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PeerBasis
Compensation Comparability Determination

The Innocent Lives Foundation

Executive Director / CEO

EIN 821110116
PA · NTEE I73
FY ending 2025-06-30
June 9, 2026

This analysis benchmarks the total compensation of Mitchell S Mccombs, Executive Director / CEO ($115,910) against every comparable organization that fit the selection criteria — 81 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 94th percentile of comparable organizationsabove the 90th percentile — board review recommended

Benchmarked executive: Mitchell S Mccombs — reported title “COO”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

81 organizations qualified on sector, size, and geography 81 within the band form the benchmarked peer set.

Distribution of comparable compensation

$4,057 total compensation of comparable organizations → $192,927 $115,910
$12,31810th
$20,93025th
$41,831Median
$60,10475th
$95,75890th
$115,910This org · 94th
p10$12,318
p25$20,930
p50$41,831
p75$60,104
p90$95,758
$115,910

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 PA 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
Chains Of Grace Inc TX$115,338 Executive Director $56,700 $60,104 2023
Failsafe-era Inc VA$115,465 President/ceo $6,000 $6,139 2023
Court Watch Nola LA$114,762 Executive Director $82,901 $96,736 2023
Taking Action For Good TN$115,785 Founder & Ceo $150,000 $173,935 2022
Life After Justice IL$113,155 Executive Director $77,184 $78,104 2024
Nofires Inc MA$113,064 Executive Di $54,600 $50,503 2024
Spf-iimc IL$112,649 President/ceo $30,975 $32,271 2023
Parents Against Child Sex Abuse IL$111,911 Executive Director $25,566 $25,871 2024
Arkansas Policy Foundation AR$118,975 Executive Direc $96,056 $111,135 2024
Easterseals Housing Solutions Inc MT$111,085 President/ce $16,543 $18,355 2024
Morgantown Area Youth Services Project WV$120,319 Exec Director $37,765 $43,331 2023
Clarinda Youth Corporation IA$108,216 President $3,600 $4,057 2024
Alliance For Higher Education CO$122,429 Executive Di $22,349 $22,058 2024
The National Foundation To End CO$122,441 Ceo $138,598 $136,793 2024
Nevada Peace Officer Association NV$107,204 President $9,600 $9,905 2024
Pathways For Change Inc FL$106,135 Executive Director $22,237 $21,502 2024
Apoyo Legal Al Emprendimiento Comunitario Inc PR$106,009 Director $32,000 $33,817 2023
Citizens For Community Justice Inc IN$103,218 Executive Director $50,000 $54,273 2024
Midland Kids First MI$128,391 President & $50,667 $55,420 2023
Sixth Judicial Court Casagal Program Inc MT$128,567 Exec. Director $28,596 $32,666 2023
Minnesota Freedom Fund Action MN$101,127 Director Programs Operatio $12,406 $12,618 2024
Legal Accountability Project DC$129,621 President $79,720 $72,007 2024
Finequity Inc NY$100,802 Executive Director $116,040 $107,930 2024
The National Legal Foundation VA$129,741 President And Director $87,598 $84,814 2025
Bayberry Courts Inc RI$100,704 President $52,490 $53,337 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to PA 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 PA 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 default94th
Total compensation (D + F), as reported (no adjustments)93rd
Reportable pay only (column D), adjusted94th
All sources (D + E + F), adjusted78th

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 (Mitchell S Mccombs) 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 81 similarly situated organizations (Same NTEE major group (I), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $115,910 is reasonable (approximately the 94th 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.