The Scaffold Initiative submitted this comment on Florida's WIOA State Plan Modification for Program Years 2026-2027. Florida's economic scale and diversity make AI literacy investment both urgent and high-impact: the state's tourism and hospitality sector employs hundreds of thousands of workers encountering AI in customer service and revenue management, while the Space Coast's aerospace and defense corridor deploys AI across mission planning, manufacturing, and logistics. Florida's agricultural sector — including citrus, specialty crops, and aquaculture — is adopting AI-driven precision farming and automated harvesting. We recommend designating AI literacy as a core workforce competency, integrating AI skills benchmarks into measurable skill gains, partnering with community-based organizations for contextualized training, and exploring waiver authority for AI-readiness pilot programs.
SUBJECT: Public Comment on Florida WIOA State Plan Modification, Program Years 2026-2027
Submitted by: The Scaffold Initiative | thescaffoldinitiative.org | outreach@thescaffoldinitiative.org
Submitted to: CareerSource Florida / Florida Department of Commerce
Date: April 3, 2026
The Scaffold Initiative is a 501(c)(4) social welfare organization incorporated in Wyoming and operating nationally, with organizational leadership based in Memphis, Tennessee and a mission focused on expanding AI and digital workforce readiness for workers facing displacement or barriers to economic mobility. Our Executive Director, Ricky Tucker, is a workforce development practitioner with over 40 years of experience in adult education, business coaching, and career development, based in Memphis, Tennessee.
We commend Florida for undertaking the PY 2026-2027 State Plan modification and write to offer substantive input on the following priorities established by Training and Employment Guidance Letters 07-25 and 05-25. Florida's decision to engage in this modification cycle reflects a commitment to aligning its workforce system with evolving federal priorities, and we appreciate the opportunity to contribute to that process.
TEGL 07-25's Pillar V explicitly calls for states to prioritize "AI literacy and skills development across the public workforce system" and create "new models of workforce innovation built to match the speed and scale of AI-driven economic transformation." We urge Florida to:
Florida's economic scale and diversity make AI literacy investment both urgent and high-impact. The state's tourism and hospitality sector — which employs hundreds of thousands of workers across the state — is rapidly integrating AI into customer service, revenue management, operations, and visitor experience systems, creating a workforce that needs new competencies to remain employable in the industry that defines much of Florida's economy. The Space Coast's aerospace and defense corridor, anchored by Kennedy Space Center and a growing commercial launch industry, is deploying AI across mission planning, manufacturing, and logistics. South Florida's financial services sector and the state's growing technology corridor are adopting AI at pace with national trends. Florida's agricultural sector — including citrus, specialty crops, and aquaculture — is encountering AI-driven precision farming tools, automated harvesting, and supply chain optimization. A deliberate AI skills strategy within the WIOA plan would serve the state's enormous and diverse workforce, ensuring that workers in tourism, aerospace, agriculture, and healthcare have structured pathways to the AI competencies their industries increasingly require.
TEGL 07-25's Pillar II calls for states to integrate "AI-powered tools including comprehensive talent marketplaces composed of comprehensive learner records or learning and employment records solutions, credential registries, and skills-based job description generators." We recommend:
Under TEGL 05-25's waiver framework, Florida has authority to request waivers that enable innovative AI-readiness pilot programs. We specifically recommend Florida explore a waiver allowing On-the-Job Training (OJT) reimbursement to extend to AI skills roles in non-traditional settings, consistent with TEGL 05-25's encouragement to raise OJT reimbursement caps and expand incumbent worker training.
The Scaffold Initiative is developing capacity to serve as a community partner in implementing AI and digital literacy training integrated with public workforce systems nationwide. As a nationally operating organization, we are committed to building capacity in service of Florida's workforce goals. We offer:
We welcome the opportunity to engage further with CareerSource Florida.
Respectfully submitted,
Ricky Tucker
Executive Director, The Scaffold Initiative
outreach@thescaffoldinitiative.org
thescaffoldinitiative.org
Three priority recommendations: designating AI literacy as a core competency eligible for ITA funding, including AI/digital skills in measurable skill gains reporting, and partnering with community-based organizations that provide contextualized AI training for adult learners, dislocated workers, and youth.
Florida faces AI-driven transformation across multiple major sectors simultaneously. Tourism and hospitality — employing hundreds of thousands — is integrating AI into customer service and revenue management. The Space Coast's aerospace corridor deploys AI across mission planning and manufacturing. Agriculture is adopting precision farming and automated harvesting. South Florida's financial services sector is adopting AI at pace with national trends. This breadth means AI literacy is not a niche need but a statewide workforce priority.
Under TEGL 05-25, Florida could request waivers allowing On-the-Job Training reimbursement to extend to AI skills roles in non-traditional settings, raise OJT reimbursement caps, and expand incumbent worker training programs.
Curriculum and facilitation for AI/digital skills training aligned to employer demand, train-the-trainer capacity for CareerSource center staff, and partnership development with regional employers to validate competencies and create hiring pipelines.