Comment from Association of Public and Land-grant Universities (APLU)

Summary: The Association of Public and Land-grant Universities (APLU) opposes the proposed rule, arguing that it imposes undue financial burdens on public universities and disrupts their ability to recruit critical faculty and researchers. They contend that the rule fails to account for the unique salary structures of higher education, ignores the fact that universities do not use foreign labor to undercut U.S. workers, and requests an exemption or a significantly delayed, phased-in implementation.