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Affordable Care Act Alerts

View the ACA Alert archive.

Washington Insider Alerts

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Public Policy Committee

The Public Policy Committee recommends to the board of directors positions and priorities on legislative and regulatory issues impacting CUPA-HR members. View the association’s current Public Policy Statement.

CUPA-HR Advocacy Positions

CUPA-HR Letters and Briefs

We frequently collaborate with other higher ed and HR associations to “weigh in” on important issues. Below are the letters and briefs to regulatory agencies, Congress and the courts that CUPA-HR has submitted on its own or has participated in developing with other organizations.

2014

Paycheck Fairness Act

Letter to U.S. Senate Leadership Opposing Cloture (and the Underlying Bill) on the Paycheck Fairness Act (S. 2199) (September 10, 2014)

Campus Accountability and Safety Act

Comments to the U.S. Senate Committee on Health Education, Labor & Pensions on S. 2692, the Campus Accountability and Safety Act (CASA) (September 5, 2014)

Higher Education Act Reauthorization Discusson Draft

Letter to Senator Tom Harkin Regarding His HEA Reauthorization Discussion Draft (August 29, 2014)

Treatment of Student Employees Under the Employer Mandate of the ACA (H.R. 5298)

Letter of Endorsement of the Student Job Protection Act of 2014 (August 13, 2014)

Treatment of Student Employees Under the Employer Mandate of the ACA (H.R. 5262)

Letter of Endorsement of the Student Worker Exemption Act of 2014 (August 13, 2014)

Definition of “Spouse” for Purposes of the Family and Medical Leave Act (FMLA)

Comments in Response to the Department of Labor’s Notice of Proposed Rulemaking, 79 Fed. Reg. 36445 (August 11, 2014)

Student Worker Exemption Act

Statement in Support of the Student Worker Exemption Act (July 28, 2014)

Student and Family Tax Simplification Act

Letter to the House Regarding H.R. 3393, the Student and Family Tax Simplification Act (July 17, 2014)

Terrorism Risk Insurance Program

Letter to the House in Support of S. 2244, the Terrorism Risk Insurance Program Reauthorization Act of 2014 (July 16, 2014)

Higher Education IRA Rollover

Letter to the House Urging Passage of H.R. 4619 to Permanently Extend the IRA Charitable Rollover (July 16, 2014)

Student-Athletes and the NLRA

Amicus Brief in Northwestern University v. College Athletes Players Association (CAPA) in Support of Employer (July 3, 2014)

Gainful Employment (GE) Regulations

Letter to U.S. Department of Education offering comments supporting gainful employment regulations (May 27, 2014)

Terrorism Risk Insurance Act (TRIA)

Letter to House and Senate urging reauthorization of the Terrorism Risk Insurance Act (TRIA) currently scheduled to expire this year (April 24, 2014)

Do Interns Have to Be Treated as Employees under the FLSA Act of 1938?

Amicus Brief in Glatt v. Fox Searchlight on the issue of the national availability of internships undertaken by college students (April 7, 2014)

NLRB Representation-Case Procedures

Comments submitted to the NLRB regarding the notice of proposed rulemaking (79 FR 7318) to amend representation-case procedures (April 7, 2014)

Tax Reform Act of 2014

Letter to House Ways and Means Committee regarding higher education provisions in the Tax Reform Act of 2014 discussion draft (April 4, 2014)

Paycheck Fairness Act

Coalition Letter to Senate regarding Opposition to the Paycheck Fairness Act (S.2199, originally introduced as S.84) (April 4, 2014)

Extension of Expired Higher Education Tax Incentives

Letter to Senate Finance Committee and House Ways and Means Committee regarding extensions of expired higher education tax incentives which expired at the end of 2013 (March 28, 2014)

Managerial Status of Professors at Private Universities

Amicus Brief in Pacific Lutheran University v. SEIU, Local 925 on the issue of when professors at private universities should be considered managerial employees (March 28, 2014)

OSHA Injury and Illness Electronic Reporting Rule

Letter to OSHA regarding proposed rule to improve tracking of workplace injuries and illnesses (March 10, 2014)

Candidate-Related Political Activities

Joint Letter to the IRS on Guidance for Tax-Exempt Social Welfare Organizations on Candidate-Related Political Activities (February 27, 2014)

Immigration

Joint Letter to the U.S. House Leadership on Immigration Reform and Higher Education (February 12, 2014)

Postsecondary Institution Ratings

Response to the Department of Education’s Call for Comment on the Postsecondary Institution Ratings System RFI (January 31, 2014)

2013

DOL Worker Classification Survey

CUPA-HR Comments on DOL’s Proposed Information Collection Request for the Worker Classification Survey (December 9, 2013)

Employment Nondiscrimination Act

CUPA-HR Letter to the U.S. Senate in Support of ENDA (November 5, 2013)

Affirmative Action

Amicus Brief on Diversity in Schuette v Coalition (August 30, 2013)

Office of Federal Contract Compliance Programs

Letter to the Secretary of Labor on OFCCP (July 31, 2013)

ACA and Student Employment

Joint letter to the Treasury and IRS in support of safe harbors related to student employment (July 16, 2013)

Employment Non-Discrimination Act (ENDA)

CUPA-HR Letter to Senate Committee in Support of ENDA Amendment (July 10, 2013)

Border Security, Economic Opportunity, and Immigration Modernization Act of 2013

Joint letter to the Senate on S. 744 (June 20, 2013)

The Legal Workforce Act

Testimony of Jill G. Blitstien on Behalf of CUPA-HR on the Legal Workforce Act Before the U.S. House Subcommittee on Immigration and Border Security (May 16, 2013)

Border Security, Economic Opportunity, and Immigration Modernization Act of 2013

Joint letter to the Senate Judiciary Committee on S. 744 (re: H-1b and L-1 visa programs) (May 13, 2013)

Border Security, Economic Opportunity, and Immigration Modernization Act of 2013

Joint letter to the Senate Judiciary Committee on S. 744 (re: STEM degree graduates) (May 8, 2013)

Working Families Flexibility Act of 2013

Joint letter to the House of Representatives in support H.R. 1406, which extends to private sector employers the option to offer comp time (May 7, 2013)

Working Families Flexibility Act of 2013

Joint letter to the Committee on Education and the Workforce in support H.R. 1406, which extends to private sector employers the option to offer comp time (April 16, 2013)

Tax Treatment of Retirement Plans and Individual Savings Arrangements

Joint Statement to the Ways and Means Tax Reform Working Group (April 12, 2013)

Working Families Flexibility Act of 2013

CUPA-HR President and CEO testifies before the House Education and Workforce Subcommittee on Workplace Protections in support of the Working Families Flexibility Act (April 11, 2013)

Update on ACA, Adjuncts and Student Employees

Comments in Response to IRS Section 4980H Re: Shared Responsibility for Employers Regarding Employee Health Coverage (March 18, 2013)

Wage and Hour Division’s Plans for a Worker Classification Survey

CUPA-HR Comments on the Flaws in DOL Assumptions and Proposed Survey Methodology (March 12, 2013)

2012

Title VII of the Civil Rights Act – what constitutes a “supervisor” in harassment cases

Vance v. Ball State University, Brief of the Society for Human Resource Management et al. as Amici Curiae in Support of Respondent (October 26, 2012)

Patient Protection and Affordable Care Act – definition of full-time employee

CUPA-HR Comments in Response to IRS Notices 2012-58 and 2012-59 Re: Provisions Enacted as Part of the Patient Protection and Affordable Care Act of 2012 (PPACA) (September 27, 2012)

Employers for Flexibility in Health Care (EFHC) Comments in Response to IRS Notices 2012-58 and 2012-59 Re: Provisions Enacted as Part of the Patient Protection and Affordable Care Act of 2012 (PPACA) (September 27, 2012)

STEM Jobs bill – to establish a new green card program for outstanding STEM advanced degree graduates

Letter to the House with Other Employer Organizations Asking for Bipartisan Passage of H.R. 6429, “STEM Jobs Act of 2012” (September 19, 2012)

Labor Condition Application (ETA Form 9035) – DOL proposes form expansion and changes

CUPA-HR comments in Response to Proposed Changes to ETA Form 9035 Labor Condition Application (ETA Form 9035) (September 7, 2012)

Admission Decisions – the use of race as one factor

Fisher v. University of Texas. Brief of American Council on Education et al. as Amici Curiae in support of Respondent (August 13, 2012)

Organizing Graduate Students – NLRB – rights of private college graduate students to organize

NYU v. GSOC/UAW and Polytechnic Institute of New York University v. International Union, United Automobile Aerospace and Agricultural Implement Workers of America, UAW. Brief of American Council on Education et al. as Amici Curiae to the NLRB in NYU Cases (July 23, 2012)

Title VII of the Civil Rights Act – OFCCP – Proposed Regulations Revising Non-Discrimination and Affirmative Action Regulations of Section 503 of the Rehabilitation Act of 1973

Letter to House Appropriators Regarding Funding Limitations for the OFCCP on the NPRM Revising the Regulations Implementing the Non-Discrimination and Affirmative Action Regulations of Section 503 of the Rehabilitation Act of 1973 (July 16, 2012)

STEM Jobs bill – to establish a new green card program for outstanding STEM advanced degree graduates

Letter to the House with Other Employer Organizations Calling on Congress to Pass a STEM Visa Bill Establishing a Green Card Program for Outstanding STEM Advanced Degree Graduates (July 12, 2012)

Faculty Unionization – NLRB – faculty NLRA coverage at private institutions

Point Park University v. Newspaper Guild of Pittsburgh/Communications Workers of America, Local 38061, AFL-CIO, CLC. Brief of American Council on Education et al. as Amici Curiae to the NLRB to Defer to Supreme Court Decision on Faculty Unionization (July 6, 2012)

Patient Protection and Affordable Care Act – minimum value, reporting requirements and employment verification

Employers for Flexibility in Health Care Coalition (EFHC) Comments in Response to IRS Notices 2012-31, 2012-32 and 2012-33 and an HHS Bulletin Re: Guidance on the PPACA provisions on Minimum Value, Reporting Requirements, and Employment Verification (June 11, 2012)

Patient Protection and Affordable Care Act – minimum value, reporting requirements and employment verification

Employer Group Letter to Senate urging a no vote on the Paycheck Fairness Act (S. 3220) (May 24, 2012)

Title VII of the Civil Rights Act – OFCCP – Proposed Regulations Revising Non-Discrimination and Affirmative Action Regulations of Section 503 of the Rehabilitation Act of 1973

Employer Groups Letter to DOL expressing concerns on Proposed OFCCP Rule Changes to Non-Discrimination and Affirmative Action Regulations of Section 503 of the Rehabilitation Act of 1973 (May 23, 2012)

FMLA – DOL – proposed changes to FMLA regulations

National Coalition to Protect Family Leave Comments in Response to the DOL’s February 15 Notice of Proposed Rulemaking Proposing Changes to the FMLA Regulations (April 30, 2012)

Hiring Process – EEOC – Criminal-Background Checks

Employer Groups Letter to EEOC about Pending Guidance on Criminal-Background Checks (April 18, 2012)

OFCCP – aggressive agenda and employer burdens

CUPA-HR and SHRM Letter to House Committee About Recent OFCCP Activity (April 17, 2012)

Title VII of the Civil Rights Act – OFCCP – Proposed Regulations on Affirmative Action Requirements for Individuals with Disabilities

SHRM and CUPA-HR Comments on OFFCP Notice of Proposed Rulemaking Regarding Affirmative Action Requirements for Individuals with Disabilities (February 20, 2012)

Hiring Process – EEOC – Criminal-Background Checks

Employer Groups Letter to the EEOC re: EEOC Policy Statement on the Issue of Conviction Records under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq. (1982) (February 1, 2012)

Federal Contractor Compliance – USDA – proposed mandate that contractors certify they are in compliance with “all applicable labor laws”

CUPA-HR and SHRM Comments on Agriculture Acquisition Regulation, Labor Law Violations; Direct Final Rule (76 Fed. Reg. 74722, December 1, 2011), RIN 0599-AA19, and Proposed Rule (76 Fed. Reg. 74755, December 1, 2011), RIN 0599-AA19 urging withdrawal as proposals would result in serious punitive consequences for even a minor technical violation of “any” labor law (January 30, 2012)

CUPA-HR and ACE Comments on Agriculture Acquisition Regulation, Labor Law Violations; Direct Final Rule (76 Fed. Reg. 74722, December 1, 2011), RIN 0599-AA19, and Proposed Rule (76 Fed. Reg. 74755, December 1, 2011), RIN 0599-AA19 urging withdrawal as proposals would result in serious punitive consequences for even a minor technical violation of “any” labor law (January 30, 2012)