The document is a formal letter submitted by the Council on Governmental Relations (COGR), an association representing 190 research universities and affiliated institutions, to the U.S. Department of Labor (DOL) regarding proposed changes to the Fair Labor Standards Act regulations. Specifically, the letter addresses the proposed redefinition of exemptions for executive, administrative, professional, outside sales, and computer employees (RIN 1235-AA11), which would significantly increase the minimum salary threshold for exempt employees. COGR expresses concern that raising the salary threshold to $50,440 would negatively affect research institutions, particularly with respect to postdoctoral scholars whose salaries, generally funded through grants and federal agencies such as NIH, often fall below the proposed threshold.
COGR argues that the mandated salary increase could lead to reduced research opportunities, delays or reductions in research progress, and additional financial burdens for institutions, potentially resulting in fewer postdoctoral positions and diminished support for graduate students. The letter notes the unique career development goals and flexible work arrangements typical of postdocs, highlighting the impracticality of imposing standard 40-hour workweeks in academic research settings. COGR recommends that the DOL consider more gradual or alternative approaches to updating salary thresholds, implement changes that do not automatically recur, and avoid unintended negative impacts on the research workforce and national competitiveness. The organization appreciates the opportunity to provide feedback and urges the DOL to take into account the specific needs and structures of higher education research environments when finalizing the rule.
