The Scaffold Initiative submitted this comment on Massachusetts' WIOA State Plan Modification for Program Years 2026-2027. Massachusetts is home to one of the world's most concentrated innovation ecosystems, yet Gateway Cities like Springfield, Brockton, and Fall River remain disconnected from the training pathways that would enable workers to participate in the AI economy. 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 Massachusetts WIOA State Plan Modification, Program Years 2026-2027
Submitted by: The Scaffold Initiative | thescaffoldinitiative.org | outreach@thescaffoldinitiative.org
Submitted to: Massachusetts State Workforce Board / Executive Office of Labor and Workforce Development
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 Massachusetts 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. Massachusetts' 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 Massachusetts to:
Massachusetts is home to one of the world's most concentrated innovation ecosystems — spanning biotech and life sciences, financial technology, robotics, and artificial intelligence research — yet the state's workforce development challenge is one of access, not proximity. Gateway Cities like Springfield, Brockton, Fall River, and Lawrence are home to workers who live within a short radius of global AI leadership but remain disconnected from the training pathways that would enable them to participate. The gap between the Greater Boston innovation corridor and the state's Gateway Cities is a workforce equity challenge that the WIOA plan is uniquely positioned to address. At the same time, Massachusetts' healthcare sector — the state's largest employer — is deploying AI across clinical, administrative, and operational functions. A deliberate AI skills strategy would ensure that workers in healthcare, manufacturing, and services sectors across the Commonwealth have structured pathways to digital fluency, rather than relying on proximity to the innovation economy to create skills transfer organically.
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, Massachusetts has authority to request waivers that enable innovative AI-readiness pilot programs. We specifically recommend Massachusetts 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 Massachusetts' workforce goals. We offer:
We welcome the opportunity to engage further with the Massachusetts State Workforce Board.
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.
Massachusetts has one of the world's most concentrated innovation ecosystems, but Gateway Cities like Springfield, Brockton, Fall River, and Lawrence remain disconnected from the training pathways that would enable workers to participate. The gap between the Greater Boston innovation corridor and these communities is a workforce equity challenge the WIOA plan is uniquely positioned to address.
Under TEGL 05-25, Massachusetts 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 MassHire Career Center staff, and partnership development with regional employers to validate competencies and create hiring pipelines.