Some questions about wage rate survey

The prevailing wage rate survey is finally published and I understand it’s one of a kind for the CNMI.  I read the article announcing this matter thoroughly and feel that what was printed by the media represented a good overview of the details of the volume of data collected and analyzed for the final published report. However, I do have some questions and perhaps these inquiries would also help the users of the final prevailing wage report as I gather that the Governor’s Office is also conducting a separate prevailing wage survey of its own. A survey like this is subject to a test of its validity and reliability based on the data that comprises the survey—from data collection, selection, compilation, and analysis to its final report form. In addition, footnotes on specific issues do affect the interpretation of the data, and certainly one must fully review this type of added comment in order to fully understand the limitations and special circumstances of the survey.

With respect to the validity of the survey, what method did the contractor use to collect credible data from the intended population group? I understand that a large number of questionnaire forms were sent out, and only half of the questionnaires were returned and used for the data. Of the number of accepted questionnaire forms, how many were discarded and how many were finally used for data? Has the contractor tested the readability level of the survey? What readability method was used and what was the target reading index and why was that reading level used as the basis for the survey questionnaires?

With respect to the reliability of the final prevailing wage rate findings and conclusions, how certain is the contractor about the recommended prevailing wage rate as the CNMI’s representative actual prevailing wage rate for the type of jobs or cluster of jobs? The number of unanswered survey questionnaires is substantial. Is this material to the reliability of the findings and final determination of the prevailing wage rate? If reliability is questionable, would the contractor use another approach and methodology, and what would that methodology be?

The report, based on media reports, referenced the prevailing wage rate as dollar per hour amount for jobs subject of the survey. I understand that the job descriptions used for questionnaires were derived from the FLSA job descriptions, including the clustering of jobs per general categories such as executive, managerial, professional, vocational, and others. The FLSA job description is an excellent source for describing jobs, and from such reliance for job information we could isolate the exempt and non-exempt jobs. However, borderline job description of the actual job in the survey do make an big impact, in which case the contractor would address special footnotes in those cases. The problem with respect to the per hour wage determination is that it matters because such a way of remuneration do not apply to executive, managerial, and professional cluster of jobs as these jobs are exempt and are paid on salary basis, not on a per-hour basis. Reporting a president of a company as earning $42.50 per hour is unheard of and do present serious flaws in the analysis. Even for the sake of argument, if this is acceptable by the contractor, what per year annual work hours was used for this purpose? The 2,080 standard hours for non-exempt jobs do carry this method, but for exempt, that is questionable. So what explanation could the contractor offer in these cases? On another note, an absent owner who is paid $100,000 per year, and never sets foot in the CNMI, does this mean that the exempt job is paid at $100,000 per hour? For clarification, this type of issues should be explained and demonstrated fully by the contractor in order to arrive at a most reasonable and credible wage rate for all jobs found in industries spread out among the three islands of the CNMI.

This is just the tip of the iceberg of questions about this survey report. Rest assured that we will continue to ask so we could arrive at a true and actual prevailing wage rate. In giving full faith reliance on this impartial survey (if that is the case), life and living wages of the lower rung wage earners and working poor would be impacted, including the survivability of small businesses that are the major employers in the CNMI.