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January 15, 2020


Dear ASHE Members,

As you may know, the National Labor Relations Board (NLRB) is engaged in rule making to establish the standard for determining whether students who perform services at a private college or university in connection with their studies are “employees” within the meaning of Section 2(3) of the National Labor Relations Act (29 U.S.C. § 152(3)).

Based upon the recommendation of the ASHE Position Taking Committee, the ASHE Board of Directors has voted to submit a comment to the NLRB on this issue. We are grateful to the sub-committee which took on the task of writing this statement on behalf of ASHE: Gary Rhoades (University of Arizona),  Gerardo Blanco (University of Connecticut), Leslie D. Gonzales (Michigan State University), and Daniel Saunders (Florida International University).  
The statement is structured around the three central questions raised by the NLRB and contains relevant research findings (much by our members), concrete examples of policies and practices at public and private institutions and references to relevant law and precedent. It is the very best example of what was intended in creating the position-taking committee and process--that is, that we as ASHE members engage our research with policy and practice questions as they arise in real time.

Please see below for additional information on the ASHE Position Taking Policy.

Sincerely,  
KerryAnn O'Meara
ASHE President
About ASHE's Position Taking Policy and Process
The ASHE Position Taking Policy was adopted in July 2013.

Members of the 2019 Position Taking Committee committee were:
  • Christine Stanley (Chair), Texas A&M University
  • Joy Blanchard, Louisiana State University
  • Deborah Carter, Claremont Graduate University
  • Susan Marine, Merrimack College
  • KerryAnn O'Meara, University of Maryland

Members of the 2020 Position Taking Committee committee are:
  • Joy Blanchard (Chair), Louisiana State University
  • Michael Brick, Institute for Higher Education Policy
  • Deborah Carter, Claremont Graduate University
  • Susan Marine, Merrimack College
  • D-L Stewart, Colorado State University

Questions about the ASHE Position Taking process can be directed to ASHE Executive Director Jason P. Guilbeau at [email protected].