The commented letter from the Council on Governmental Relations (COGR), dated September 4, 2015, addresses the U.S. Department of Labor's proposal to significantly raise the minimum salary threshold for exempt employees under Fair Labor Standards Act (FLSA) rules (RIN 1235-AA11). COGR, representing 190 research universities and affiliated institutions, expresses concern that more than doubling the exempt salary threshold would have detrimental effects on the research community, particularly for postdoctoral scholars and entry-level research professionals. The letter highlights that postdoctoral salaries, often funded by federal grants and set by agencies such as the NIH, typically fall below the proposed minimum. Mandating overtime eligibility for this group could lead to increased costs, administrative burdens, and potential delays or reductions in research and training opportunities, alongside negative impacts on budgets supporting research enterprise, including global competitiveness and workforce development.
COGR acknowledges the importance of fair compensation and supports gradual, realistic increases in salary levels to benefit employees. However, the organization urges the Department of Labor to consider alternative, phased approaches—rather than a swift, large-scale increase—to avoid disruptions to research operations and training programs. The letter recommends excluding automatic updates to the salary threshold and requests that new regulations not impose undue administrative or financial burdens. COGR stresses the need for flexibility in managing research personnel and maintaining institutional competitiveness, noting that postdoctoral work is central to research advancement, supervision, and educational missions at universities. Overall, the letter advocates for policy adjustments that balance fair labor practices with the unique operational realities of the academic research environment.
