Comment from College and University Professional Association for Human Resources
College and University Professional Association for Human ResourcesOpposeAdvocacy
Summary: CUPA-HR, representing higher education institutions, opposes the proposed rule because it fails to account for the unique labor market dynamics and operational constraints of the higher education sector. They argue that the proposed methodology, particularly the use of national wage estimates and the lack of separate analysis for higher education, will create significant wage floor shortfalls and hinder the ability of institutions to recruit and retain essential faculty and research staff.
See attached file