The document is a formal letter from the Council on Governmental Relations (COGR), an association of 190 prominent research universities and affiliated academic institutions, addressed to the U.S. Department of Labor in response to proposed changes regarding overtime pay exemptions under the Fair Labor Standards Act (FLSA). COGR expresses concern over the Department of Labor’s proposal to significantly increase the minimum salary threshold for exempt employees, particularly highlighting the potentially adverse effects on the research sector. The letter emphasizes that postdoctoral scholars, who play a critical role in advancing scientific research and are often funded by federal grants from agencies such as the National Institutes of Health, typically earn salaries below the proposed new exemption level. If the threshold is raised to $50,440, many postdocs would become eligible for overtime pay, which academic institutions may struggle to fund due to constraints in federal and industrial research support budgets.
COGR argues that such a substantial increase could disrupt the research community by reducing the number of research and postdoctoral positions, delaying research progress, and increasing administrative burdens. The organization suggests that a more graduated or incremental approach to increasing salary thresholds would be more manageable and less likely to negatively impact both research productivity and professional development opportunities for postdocs and graduate students. The letter further requests the Department of Labor to consider the unique nature of academic research environments, the importance of flexibility in postdoctoral training, and the absence of sufficient alternative sources of revenue to cover additional costs. COGR concludes by urging reconsideration of the proposed threshold increase, suggesting alternative measures, and asking for meaningful dialogue to avoid unintended consequences for the U.S. research enterprise.
