The Scaffold Initiative submitted this comment on New Jersey's WIOA State Plan Modification for Program Years 2026-2027. New Jersey's economy is particularly exposed to AI-driven transformation — the state is the nation's pharmaceutical capital, home to Port Newark-Elizabeth (one of the busiest container ports in the country), and a financial services hub deploying AI across trading, risk, and compliance. We recommend designating AI literacy as a core workforce competency, integrating sector-specific AI skills benchmarks into measurable skill gains, partnering with community-based organizations, and exploring waiver authority for AI-readiness pilot programs.
SUBJECT: WIOA State Plan Modification PY 2026-2027
Submitted by: The Scaffold Initiative | thescaffoldinitiative.org | outreach@thescaffoldinitiative.org
Submitted to: New Jersey State Employment and Training Commission (SETC) / New Jersey Department 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 New Jersey 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. New Jersey'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 New Jersey to:
New Jersey's economy is particularly exposed to AI-driven transformation across multiple sectors. The state is the nation's pharmaceutical capital, with major research and manufacturing operations integrating AI into drug discovery, clinical trials, quality control, and regulatory compliance. New Jersey's logistics and transportation sector — driven by Port Newark-Elizabeth, one of the nation's busiest container ports, and the state's position as the Northeast's distribution corridor — is deploying AI across warehousing automation, fleet routing, and supply chain optimization at scale. Financial services, centered in the northern part of the state, are rapidly adopting AI for trading, risk assessment, and compliance. A deliberate AI skills strategy within the WIOA plan would equip workers across all three of these high-impact sectors, ensuring that New Jersey's workforce system prepares participants for the specific AI tools they will encounter in the state's dominant industries rather than offering generic digital literacy alone.
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, New Jersey has authority to request waivers that enable innovative AI-readiness pilot programs. We specifically recommend New Jersey 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 New Jersey's workforce goals. We offer:
We welcome the opportunity to engage further with the State Employment and Training Commission.
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.
New Jersey is the nation's pharmaceutical capital with AI integration across drug discovery, clinical trials, and regulatory compliance. Port Newark-Elizabeth and the state's logistics corridor are deploying AI in warehousing automation, fleet routing, and supply chain optimization. Financial services in northern New Jersey are rapidly adopting AI for trading, risk assessment, and compliance. All three sectors face simultaneous AI-driven transformation.
Under TEGL 05-25, New Jersey 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 One-Stop Career Center staff, and partnership development with regional employers to validate competencies and create hiring pipelines.