Improving Wage Protections for the Temporary and Permanent Employment of Certain Foreign Nationals in the United States

The Consumer Technology Association (CTA) opposes the proposed rule, arguing that it will significantly increase labor costs for U.S. businesses, particularly startups and small companies. They contend that the rule creates workforce uncertainty, reduces access to critical global talent, and will ultimately harm U.S. competitiveness by pushing innovation and investment overseas.

The University of Colorado opposes the proposed rule because it believes the upward recalibration of prevailing wage levels will disproportionately harm higher education, disrupt clinical staffing, and limit the recruitment of global talent in research and healthcare. The university requests that the Department of Labor preserve distinct treatment for academic institutions, adjust wage methodologies to reflect grant-funded roles, and provide extended transition periods.

The National Immigration Forum, a nonprofit organization advocating for immigration, opposes the proposed rulemaking because it relies on broad percentile increases that do not account for individual experience, skills, or market realities. They argue the rule will create labor market disruptions, hinder workforce development for early-career professionals, and reduce the U.S. economy's global competitiveness.

The Software & Information Industry Association (SIIA) opposes the proposed rule, arguing that it would cause substantial industry disruption and disproportionately harm small and medium-sized enterprises. They contend that the new prevailing wage methodology fails to account for non-salary compensation like equity and violates statutory rights by restricting the use of private wage data.

The Software & Information Industry Association (SIIA) opposes the proposed rule because it raises prevailing wage thresholds in a way that disproportionately harms small and medium-sized enterprises and ignores non-salary compensation like equity. They argue the rule disrupts the information industry's ability to attract talent and potentially violates statutory rights by restricting the use of private wage data.

The Conference of Boston Teaching Hospitals, representing 12 member hospitals, opposes the proposed rule because it would significantly increase prevailing wage requirements for H-1B and other visa holders. They argue that these dramatic wage increases would make it financially unworkable to hire and retain highly specialized researchers and clinicians, potentially driving talent out of the U.S. and increasing healthcare costs.

The Business Roundtable opposes the proposed rule, arguing that it fails to account for recent H-1B program changes, creates significant business uncertainty by lacking a transition period, and restricts critical talent pipelines for early-career professionals. They request that the Department conduct further analysis on these impacts and consider "total compensation" models before proceeding with regulatory changes.

Emory University opposes the proposed rule, arguing that the new prevailing wage methodology fails to account for the unique structure of academic and research labor markets. They contend that the proposed wage floors would create internal pay inequities, disrupt the talent pipeline for research and education, and lead to critical positions remaining unfilled due to federal compensation constraints.

The University of Pennsylvania opposes the proposed rule because it fails to account for the unique wage structures and federal funding constraints of academic research, specifically regarding postdoctoral trainees. They argue that the proposed prevailing wage levels would exceed federal stipend benchmarks and could undermine U.S. research capacity and innovation.

TechNet, a national network of technology CEOs and executives, opposes the proposed rule because it imposes artificial wage floors that do not reflect market realities, particularly in the high-skilled technology sector. They argue the rule will eliminate entry-level pathways for graduates, incentivize offshoring of innovation, and ignore standard compensation components like equity and performance bonuses.