,705$147,513 990
Southeastern Missouri Area HealthMO $358,784$59,332 990

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 MT 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 default27th
Total compensation (D + F), as reported (no adjustments)22nd
Reportable pay only (column D), adjusted0th
All sources (D + E + F), adjusted57th

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 (Steve Todd) 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 94 similarly situated organizations (Same NTEE sector (E11), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $23,323 is reasonable (approximately the 27th 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). 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.