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PeerBasis
Compensation Comparability Determination

Pathways To Safety International

Executive Director / CEO

EIN 931281870
OR · NTEE I71
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Paula Lucas, Executive Director / CEO ($13,713) against every comparable organization that fit the selection criteria — 11 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 27th percentile of comparable organizationswithin the typical range

Benchmarked executive: Paula Lucas — reported title “Founder/Treasurer”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

11 organizations qualified on sector, size, and geography 11 within the band form the benchmarked peer set.

Distribution of comparable compensation

$5,288 total compensation of comparable organizations → $95,538 $13,713
$7,85510th
$13,60925th
$25,583Median
$30,60275th
$37,95090th
$13,713This org · 27th
p10$7,855
p25$13,609
p50$25,583
p75$30,602
p90$37,950
$13,713

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
Guardian Care Foundation Inc FL$36,501 Executive Director $24,564 $25,583 2023
Columbus Police Foundation OH$40,038 Board Chair/ $10,500 $11,975 2024
New Jersey Institute Of Local Government NJ$41,736 Executive Director $5,500 $5,288 2024
Sheila D Brown Women's Center PA$42,037 Director Of Construction $13,787 $15,242 2023
Andrea Project Inc TX$42,247 Executive Di $16,961 $18,270 2024
North Carolina State Bar Foundation NC$45,805 Executive Di $33,129 $37,950 2023
Gasp Guardians Advocating Child OH$46,386 Executive Di $25,491 $29,932 2023
Colorado Foundation For Justice CO$26,000 Executive Director $26,112 $26,962 2024
Families Of Twa Flight 800 Association Inc NY$51,715 Secretary & Ceo $98,184 $95,538 2024
Truth Be Told TX$52,063 Executive Director $7,292 $7,855 2024
Stop Dui Inc NV$52,163 Executive Director $28,971 $31,271 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 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 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 default27th
Total compensation (D + F), as reported (no adjustments)27th
Reportable pay only (column D), adjusted73rd
All sources (D + E + F), adjusted27th

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 (Paula Lucas) 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 11 similarly situated organizations (Same NTEE major group (I), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $13,713 is reasonable (approximately the 27th 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.