WIOA Transparency Audit

In spring 2026, we conducted the first comprehensive audit of WIOA public comment periods across all 50 states and DC. No centralized federal record of these windows exists, so we built one. This is what we found.

51
Jurisdictions Researched
22
Comments Filed
8
Invisible Processes
9 days
Shortest Window Found

About This Research

Under the Workforce Innovation and Opportunity Act (WIOA), every state must submit a four-year plan to the U.S. Department of Labor and modify it at the two-year mark. Federal regulation 20 CFR § 676.130(d) requires a public comment period before each submission. These comment periods are how the public participates in shaping workforce policy.

The problem: there is no centralized place to find them. WorkforceGPS does not aggregate comment windows. DOL does not publish a schedule. And unlike local plans (which federal regulation caps at 30 days under 20 CFR § 679.550), state-level plans have no minimum comment period at all.

During the PY 2026–2027 modification cycle, we researched every state's process. The data below is what we found.

Key Findings

  • Only 6 of 36 researched states had comment periods discoverable through standard web search on the day they were open.
  • Comment window lengths vary wildly. New Mexico ran 9 days. Kansas closed at noon on a Friday. Iowa and Nebraska closed before the original federal deadline.
  • 8 states have no publicly findable evidence of a modification or comment period. Either the process happened invisibly or was never conducted.
  • No standardization exists for comment period length, submission format, or public notice requirements across states.
  • The federal regulatory gap is structural. 20 CFR § 676.130(d) mandates public comment for state plans but sets no minimum duration, while 20 CFR § 679.550(b)(3) requires 30 days for local plans.
State Status Plan Type Comment Period Contact Notes
Alabama No Public Data — — Dept of Commerce, Workforce Dev Division No modification or comment period found during research period.
Alaska No Public Data — — DOLWD, Alaska Workforce Investment Board No modification or comment period found in research.
Arizona No Public Data — — DES, ARIZONA@WORK Waivers guide references plan modification but no public dates. Prior cycle: only 14-day window.
Arkansas Comment Filed Combined Submitted Apr 4 [email protected] Waivers in 30-day comment. Seeking to consolidate ALL local boards into single state entity (target Jul 2027).
California Documented Combined Closed Feb 11, 2026 [email protected] In federal review.
Colorado Comment Filed — Submitted Apr 3 [email protected]
Connecticut Documented — Closed before Mar 3, 2026 Office of Workforce Strategy Submitted Mar 3 under original deadline.
Delaware Comment Filed Unified Submitted Apr 4 [email protected] Full draft + 14 appendices posted.
District of Columbia Comment Filed Unified Submitted Apr 4 [email protected] Single workforce area.
Florida Comment Filed — Submitted Apr 3 [email protected]
Georgia No Public Data — — TCSG, WorkSource Georgia No 2026 modification found during research period.
Hawaii Documented — Closed ~Mar 23, 2026 Workforce Development Council Ratified at Apr 2 board meeting.
Idaho Documented — Feb 9 – Mar 11, 2026 [email protected] Single-area state, well-documented.
Illinois Documented — ~Jan – Mar 2026 DCEO / Illinois WorkNet Phased engagement: webinars + survey.
Indiana Documented — Feb 18 – Mar 20, 2026 [email protected] Strategic region realignment underway.
Iowa Documented — Closed Feb 26, 2026 comment.iowa.gov Excellent centralized portal. Closed before original federal deadline.
Kansas Documented — Closed Apr 3 at Noon CDT [email protected]
Kentucky Comment Filed — Submitted Mar 25 Web portal (secure.kentucky.gov) Confirmation received.
Louisiana No Public Data — — Louisiana Workforce Commission No comment announcement found.
Maine No Public Data — — [email protected] Historical pattern: very short windows (2 weeks). May have closed quietly.
Maryland No Public Data Combined — Dept of Labor, GWDB Combined plan 2024-2028. No 2026 modification visible during research period.
Massachusetts Comment Filed — Submitted Apr 3 [email protected]
Michigan Documented Combined ~Feb 6 – Mar 8, 2026 LEO Bureau of Workforce Dev 454-page draft.
Minnesota Documented Combined Feb 17 – Mar 16, 2026 [email protected]
Mississippi Comment Filed — Submitted Mar 25 [email protected]
Missouri Documented — Unknown [email protected] State-level process opaque. Local boards posted separately.
Montana Comment Filed Converting to Combined Submitted Apr 4 Online at swib.mt.gov Adding Perkins V first time. HB 823, "406 JOBS" initiative. Email + online portal submission.
Nebraska Documented — Jan 30 – Mar 2, 2026 [email protected] Closed before original federal deadline.
Nevada Comment Filed — Submitted Mar 25 [email protected]
New Hampshire Comment Filed — Submitted Mar 19 Keith Ammon (House Majority Floor Leader) Keith Ammon responded, reviewing.
New Jersey Comment Filed — Submitted Apr 3 [email protected]
New Mexico Documented — Mar 20 – Mar 29, 2026 [email protected] Only 9 days. Transparency concern.
New York Documented — Feb 5 – Mar 8, 2026 [email protected] Acknowledged commenters by name.
North Carolina Documented — Likely closed pre-March 2026 NC Commerce State plan submitted pre-March 2026.
North Dakota Documented — Feb 17 – Mar 16, 2026 [email protected] Well-documented.
Ohio Documented Combined Closed Feb 22, 2026 ODJFS Office of Workforce Dev Person-centered model.
Oklahoma Comment Filed — Submitted Apr 1 Web form (oklahoma.gov)
Oregon Comment Filed — Submitted Apr 1 [email protected]
Pennsylvania Comment Filed — Submitted Mar 25 [email protected] Auto-reply confirmed. Window closed Apr 1.
Rhode Island Comment Filed — Submitted Apr 3 [email protected]
South Carolina No Public Data — — DEW / SC Works Draft posted but comment dates not found.
South Dakota Documented — Closed Jan 16, 2026 DLR Workforce Services Very early (started Dec 2025).
Tennessee Comment Filed — Submitted Mar 25 [email protected]
Texas Documented — Likely closed late 2025 / early 2026 Texas Workforce Commission Commission-approved. Exact dates unclear.
Utah Documented — Closed ~Jan 2026 Dept of Workforce Services Virtual town hall Jan 14, 2026.
Vermont Documented — Closed Feb 26, 2026 [email protected] Best-documented process in research.
Virginia Comment Filed — Submitted Mar 25 + Apr 3 [email protected] Hobie Lehman (Senate Committee) forwarded to committee.
Washington Comment Filed — Submitted Mar 25 [email protected]
West Virginia Comment Filed Combined Submitted Apr 4 [email protected] SB 490 (Workforce Pell Grants) effective Jul 1, 2026. Jobs and Hope integration recommended.
Wisconsin Comment Filed — Submitted Apr 3 [email protected]
Wyoming Comment Filed — Submitted Mar 25 [email protected]

Data archived: April 2026 · Research conducted December 2025 – April 2026

Methodology & Archival Note

This audit was conducted between December 2025 and April 2026 using parallel research across all 50 states and DC. Sources included state workforce agency websites, DOL WorkforceGPS, public meeting minutes, state register notices, and direct agency correspondence.

"Comment Filed" means The Scaffold Initiative submitted a formal public comment on the state's PY 2026-2027 WIOA plan modification. "Documented" means the state's comment period was identified through research but The Scaffold Initiative did not submit a comment. "No Public Data" means no publicly findable evidence of a modification draft or comment period was located through standard research methods.

This data represents a point-in-time snapshot of the PY 2026-2027 modification cycle. The PY 2026-2027 modifications took effect July 1, 2026. Federal submissions were due by April 30, 2026 (extended from March 3, 2026 via TEGL 07-25).

For questions about this research, contact [email protected].

Looking Ahead: PY 2028–2031

The next full WIOA planning cycle covers Program Years 2028–2031. Based on historical patterns, federal planning guidance (TEGL) is expected in late 2027, with state public comment periods opening in January–February 2028.

If WIOA reauthorization (H.R. 8210, “A Stronger Workforce for America Act of 2026”) advances, the next cycle's plans could operate under substantially different rules, including consolidated five-year grants and expanded gubernatorial set-asides that would increase the importance of state-level public comment.

The transparency gaps documented in this audit remain unaddressed. No federal standardization of state comment periods has been enacted or proposed.