Publications

Public comments and policy work from The Scaffold Initiative and partner organizations. All publications are freely accessible.

Implementation Guide

AI Literacy Implementation Guide for Community-Based Organizations

A practical companion to the DOL AI Literacy Framework (TEN 07-25). Covers curriculum design, workforce board partnerships, WIOA funding pathways including cohort contracting, and outcome measurement for CBOs building AI literacy programs.

April 2026
Public Comment

Comment on Virginia WIOA Combined State Plan Modification

AI workforce readiness across Virginia's 14 Local Workforce Development Areas. Recommends extending HB 310 principles, regional strategies for NOVA and Southside, and Governor's Reserve pilot programs.

April 3, 2026
Public Comment

Comment on Massachusetts WIOA State Plan Modification

AI literacy as a core workforce competency for Massachusetts' Gateway Cities and innovation corridor. Recommends MassHire staff training and OJT waiver authority for AI pilot programs.

April 3, 2026
Public Comment

Comment on Rhode Island WIOA State Plan Modification

AI workforce readiness for Rhode Island's defense, manufacturing, and healthcare sectors. Recommends netWORKri staff training and statewide AI literacy as a model for smaller states.

April 3, 2026
Public Comment

Comment on New Jersey WIOA State Plan Modification

AI workforce readiness for New Jersey's pharmaceutical, logistics, and financial services sectors. Recommends sector-specific AI training and One-Stop Career Center staff upskilling.

April 3, 2026
Public Comment

Comment on Wisconsin WIOA State Plan Modification

AI literacy for Wisconsin's manufacturing and agricultural workforce. Recommends AI skills benchmarks, Job Center staff training, and OJT waivers for production-embedded AI training.

April 3, 2026
Public Comment

Comment on Colorado WIOA State Plan Modification

AI workforce readiness across Colorado's aerospace, energy transition, and tourism sectors. Recommends Workforce Center staff training and AI pilot programs under waiver authority.

April 3, 2026
Public Comment

Comment on Florida WIOA State Plan Modification

AI workforce readiness for Florida's tourism, Space Coast aerospace, agriculture, and healthcare sectors. Recommends CareerSource staff training and competency-based AI credentials.

April 3, 2026
Public Comment

Comment on Federal Reserve Reputation Risk Rule (R-1884)

How reputation risk-driven debanking cascades to the 28 million sole proprietors who depend on fintech and AI tools for invoicing, marketing, bookkeeping, and lending.

April 1, 2026
Public Comment

Comment on DOL Independent Contractor Classification Rule

Addressing the gap in the proposed rule regarding AI's impact on worker classification. Distinguishes worker-initiated AI tool use from platform-imposed algorithmic management.

April 1, 2026
Public Comment

Comment on HUD Work Requirements and Term Limits Rule

Recommending AI literacy training as a qualifying work activity and requiring bias audits for automated systems used to monitor compliance or determine exemptions.

April 1, 2026
Public Comment

Comment on Wyoming WIOA State Plan Modification

Recommending AI literacy as a core workforce competency, AI skills benchmarks in measurable skill gains, and community-based organization partnerships for contextualized training.

March 25, 2026
Public Comment

Comment on NCUA GENIUS Act: AI in Credit Union Stablecoin Operations

Proposing behavioral safety credentialing as a proportionate compliance mechanism for credit unions dependent on third-party AI vendors for stablecoin operations.

March 10, 2026