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PeerBasis
Compensation Comparability Determination

Equal Access To Justice Inc

Executive Director / CEO

EIN 850437183
NM · NTEE T99
FY ending 2025-03-31
June 9, 2026

This analysis benchmarks the total compensation of Heather Norfleet, Executive Director / CEO ($79,435) against every comparable organization that fit the selection criteria — 35 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 77th percentile of comparable organizationswithin the typical range

Benchmarked executive: Heather Norfleet — reported title “EXECUTIVE DIRECTOR”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

35 organizations qualified on sector, size, and geography 35 within the band form the benchmarked peer set.

Distribution of comparable compensation

$493 total compensation of comparable organizations → $117,352 $79,435
$4,39010th
$19,15425th
$42,604Median
$74,88175th
$94,46890th
$79,435This org · 77th
p10$4,390
p25$19,154
p50$42,604
p75$74,881
p90$94,468
$79,435

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
Overly's Country Christmas Inc PA$368,962 Executive Director $22,625 $22,169 2023
Burning Ones Inc FL$369,303 President $47,500 $42,586 2024
The Waterhouse Charitable Trust HI$350,901 Co-trustee $109,480 $96,307 2023
Africa Network Evangelism Task TX$327,442 Ceo & Chairman $119,400 $117,352 2023
The Viaquest Foundation OH$397,274 Executive Director $72,853 $75,815 2023
Henrik Lundqvist Foundation Inc NJ$400,275 Executive Dir. $50,000 $42,604 2024
One Equal Heart Foundation WA$402,021 Executive Director $102,175 $89,881 2023
Ymca Foundation Of Mid-america KS$405,761 Chief Executive Officer $37,063 $38,213 2024
Finao WI$314,091 President $14,400 $14,777 2023
Friends Of Michlalah Yerushalayim Inc NY$311,382 President $3,600 $3,104 2024
Ivan & Caroline Wilson Memorial IA$417,707 Trustee $15,000 $16,138 2023
World Stewardship Institute CA$419,063 President $48,960 $40,347 2024
Engineers Charitable Trust NY$304,582 Executive Director $94,257 $81,285 2024
All For Him Ministry Inc TN$304,184 President $22,471 $23,208 2023
Ventura Music Festival Association CA$423,602 Executive Di $115,000 $94,770 2024
The Central Benefits OH$424,274 Secretary $105,945 $110,253 2023
American Friends Of Action PA$300,229 Program Dire $75,686 $72,032 2024
Hamilton Education Foundation Inc WI$294,433 Co-executive Director $4,333 $4,446 2023
Olde Towne Theatre Co Inc SD$433,343 Executive Di $27,209 $29,505 2023
Friends Of The School Of The Arts Fnd CA$438,471 Treasurer $5,000 $4,014 2025
The Potters Hands Foundation Inc NY$450,977 Executive Directorboard Chair $85,748 $73,947 2024
Evanstonskokie District 65 Educational IL$267,731 Executive Director $95,191 $89,312 2024
Wings Educational Foundation MO$267,115 Secretary $4,420 $4,353 2025
Kansas Financial Empowerment Foundation KS$458,087 President $478 $493 2024
Philanthropy West Virginia Inc WV$266,148 Pres. & Ceo (Ex-officio) $46,738 $48,296 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to NM 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 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 default77th
Total compensation (D + F), as reported (no adjustments)71st
Reportable pay only (column D), adjusted77th
All sources (D + E + F), adjusted63rd

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 (Heather Norfleet) 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 35 similarly situated organizations (Same NTEE sector (T99), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $79,435 is reasonable (approximately the 77th 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.