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PeerBasis
Compensation Comparability Determination

The Way To Justice

Executive Director / CEO

EIN 845129426
WA · NTEE R99
FY ending 2025-06-30
June 9, 2026

This analysis benchmarks the total compensation of Virla Spencer, Executive Director / CEO ($269,427) against every comparable organization that fit the selection criteria — 22 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 91st percentile of comparable organizationsabove the 90th percentile — board review recommended

Benchmarked executive: Virla Spencer — reported title “CEO”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

22 organizations qualified on sector, size, and geography 22 within the band form the benchmarked peer set.

Distribution of comparable compensation

$15,808 total compensation of comparable organizations → $602,870 $269,427
$30,05710th
$94,64125th
$151,760Median
$180,95775th
$216,03190th
$269,427This org · 91st
p10$30,057
p25$94,641
p50$151,760
p75$180,957
p90$216,031
$269,427

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 WA 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
Government Accountability Alliance IL$3,370,159 President And Ceo $146,991 $165,678 2024
One Action DC$3,364,294 Sr Dir, U.s. Gov Relatns $216,030 $217,343 2024
Government Accountability Institute FL$3,537,381 President, Secretary/treas $260,408 $280,469 2024
Power To The Polls Inc DC$3,543,209 President $29,299 $29,477 2024
State Power Action Fund OH$3,293,226 Executive Director $17,500 $21,250 2024
🔒 17 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 WA 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 WA 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 default91st
Total compensation (D + F), as reported (no adjustments)95th
Reportable pay only (column D), adjusted95th
All sources (D + E + F), adjusted82nd

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 22-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.