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PeerBasis
Compensation Comparability Determination

Nch'i Wana Housing

Executive Director / CEO

EIN 871164014
OR · NTEE L22
FY ending 2023-12-31
June 13, 2026

This analysis benchmarks the total compensation of Debra Whitefoot, Executive Director / CEO ($60,310) against every comparable organization that fit the selection criteria — 299 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 65th percentile of comparable organizationswithin the typical range

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

How comparable organizations were selected

299 organizations qualified on sector, size, and geography 299 within the band form the benchmarked peer set.

Distribution of comparable compensation

$323 total compensation of comparable organizations → $387,053 $60,310
$10,20510th
$24,10625th
$41,762Median
$67,52175th
$80,16090th
$60,310This org · 65th
p10$10,205
p25$24,106
p50$41,762
p75$67,521
p90$80,160
$60,310

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 OR 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
Greencastle Of Sterling Inc IL$456,225 President & Ceo $50,615 $52,046 2024
Saint Elizabeth Terrace Warwick RI$454,615 President & Ceo $27,641 $27,722 2024
United Church Residences Of Greenwood OH$456,733 Treasurer $50,772 $56,245 2024
2life Realty Inc MA$456,866 Ceo, President $13,523 $13,086 2023
Mckendree Lambuth At Gallatin Inc TN$459,465 President $46,401 $52,521 2023
National Steelworkers Oldtimers FL$451,562 Vice Preside $75,384 $72,161 2025
The Residences At Neponset Field Inc MA$451,548 Chief Executive Officer $42,255 $40,888 2023
Peace Presbyterian Village MI$460,195 Administrator $47,128 $50,878 2024
5199 Mission Street Senior Housing Inc CA$460,301 Executive Dir. $13,111 $12,191 2023
Booth Manor Inc NE$450,725 President $9,613 $10,814 2024
Philippian Gardens Inc PA$449,934 Executive Di $62,260 $66,858 2023
Vision Personal Care Home Inc GA$461,289 Director $101,000 $106,218 2024
Gallagher Mansion Inc MD$448,849 Secretary $11,427 $11,174 2024
Liberty Manor For Veterans Inc FL$447,572 President $64,910 $63,779 2024
St James Place Of Baton Rouge LA$464,063 President /Ceo $17,164 $19,768 2024
Benet Place South MN$464,119 President And Ceo $41,871 $43,274 2024
Luther Towers Iv Of Dover Inc DE$446,290 Executive Director $5,511 $5,499 2025
Share Inc NJ$465,147 Executive Director $83,321 $77,810 2024
Chv Buckingham Housing Development Fund NY$445,249 President $87,526 $85,167 2023
D'youville Elderly Housing Corporation MA$445,176 Former President/ Ceo $2,380 $2,303 2023
Good Samaritan League Of America Inc ID$445,132 Ceo $79,778 $88,765 2024
Montclair Shared Housing Association Inc NJ$466,790 Ex Director $72,046 $67,280 2024
Westminster Asbury East Inc FL$442,573 Ceo/presiden $36,488 $36,911 2023
St Theresa Village Inc CO$469,005 Director $34,463 $35,585 2023
Schoharie County Housing Development NY$442,055 Executive Director $23,474 $22,186 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to OR cost of living and 2023 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 OR 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 default65th
Total compensation (D + F), as reported (no adjustments)65th
Reportable pay only (column D), adjusted88th
All sources (D + E + F), adjusted11th

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 (Debra Whitefoot) 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 13, 2026, comparing compensation against 299 similarly situated organizations (Same NTEE sector (L22), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $60,310 is reasonable (approximately the 65th 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 13, 2026.