Understanding Form 990 Compensation Data

IRS Form 990 is the single best public source of nonprofit compensation data. Every tax-exempt organization with gross receipts over $200,000 or total assets over $500,000 must file one annually (Form 990 Instructions), and for tax years beginning after July 1, 2019, the Taxpayer First Act requires electronic filing for most exempt organizations — which means the data is machine-readable and available in bulk.

But 990 compensation data has nuances that trip up even experienced analysts. Here’s what you need to know.

Where compensation lives on the 990

Part VII, Section A: Officers, directors, and key employees

This is the primary source for executive compensation data. Per the IRS reporting requirements, every 990 filer must list all current officers, directors, and trustees (regardless of compensation), plus up to 20 key employees with reportable compensation over $150,000, plus the five highest compensated employees with reportable compensation over $100,000. For each person, three columns of compensation are reported:

1. Column D — Reportable compensation from the organization (W-2 or 1099-NEC income)
2. Column E — Reportable compensation from related organizations
3. Column F — Estimated amount of other compensation from the organization and related organizations (deferred comp, nontaxable benefits, etc.)

Total compensation is the sum of all three columns. This is what RightStart uses for benchmarking, matching how the IRS itself defines total compensation in the Form 990 instructions.

Schedule J: Supplemental compensation information

Organizations that answer “Yes” to certain Part VII questions must also file Schedule J, which provides additional detail: first-class travel, housing allowances, club dues, and other perks. This data is valuable for deep-dive analysis, though it’s only required for individuals with over $150,000 in total compensation (Columns D, E, and F combined) from the organization and related organizations.

What the data includes

• Base salary and bonuses — Captured in Column D as reportable W-2 compensation
• Deferred compensation — 401(k)/403(b) employer contributions, pension plan contributions (Column F)
• Health and dental insurance — Employer-paid premiums (Column F)
• Related organization pay — Compensation from a subsidiary or affiliated entity (Column E)

What the data does not include

This matters just as much as what’s in the data:

• Hourly breakdowns — You get annual totals only. A reported $200K figure could cover 12 months or 6 months if the person started mid-year.
• Reliable part-time indicators — The 990 reports “average hours per week devoted to position” but the instructions note this is an estimate. A CFO reporting 40 hours might actually work 50; one reporting 20 is genuinely part-time.
• Equity or stock options — Rare in nonprofits but not unheard of in healthcare systems. Not consistently captured in the standard 990 columns.
• Cost-of-living adjustments — Raw 990 data doesn’t normalize for geography. $150K in Manhattan is very different from $150K in Tulsa.

Title normalization: the hidden challenge

Nonprofits are notoriously inconsistent with titles. The same role might be listed as “Executive Director,” “President & CEO,” “Chief Executive,” or “Managing Director.” Smaller organizations sometimes list the founder as “Director” when they function as the CEO.

Any serious benchmarking tool needs to normalize these titles into comparable role categories. RightStart maps reported titles to eight canonical roles (CEO, CFO, COO, etc.) using pattern matching against thousands of title variations observed across 1.9 million filings.

Filing lag and data freshness

Organizations file their 990 after their fiscal year ends, and the IRS processes electronic filings on a rolling basis. In practice, this means:

• Most available data is 1–2 years behind the current date
• Organizations with June 30 fiscal year-ends file later than those on a calendar year
• The IRS publishes new e-filed returns through the Exempt Organizations Business Master File, but there’s always a processing delay

This lag is inherent to 990-based benchmarking. It’s important to note the tax years covered in any analysis and to account for inflation or market shifts when interpreting results.