February 2022 Letter Regarding Overtime Regulations

This week, Forbes magazine released an article entitled Higher Education Has A Morale Problem, Opposing Higher Pay Will Make It Worse. The article appropriately identifies significant challenges in the higher education workforce: low morale, difficult working conditions (particularly during the pandemic), and depressed salaries. These issues are particularly acute in the student affairs community, as many student affairs staff feel burned-out, exhausted, and are weary of the crisis management, racial inequities, and the college student mental health epidemic that has dramatically changed the landscape of the work itself. 

The article goes on to say “senior administrators and the associations that represent them are about to make things worse for their front-line employees by lobbying against a Biden administration proposal to increase wage minimums for college staff who don’t qualify for overtime pay.” This portion of the article links to a letter that was sent to the Department of Labor (DOL)  from a group of higher education associations, one of which was NASPA.

However, the letter does not, as the Forbes article suggests, argue against increasing base salary levels. Rather, it was written as a request to DOL that higher education be at the table to discuss the implementation and implications of proposed changes.

The letter says specifically: 

“The higher education community believes DOL is obligated to update the regulations governing the EAP exemptions every five to nine years as it did prior to 1975 and that these updates should include appropriate increases to the minimum salary threshold. Given the impact EAP regulatory changes have on the workforce, however, DOL must engage with stakeholders prior to releasing any proposed changes so it can better gauge impacts on employers and employees in an economy that may have changed significantly since the last update.”

These are complex issues. Raising the minimum salary threshold from its current level of $35,568 to $82,732 by 2026 will create unintended consequences for higher education that should at least be examined. To ensure that we best serve employees, the Department of Labor should seek wide input to this rule change.  

Finally, please take a look at the NASPA Future of Student Affairs Task Force report. Building on 18 months of work by staff and volunteers, NASPA takes a clear position on significant workforce issues facing the field and what can be done to address it, advocating for pay equity and increased work flexibility. Two quotes from this report speak to our commitment to examine and challenge long-standing employment structures in student affairs:

“As our responsibilities as student affairs professionals have evolved over time, there is a need for a large-scale updating of job descriptions and clear articulation of position expectations”.

“Adjusting policies and messaging should be one part of a comprehensive and long-term effort to reframe shared assumptions and cultural norms about pace of work and space needed for restorative rest”.

The Task Force makes a clear call to employers to ensure transparent salary information, clear processes for financial incentives, and equitable promotion policies among all staff and faculty at the institution. 

We appreciate the role the Forbes article plays in raising awareness of the morale issues that exist in the higher education workforce, and of the need to examine pay scales for the critical work of student affairs professionals – something that is long overdue. NASPA regularly provides input on policies that would impact the student affairs community. We are not opposed to raising minimum salary thresholds, and  insist that the Department of Labor allow for input as part of making regulatory changes.