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PeerBasis
Compensation Comparability Determination

Good Counsel Cooperative

Executive Director / CEO

EIN 931551609
CO · NTEE S20
FY ending 2024-06-30
June 9, 2026

This analysis benchmarks the total compensation of Rebecca Miller, Executive Director / CEO ($32,083) against every comparable organization that fit the selection criteria — 294 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 19th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Rebecca Miller — reported title “PRESIDENT/EX”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

294 organizations qualified on sector, size, and geography 294 within the band form the benchmarked peer set.

Distribution of comparable compensation

$636 total compensation of comparable organizations → $190,892 $32,083
$18,43510th
$38,11925th
$64,975Median
$84,81875th
$109,81490th
$32,083This org · 19th
p10$18,435
p25$38,119
p50$64,975
p75$84,818
p90$109,814
$32,083

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 CO 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
The High Point Community Development Cor CA$277,109 Executive Dir. $79,700 $71,772 2024
Community Action Team-california Inc CA$273,760 Chief Executive Officer $105,000 $94,556 2024
Erie Together PA$280,307 Executive Director $94,000 $95,240 2025
Allston Village Main Streets Inc MA$280,379 Executive Director $83,200 $75,961 2025
New Season Community Development Corp CA$273,020 Director $45,000 $40,524 2024
Elyria Community Partnership OH$280,473 Executive Director $79,276 $87,566 2024
Urban University CA$271,812 Executive Director $64,896 $56,934 2025
Woodbridge Neighborhood Development Corporation MI$271,107 Executive Director $53,000 $58,736 2023
Haverford Partnership For Economic PA$282,424 Executive Di $46,453 $49,738 2023
Visions America Cdc MD$282,496 President $33,664 $32,822 2024
Main Street Greeneville TN$270,833 Executive Director $44,166 $48,415 2024
Batavia Mainstreet IL$282,717 Executive Dir. $67,083 $70,810 2023
Parkville Community Development Cor MO$270,419 Executive Di $62,515 $69,053 2024
Producir Inc Una Corp De Desarrollo Comunal Y Econ Para Cubuy Y Lomas PR$283,505 Ceo $54,445 $54,445 2024
New Mexico Appleseed NM$284,037 Executive Di $151,740 $175,231 2023
Sheppard Military Affairs Committee TX$284,060 President $90,000 $91,469 2025
The Montague Street District Management NY$284,926 Executive Direc $61,285 $57,754 2024
Beloved Community Ministries Inc GA$268,315 Executive Dir. $14,485 $15,638 2023
North Capital Main Street DC$285,374 Executive Director $48,182 $45,397 2023
Raton Mainstreet Inc NM$267,245 Executive Director $50,000 $54,638 2025
Partners For Livable Omaha NE$286,715 Executive Director $69,383 $77,826 2024
Connect Waukegan Nfp IL$287,155 Executive Dir. $119,550 $122,572 2024
Ken-rock Community Center Inc IL$287,423 President & Ceo $64,820 $68,422 2023
Main Street Gettysburg Inc PA$287,455 President $80,822 $84,055 2024
Homer-cortland Community Agency Inc NY$264,626 Executive Director $72,500 $70,340 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to CO 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 CO 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 default19th
Total compensation (D + F), as reported (no adjustments)20th
Reportable pay only (column D), adjusted21st
All sources (D + E + F), adjusted18th

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 (Rebecca Miller) 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 294 similarly situated organizations (Same NTEE sector (S20), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $32,083 is reasonable (approximately the 19th 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.