The September 4, 2015 letter from the Council on Governmental Relations (COGR), representing 190 research universities and affiliated institutes, addresses the U.S. Department of Labor's proposed changes to the exemptions for executive, administrative, professional, outside sales, and computer employees under RIN 1235-AA11. The primary concern expressed is the Department’s plan to significantly increase the minimum salary threshold for exempt employees, which would impact a broad segment of the research workforce, notably postdoctoral scholars and entry-level professionals whose salaries often fall below the proposed new threshold. COGR acknowledges the need for fair compensation but argues that the abrupt and substantial salary increase would have adverse effects, such as reduced opportunities for research and training, delayed research progress, and increased administrative and financial burdens on institutions dependent on federal and industrial funding.
Specifically, COGR cites the potential for disruptions in graduate and postdoctoral research due to the necessity of overtime payments, impediments to flexible work arrangements, and the financial infeasibility of covering increased salary costs through existing grant mechanisms. The organization recommends a graduated approach to salary adjustment to mitigate negative impacts on research and training and urges consideration of alternative measures that balance fair pay with the sustainability of the research ecosystem. Furthermore, COGR highlights the lack of federalism implications and cautions against imposing additional regulatory burden without fully assessing the repercussions for research institutions and the development of future scientists. The letter calls for thorough reconsideration before implementing the proposed rule changes.
