The Scaffold Initiative submitted this comment on Wyoming's WIOA Unified State Plan Modification for Program Years 2026-2027. 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. Wyoming's economic diversification beyond its energy sector makes AI workforce development especially strategic.
SUBJECT: Public Comment on Wyoming WIOA Unified State Plan Modification, Program Years 2026-2027
Submitted by: The Scaffold Initiative | thescaffoldinitiative.org | outreach@thescaffoldinitiative.org
Submitted to: Wyoming Workforce Development Council / Wyoming Department of Workforce Services
Date: March 25, 2026
The Scaffold Initiative is a 501(c)(4) social welfare organization incorporated in Wyoming (EIN 41-4911679, WY SOS 2026-001921360) 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 Wyoming for undertaking the PY 2026-2027 Unified 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. Wyoming'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 Wyoming to:
We note that Wyoming faces a particular strategic opportunity here. As the state works to diversify its economy beyond its traditional energy sector, AI and digital skills represent a critical pathway for workforce diversification. Workers in energy, agriculture, and natural resources — industries that define Wyoming's economic identity — are increasingly encountering AI-driven tools in their daily work, from precision agriculture to automated resource extraction monitoring. Investing in AI literacy now positions Wyoming's workforce to lead in emerging industries rather than react to displacement after the fact. A deliberate AI skills strategy within the WIOA plan would complement the state's broader economic diversification goals and help ensure that Wyoming workers are competitive in a national labor market that increasingly rewards digital fluency.
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, Wyoming has authority to request waivers that enable innovative AI-readiness pilot programs. We specifically recommend Wyoming 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 Wyoming's public workforce system. As a Wyoming-incorporated organization, we are committed to building that capacity in service of the state's workforce goals. We offer:
We welcome the opportunity to engage further with Wyoming's Workforce Development Council.
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.
Wyoming is diversifying beyond its traditional energy sector. Workers in energy, agriculture, and natural resources increasingly encounter AI-driven tools in daily work — from precision agriculture to automated resource extraction monitoring. Investing in AI literacy now positions Wyoming's workforce for emerging industries rather than reacting to displacement.
Under TEGL 05-25, Wyoming 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 American Job Center staff, and partnership development with regional employers to validate competencies and create hiring pipelines.