The Scaffold Initiative submitted this comment on Rhode Island's WIOA State Plan Modification for Program Years 2026-2027. Rhode Island's compact geography and concentrated economy create a unique opportunity for statewide AI literacy adoption — with defense, advanced manufacturing, and healthcare sectors all undergoing significant AI integration. 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 — Rhode Island WIOA State Plan Modification, Program Years 2026-2027
Submitted by: The Scaffold Initiative | thescaffoldinitiative.org | outreach@thescaffoldinitiative.org
Submitted to: Governor's Workforce Board of Rhode Island
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 Rhode Island 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. Rhode Island'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 Rhode Island to:
Rhode Island's compact geography and concentrated economy create a unique opportunity for statewide AI literacy adoption. The state's workforce is anchored in healthcare, defense, advanced manufacturing, and higher education — all sectors undergoing significant AI integration. Naval Station Newport and the defense technology corridor are deploying AI across maintenance, logistics, and cybersecurity functions. Rhode Island's advanced manufacturing base, particularly in jewelry, specialty metals, and marine fabrication, is encountering AI-driven design and production tools. And the state's healthcare sector — the largest employer — is integrating AI into clinical decision support, administrative operations, and population health management. Rhode Island's small scale is an advantage here: a statewide AI skills strategy within the WIOA plan could reach a meaningful share of the workforce system relatively quickly, creating a model for how smaller states operationalize TEGL 07-25's AI literacy mandate.
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, Rhode Island has authority to request waivers that enable innovative AI-readiness pilot programs. We specifically recommend Rhode Island 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 Rhode Island's workforce goals. We offer:
We welcome the opportunity to engage further with the Governor's Workforce Board of Rhode Island.
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.
Rhode Island's compact geography and concentrated economy mean a statewide AI skills strategy within the WIOA plan could reach a meaningful share of the workforce system relatively quickly. This creates a model for how smaller states operationalize TEGL 07-25's AI literacy mandate across defense, advanced manufacturing, healthcare, and higher education sectors.
Under TEGL 05-25, Rhode Island 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 netWORKri career center staff, and partnership development with regional employers to validate competencies and create hiring pipelines.