Letter on H1B Prevailing Wage Rule

Dear Administrator Pasternak,

On behalf of the College and University Professional Association for Human Resources (CUPA-HR) and undersigned organizations, we write in response to the Notice of Proposed Rulemaking (NPRM) published March 27, 2026 in the Federal Register by the Department of Labor (Department), entitled Improving Wage Protections for the Temporary and Permanent Employment of Certain Foreign Nationals in the United States.1

CUPA-HR serves as the voice of human resources in higher education, representing more than 25,000 human resources professionals and other higher-education leaders at more than 1,725 colleges and universities across the country, including 88 percent of all U.S. doctoral institutions, 66 percent of master’s institutions, 45 percent of bachelor’s institutions, and nearly 600 two-year and specialized institutions. The institutions represented by this comment include major research universities, academic medical centers, regional public universities, liberal arts colleges, and community colleges that rely on highly skilled international faculty, researchers, instructors, clinicians, and other professionals to support institutional teaching, research, and patient-care missions.

CUPA-HR and the undersigned organizations submit this comment to express substantial concern regarding the proposed rule’s effects on institutions of higher education and affiliated research enterprises. Higher-education employers use the H-1B, H-1B1, E-3, and PERM (permanent labor certification) programs principally to recruit and retain faculty, postdoctoral researchers, research scientists, instructors, physicians, and other specialized personnel in fields where advanced graduate training is the norm and where institutions compete in national and international academic labor markets. The proposed changes would significantly affect higher education’s ability to recruit and retain this workforce and would disrupt academic hiring, research operations, clinical programs, and grant-funded positions across the sector…

Please view the attachment for the full letter.