EP
ExemptPay.com
A board member is asking

A board member questioned your compensation. Respond with data.

When a board member questions pay, the instinct is to justify. The stronger response is to show the data — a Board Confidence Report built from 3.27 million IRS Form 990 records, backed by the same public filings anyone can look up.

Reports from $149 · minutes, not weeks

Build my response →Explore benchmarks free
3 prongs
The rebuttable-presumption safe harbor the IRS looks for
Minutes
From question to a documented, data-backed answer
Verbatim
Board discussion language you can read into the record
The better response

Don’t argue the number. Show the process behind it.

A compensation question from a board member isn’t an attack — it’s a governance duty being exercised. Meeting it with justification and conviction rarely lands. Meeting it with data almost always does.

The strongest answer shows that pay was set through a documented process using comparability data from similar organizations — matched by budget size, geography, and mission. That is precisely the structure the IRS rebuttable presumption rewards.

ExemptPay assembles that answer: which peers are in the comparison group, where your pay sits against them, and minutes-ready language you can read into the record so the discussion is documented as it happens.

3 tests
Independent approval, appropriate comparability data, and contemporaneous documentation. Satisfy all three and compensation is presumed reasonable unless the IRS proves otherwise.

The rebuttable presumption, in three parts.

01
Independent approval
An authorized, conflict-free body — the board or a compensation committee — approves the pay without the executive in the room.
02
Comparability data
Appropriate data on what similar organizations pay. This is the piece ExemptPay supplies, sourced and sample-sized.
03
Contemporaneous record
The basis for the decision is documented in the minutes at the time — not reconstructed later. The report gives you the language.
How it works

From your numbers to a board-ready file in three steps.

1
Enter your details
Title, total compensation, state, and budget size. Your EIN auto-fills the rest.
2
We find your peers
Matched against 3.27M compensation records from IRS Form 990 filings by budget, geography, and mission.
3
Get your report
A board-ready PDF with benchmarks, variance analysis, and minutes-ready discussion language.
Free, right now
The market picture
•Median & percentile ranges by title, budget band, and state
•Sample size on every benchmark you view
•A directional read on where a number sits in the market
In the report · from $149
Your defensible case
✓Your compensation placed against a matched peer group
✓Compa-ratio, position-in-range, and full P10–P90 detail
✓Traffic-light variance signals for every position
✓Rebuttable-presumption (§4958) checklist, ready for your minutes
✓Board discussion language your secretary can paste in
✓Board deck & discussion guide on the Governance tier
See a sample report →
Frequently asked

Responding to a compensation challenge.

How should a nonprofit board respond when executive compensation is questioned?+
The strongest response is data. Boards should show compensation was set using a documented process with comparability data from similar organizations by budget size, geography, and mission. The IRS rebuttable presumption provides the framework.
What data should boards use to benchmark nonprofit executive compensation?+
IRS Form 990 filings are the most comprehensive public source, containing actual reported compensation for every tax-exempt organization’s officers and key employees. ExemptPay aggregates 3.27 million of these records.
What is the IRS rebuttable presumption of reasonableness?+
A safe harbor: if a board uses comparability data, documents the basis for its decision, and ensures independence of decision-makers, compensation is presumed reasonable unless the IRS proves otherwise.
Can a board member’s compensation concern become a legal issue?+
Yes. Excessive compensation can trigger intermediate sanctions — a 25% excise tax on the executive and potentially 20% on approving board members. Documented comparability data significantly reduces this risk.
How can we prevent compensation challenges from catching us off guard?+
Establish an annual compensation review before your fiscal year starts. Boards that benchmark proactively — and keep a current report on file — can respond to any question immediately. The strongest position isn’t a good answer to a hard question; it’s having the documentation already in place when the question arrives.

Related resources

Nonprofit salary benchmarks
See what comparable organizations actually pay their executives.
990 compensation defense
Put your public 990 compensation in context with peer benchmarks.
Compensation documentation
Generate documentation with peer benchmarks and board-ready language.
See a sample report
Preview the Board Confidence Report format before you buy.

Answer the question with data — and document it as you go.

Board-ready reports from $149. Less than a single consultant hour.

Build my response →View pricing