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PeerBasis
Compensation Comparability Determination

Pro Bono Organization For Native

Executive Director / CEO

EIN 932951959
HI · NTEE I80
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Heidi Ho, Executive Director / CEO ($80,000) against every comparable organization that fit the selection criteria — 93 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 34th percentile of comparable organizationswithin the typical range

Benchmarked executive: Heidi Ho — reported title “EXECUTIVE DI”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

93 organizations qualified on sector, size, and geography 93 within the band form the benchmarked peer set.

Distribution of comparable compensation

$14,547 total compensation of comparable organizations → $454,403 $80,000
$50,25310th
$68,15125th
$92,242Median
$112,20375th
$144,22490th
$80,000This org · 34th
p10$50,253
p25$68,151
p50$92,242
p75$112,203
p90$144,224
$80,000

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 HI 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
Monroe County Senior Legal Services MI$363,058 Executive Director $69,884 $80,567 2024
Childrens Advocacy Center Of West Texas Inc TX$363,194 Exec Director $66,458 $74,252 2024
National Veterans Benefits Attorneys Inc FL$365,619 Executive Director $48,750 $52,663 2023
Self Help Inc NM$358,462 Executive Dir. $60,320 $74,605 2023
Iron Defense MI$367,750 Executive Director $106,570 $122,861 2024
Financial Protection Law Center NC$370,385 President/e.d. $122,197 $145,192 2023
Equal Access Legal Services Inc PA$353,409 Executive Director $90,975 $101,332 2024
Women Against Abuse Legal Center PA$348,150 Executive Director & Presi $12,685 $14,547 2023
Southwest Georgia Legal Self-help GA$342,337 Executive Di $33,182 $37,265 2024
Legal Resource Center On Violence Against Women Inc MD$340,335 Executive Director $117,620 $119,656 2025
Greater Dayton Volunteer Lawyers Project OH$339,911 Executive Director $87,000 $102,922 2024
The Association Of The Federal Bar Of The State Of New Jersey NJ$384,805 Executive Director $64,700 $62,858 2025
Legal Works Inc OH$385,248 Non Voting M $94,000 $114,488 2023
Oklahoma Access To Justice Foundation OK$387,073 Executive Director $78,869 $97,001 2024
Court Appointed Special Advocates TX$387,568 Executive Di $66,867 $74,709 2024
World Immigration Center Inc NY$335,018 Secretary $25,829 $26,839 2023
Neighborhood Legal Support Of Kansas City MO$390,055 Executive Director $98,099 $116,052 2024
Atlantic Area Court Appointed Casa GA$333,808 Director $76,016 $85,371 2024
West Florida Center For Trafficking Advocacy Inc FL$391,812 Director $94,765 $99,435 2024
Trinity Legal Clinic Of Oklahoma OK$326,987 Executive Dir. $56,347 $69,301 2024
Ventura County Legal Aid Inc CA$400,550 Director $70,050 $67,562 2024
Legal Assistance Center MI$406,111 Executive Di $100,570 $115,944 2024
Emergency Legal Responders LA$317,714 Executive Director $80,125 $101,457 2023
People With Disabilities Foundation CA$409,253 President & $91,826 $91,180 2023
Volunteer Lawyer Program Of Northeast IN$409,557 Executive Dir. $84,500 $99,530 2024

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to HI 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 HI 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 default34th
Total compensation (D + F), as reported (no adjustments)47th
Reportable pay only (column D), adjusted35th
All sources (D + E + F), adjusted33rd

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 (Heidi Ho) 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 93 similarly situated organizations (Same NTEE sector (I80), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $80,000 is reasonable (approximately the 34th 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.