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.
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)
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)
