Comment from Center for Strategy and Applied Insights at Fragomen

Summary: The Center for Strategy and Applied Insights at Fragomen opposes the proposed prevailing wage methodology, arguing that the percentile-based approach is statistically unsound and fails to distinguish workers based on experience, education, or supervision as required by statute. They advocate for an "experience benchmarking" approach, which they claim would more accurately identify market wages and provide better worker protections without creating new administrative burdens for employers.