The Scaffold Initiative submitted this comment on Wisconsin's WIOA State Plan Modification for Program Years 2026-2027. Wisconsin's manufacturing-intensive economy — spanning paper products, machinery, food processing, medical devices, and advanced manufacturing — faces a persistent skills gap as AI-driven automation reshapes production floors. The state's dairy and agricultural sector is simultaneously adopting precision agriculture and AI-driven herd management systems. 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 that complement Wisconsin's strong technical college system.
SUBJECT: Public Comment on Wisconsin WIOA State Plan Modification, Program Years 2026-2027
Submitted by: The Scaffold Initiative | thescaffoldinitiative.org | outreach@thescaffoldinitiative.org
Submitted to: Wisconsin Department of 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 Wisconsin 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. Wisconsin'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 Wisconsin to:
Wisconsin's manufacturing-intensive economy makes AI literacy a particularly urgent workforce priority. The state's industrial base — spanning paper products, machinery, food processing, medical devices, and advanced manufacturing — is integrating AI-driven automation, predictive maintenance, and quality control systems at an accelerating pace. Wisconsin manufacturers face a persistent skills gap: even as automation reshapes production floors, employers struggle to find workers with the digital competencies needed to operate, maintain, and collaborate with AI-augmented systems. At the same time, Wisconsin's dairy and agricultural sector — a defining feature of the state's economic identity — is adopting precision agriculture, AI-driven herd management, and automated milking systems. A deliberate AI skills strategy within the WIOA plan would directly address the state's most pressing workforce challenge: ensuring that Wisconsin's manufacturing and agricultural workers develop the competencies to work alongside AI tools rather than be displaced by them. This investment would complement the state's strong technical college system and create a more complete pipeline from training to employment.
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, Wisconsin has authority to request waivers that enable innovative AI-readiness pilot programs. We specifically recommend Wisconsin 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. Given the depth of Wisconsin's manufacturing sector, such a waiver could enable structured AI skills training embedded in production environments — allowing workers to develop digital competencies on the job rather than pausing employment for classroom-based 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 Wisconsin's workforce goals. We offer:
We welcome the opportunity to engage further with the Wisconsin Department of Workforce Development.
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.
Wisconsin's industrial base — spanning paper products, machinery, food processing, medical devices, and advanced manufacturing — is integrating AI-driven automation, predictive maintenance, and quality control systems at an accelerating pace. Employers face a persistent skills gap, struggling to find workers with the digital competencies needed to operate and collaborate with AI-augmented systems. The state's dairy and agricultural sector is simultaneously adopting precision agriculture and AI-driven herd management.
Under TEGL 05-25, Wisconsin 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. Given the depth of Wisconsin's manufacturing sector, such a waiver could enable structured AI skills training embedded in production environments.
Curriculum and facilitation for AI/digital skills training aligned to employer demand, train-the-trainer capacity for Job Center of Wisconsin staff, and partnership development with regional employers to validate competencies and create hiring pipelines.