Comment from College and University Professional Association for Human Resources

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 will create a significant wage floor shortfall for academic positions and that the Department should conduct a separate analysis for higher education to ensure the rule does not negatively impact the ability to recruit and retain essential faculty and research staff.