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PeerBasis
Compensation Comparability Determination

Georgia O'keeffe Museum

Executive Director / CEO

EIN 850437114
NM · NTEE A510
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Cody Hartley, Executive Director / CEO ($395,441) against every comparable organization that fit the selection criteria — 23 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 83rd percentile of comparable organizationswithin the typical range

Benchmarked executive: Cody Hartley — reported title “MUSEUM DIRECTOR”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

23 organizations qualified on sector, size, and geography 23 within the band form the benchmarked peer set.

Distribution of comparable compensation

$148,055 total compensation of comparable organizations → $565,993 $395,441
$201,59110th
$276,69625th
$347,771Median
$387,35775th
$473,91490th
$395,441This org · 83rd
p10$201,591
p25$276,696
p50$347,771
p75$387,357
p90$473,914
$395,441

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 NM 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
Sterling And Francine Clark Art MA$10,724,599 Director & Ex Officio $616,399 $530,207 2023
Santa Barbara Museum Of Art CA$11,334,880 Director And Ceo $239,703 $198,128 2023
San Diego Museum Of Art CA$10,450,340 Executive Director & Ceo $439,806 $363,524 2023
Phoenix Art Museum AZ$10,338,592 Director/ceo $234,029 $215,442 2023
Honolulu Museum Of Art HI$11,579,809 Director/ceo $431,383 $369,695 2023
🔒 18 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 NM 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 NM 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 default83rd
Total compensation (D + F), as reported (no adjustments)43rd
Reportable pay only (column D), adjusted83rd
All sources (D + E + F), adjusted83rd

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 23-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.