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PeerBasis
Compensation Comparability Determination

The Foundation For Drug Policy Solutions

Executive Director / CEO

EIN 881041205
VA · NTEE W01
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Luke D Niforatos, Executive Director / CEO ($60,000) against every comparable organization that fit the selection criteria — 262 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 71st percentile of comparable organizationswithin the typical range

Benchmarked executive: Luke D Niforatos — reported title “EXECUTIVE VICE PRESIDENT”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

262 organizations qualified on sector, size, and geography 262 within the band form the benchmarked peer set.

Distribution of comparable compensation

$52 total compensation of comparable organizations → $225,416 $60,000
$4,08910th
$13,97725th
$33,081Median
$66,15575th
$96,77290th
$60,000This org · 71st
p10$4,089
p25$13,977
p50$33,081
p75$66,155
p90$96,772
$60,000

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
American Patriot Service Corporatio UT$184,349 President $11,999 $12,354 2024
Community Leadership Development Program NY$185,289 President & Ceo $76,758 $71,836 2023
Through The Trees NC$183,310 Executive Di $27,388 $28,468 2024
Heartland Center For Leadership NE$183,296 President $75,275 $79,347 2025
Central States Conference On The MI$185,387 Executive Di $37,100 $37,529 2025
March On Harrisburg Education Fund PA$186,332 President $60,000 $61,969 2023
American Legion Post 0094 Charles Pratt Post IN$182,068 Bar Gaming Manager $38,055 $39,330 2025
Grandmother Collective Inc MA$181,647 Executive Director $80,557 $72,822 2024
Veterans Of Foreign Wars 9566vfw-mass MA$180,705 Past Quartermaster $4,410 $3,986 2024
Whitehall Lodge No 1491 Bpoe NY$180,612 Secretary $1,500 $1,328 2025
Pin-ups For Vets CA$188,710 President $107,529 $93,406 2024
The Institute For The Public Trust NC$179,813 Director $72,000 $74,839 2024
Oak Lawn Municipal Employees Credit IL$179,586 Director $27,985 $27,677 2024
Watsontown American Legion Club Inc PA$189,157 Finance Officer $4,050 $4,063 2024
Veterans Of Foreign Wars Of The United States Dept Of Florida FL$179,435 Quartermaster $2,600 $2,393 2025
Barrios Unidos NM$179,237 President And Executive Director $39,670 $44,190 2023
The Utah National Guard Charitable Trust UT$189,694 Executive Dir. $24,000 $24,710 2024
21st Century Alliance CA$191,034 Executive Director $252,054 $225,416 2023
Walter Jones Post 2876 Veterans Of IL$191,118 Jr Vice Comm $10,830 $10,710 2024
Lake Pillsbury Properties CA$177,382 Director $31,276 $26,468 2025
Veterans Of Foreign Wars Department Of AK$176,865 Quartermaster $5,990 $5,931 2023
Main Line Cycle Center MN$194,224 Executive Director $35,984 $36,825 2023
Wildlife Center Friends Inc NJ$195,080 Treasurer $3,480 $3,218 2023
Us Army Warrant Officers Association VA$173,506 Executive Director/ Editor $62,398 $60,608 2024
Emunah Project Inc NJ$173,265 Director $20,880 $19,308 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to VA 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 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 default71st
Total compensation (D + F), as reported (no adjustments)69th
Reportable pay only (column D), adjusted73rd
All sources (D + E + F), adjusted64th

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 (Luke D Niforatos) 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 262 similarly situated organizations (Same NTEE major group (W), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $60,000 is reasonable (approximately the 71st 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.