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PeerBasis
Compensation Comparability Determination

Last Prisoner Project

Executive Director / CEO

EIN 834502829
CO · NTEE I43
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Sarah Gersten, Executive Director / CEO ($186,012) against every comparable organization that fit the selection criteria — 391 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 85th percentile of comparable organizationswithin the typical range

Benchmarked executive: Sarah Gersten — reported title “EXECUTIVE DIRECT”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

391 organizations qualified on sector, size, and geography 391 within the band form the benchmarked peer set.

Distribution of comparable compensation

$3,009 total compensation of comparable organizations → $377,001 $186,012
$70,21310th
$99,26125th
$127,197Median
$159,03075th
$202,04690th
$186,012This org · 85th
p10$70,213
p25$99,261
p50$127,197
p75$159,030
p90$202,046
$186,012

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 CO 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
Columbia Gorge Defenders OR$2,265,806 Executive Di $154,000 $149,146 2024
New York State Sheriffs' Institute NY$2,266,799 Executive Di $170,136 $165,068 2023
Colorado Poverty Law Project CO$2,265,421 Executive Director $143,936 $143,936 2024
Unemployment Law Project WA$2,263,618 Executive Director $100,125 $96,248 2023
Harvest Academy IA$2,268,917 Director & Ceo $51,948 $61,071 2023
🔒 386 more comparable organizations — included in the purchased report

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to CO cost of living and 2024 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 CO 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 default85th
Total compensation (D + F), as reported (no adjustments)84th
Reportable pay only (column D), adjusted89th
All sources (D + E + F), adjusted81st

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:

Ready-to-adopt board minutes — executive compensation

🔒 The complete minutes language — three numbered resolutions pre-filled with this organization, the 391-organization comparison, the date, and the percentile finding, ready to paste into your minutes — is included in the purchased report.

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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.