The intake form already records each participant's employment, salary, and education, but nothing records where they end up. The Scaffold Initiative supports the collection and suggests pairing that starting point with an end point through one optional consent; describing the program participants will actually find, starting with eligibility; completing the Privacy Act statement; recording each credential by name; and correcting the ICR record so OMB reviews an accurate burden estimate.
The Scaffold Initiative is a Wyoming-incorporated 501(c)(4) social welfare organization focused on workforce equity, the capacity of community-based organizations, and the responsible use of technology in workforce programs. We have commented on Workforce Innovation and Opportunity Act (WIOA) state plans, including those of Wyoming, Oklahoma, and Oregon, and on federal workforce data collections, including the Job Corps Placement and Assistance Record (OMB Control No. 1205-0035) and VA’s VET TEC 2.0 employment certification (VA Form 22-10299).
We support this collection. Our work centers on helping people move into the jobs that technology is creating. The IBM SkillsBuild collaboration does exactly that for Veterans, Service members, and their families, at no cost to them. Our comments draw on the draft form and supporting statement posted with the Information Collection Request (ICR) package, and on the program as VA.gov describes it today.
Items 13A through 13D ask whether the applicant works, in which technology field, at what salary range, and with what education. That is a baseline. The package doesn’t yet describe an end point to compare it with. Supporting statement item 2 asks for the “actual use the agency has made of the information.” Item 16 states that the information “is not for publication or tabulation use.” The Government Accountability Office (GAO) saw the same pattern in VA’s original VET TEC pilot, finding that VA did not use the job-type data it collected (GAO-23-105343, October 2022).
The data to close the gap already exists. IBM issues SkillsBuild credentials through Credly, and VA.gov tells applicants that these credentials “are verified proof of your subject matter expertise.” We recommend that VA:
For Veterans, VA could also confirm later employment through new-hire records, using Routine Use 70 of its education records system, as we suggested for VET TEC 2.0. That path needs a full Social Security number and covers Veterans only. The consent route reaches every participant, including spouses, children, and caregivers.
The form, the supporting statement, and VA.gov describe different versions of the program:
| Topic | Form 22-10282 says | Supporting statement and VA.gov say |
|---|---|---|
| Eligibility | Applicant must have “previous or current entitlement under the GI Bill program” | “An eligible individual does not have to have current or previous entitlement under a GI Bill program” (item 12e). VA.gov lists six groups, with no GI Bill requirement |
| Courses | Four choices: cybersecurity or data analytics, basic or advanced, plus “Other” | More than 1,000 courses, including AI, cloud computing, and IT support |
| Course length | Cohorts last 18 weeks, 7 to 10 hours a week | Four months, 8 to 10 hours a week (item 1); VA.gov lists guided courses of 1 to 8 weeks |
| How to apply | On the IBM SkillsBuild website | VA.gov only (notice); email to [email protected] (ICR abstract); online or by emailed paper form (VA.gov forms page) |
Eligibility matters most. A spouse or caregiver who reads the form’s criterion could decide not to apply, though VA’s own materials say they qualify. We assume the supporting statement and VA.gov reflect current policy, and recommend that VA align the form to them. We also recommend that item 11 list the subject areas VA.gov names, that item 7 (cohort date) apply only to guided courses, and that the form name a single way to apply.
The Privacy Act asks each form to state its authority, principal purposes, routine uses, and the effect of not responding (5 U.S.C. 552a(e)(3)). Four short edits would bring the statement up to date:
Where a participant consents, VA should record each credential by the name IBM issues it under, with its date. We also invite IBM to publish SkillsBuild credentials to Credential Engine’s registry. Each published credential receives a Credential Transparency Identifier (CTID), which lets VA compare SkillsBuild results with other VA education programs and link each credential to the occupations it prepares for. We recommended the same identifier for the Job Corps Placement and Assistance Record (Comment of The Scaffold Initiative, FR Doc. 2026-17834, OMB Control No. 1205-0035, submitted September 29, 2026).
The ICR lists a respondent cost burden of $49,559. That figure matches the cost to the Federal Government in supporting statement item 14 ($49,559.48). Applicants pay nothing to complete a free online form, and the prior ICR listed $0. The ICR also answers “No” to whether VA received public comments, while the supporting statement reports one. The Appendix lists these and other small edits.
Every year, about 12,000 Veterans, Service members, and family members tell VA where they stand when they start this program. With one consent checkbox, a form that matches the program, a complete privacy notice, and named credentials, VA can also learn where they end up. The Scaffold Initiative would be glad to help test the revised form with community partners who serve military families.
Respectfully submitted,
Ricky Tucker
Executive Director
The Scaffold Initiative
c/o Northwest Registered Agent LLC
30 N Gould Street, Suite N
Sheridan, WY 82801
[email protected]
| Where | Suggested edit |
|---|---|
| ICR, Annual Cost Burden | Lists $49,559, the government’s cost. Respondents have no out-of-pocket cost. Use $0, as in the prior ICR. |
| Supporting statement, item 13 | Answers “There are no questions of a sensitive nature.” Replace with the respondent cost statement. |
| ICR, public comments | Answers “No.” The supporting statement and ICR list one comment (September 3, 2026). Answer “Yes.” |
| ICR, information collection list | Lists the form number as 22-10285. Use 22-10282. |
| ICR abstract | Says the form is “sent via Email to [email protected].” Match the current online process. |
| Notice, ADDRESSES | Directs commenters to “OMB Control No. 2900-NEW.” Use 2900-0922. |
| Form, page 1, “How do I apply?” | The link …/ibm-skillbuild-program/ returns “page not found.” Use …/ibm-skillsbuild-program/. |
| Form, page 1, first heading | Asks “What is the IBM SkillsBuild Pilot Training Program?” The notice drops “pilot.” Use one name. |
| Form, burden statement | Reads “per respondent, per year,” while the notice lists the frequency as “Once.” Use “per response.” |
| Form, page 2, instructions | Says the form “must be completed in its entirety,” but some items don’t apply to everyone (home number, cohort date, items 13B and 13C). Mark required items. |
| Form, item 13B | Lists five technology fields with no “No” or “Other” option. Add both. |
| Supporting statement | “IMB SkillsBuild” (item 6); “VA Form 2210282” (item 3). |
AI Disclosure: This comment was prepared with the assistance of Claude (Anthropic), which was used for research synthesis, drafting, and citation verification. All substantive positions, recommendations, and strategic judgments are those of The Scaffold Initiative. Facts about the collection come from the Federal Register notices (91 FR 37231 and 91 FR 60699), the draft VA Form 22-10282 and supporting statement posted with ICR Reference No. 202606-2900-004 on reginfo.gov, and VA.gov’s IBM SkillsBuild program and form pages as of October 23, 2026.