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PeerBasis
Compensation Comparability Determination

Pde Action

Executive Director / CEO

EIN 872352093
VA · NTEE B01
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Nicole Neily, Executive Director / CEO ($8,876) against every comparable organization that fit the selection criteria — 58 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 3rd percentile of comparable organizationsbelow the typical range for comparable organizations

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

How comparable organizations were selected

58 organizations qualified on sector, size, and geography 58 within the band form the benchmarked peer set.

Distribution of comparable compensation

$989 total compensation of comparable organizations → $247,500 $8,876
$17,98710th
$30,29725th
$54,834Median
$83,76375th
$108,46290th
$8,876This org · 3rd
p10$17,987
p25$30,297
p50$54,834
p75$83,763
p90$108,462
$8,876

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 VA 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
Bli Learning Labs Incorporated FL$205,474 Executive Director $44,978 $42,634 2025
Iowa Association Of Christian Schools IA$205,486 Executive Director $60,000 $66,286 2025
Indiana Urban Schools Assoc Ii Inc IN$201,525 Executive Director $95,750 $104,577 2024
Frontline Policy Action Inc GA$209,827 President $31,106 $33,350 2023
Kentucky Financial Empowerment KY$198,771 Executive Director $95,000 $108,829 2023
South Carolina First Steps To SC$211,612 Executive Di $62,000 $68,968 2023
Maine Donor Alliance Fund ME$215,743 Executive Director $35,000 $37,370 2023
Es Of Choice GA$216,046 Director $950 $989 2024
Law And Public Safety Education GA$217,301 Treasurer $95,233 $102,102 2023
The American Lyceum VA$218,680 President $167,115 $172,051 2023
South Carolina First Steps To SC$221,612 Executive Di $57,083 $63,498 2023
South Carolina First Steps To SC$227,937 Ed Through 4 $61,759 $68,700 2023
Folk Education Services WA$229,297 Director $21,125 $19,588 2024
Escucha Mi Voz Iowa IA$234,190 Co-director $49,979 $56,677 2024
South Carolina First Steps To SC$240,260 Executive Di $21,173 $23,552 2023
Minnesota Leadership Council On Aging MN$242,300 President $88,000 $87,736 2025
Cyber Texas Foundation Inc TX$243,071 Executive Director/secretary $20,323 $21,055 2024
Davidsonians For Freedom Of Thought And Discourse SC$243,390 Executive Director $80,937 $90,034 2023
Delaware Coalition Against Gun Violence DE$166,353 Executive Director $54,444 $55,212 2024
Allison Rose Foundation OH$165,161 Executive Director $25,000 $27,424 2024
Local Learningthe National Network For Folk Arts In Education NY$245,447 Executive Director $50,496 $48,654 2023
South Carolina First Steps To SC$246,903 Executive Di $45,893 $51,051 2023
South Carolina First Steps SC$247,364 Executive Di $44,313 $49,293 2023
Washington Student Association WA$248,411 Executive Director $60,000 $57,278 2023
The Aakoma Project Inc VA$161,468 President $247,500 $247,500 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to VA 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 VA 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 default3rd
Total compensation (D + F), as reported (no adjustments)5th
Reportable pay only (column D), adjusted7th
All sources (D + E + F), adjusted3rd

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 (Nicole Neily) 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 58 similarly situated organizations (Same NTEE sector (B01), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $8,876 is reasonable (approximately the 3rd 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.