Comment from National Association of Manufacturers (NAM)

Summary: The National Association of Manufacturers (NAM) opposes the proposed rule, arguing that it relies on obsolete data, creates internal inconsistencies in wage level definitions, and fails to account for the full scope of compliance and compensation costs. They contend that the rule will hinder manufacturing growth by restricting access to high-skilled immigrants and recommend that the ETA reconsider the proposal or, at minimum, implement a multi-year phase-in period.