I request the law be amended to include NCCT certification.  My TS-C credential is approved by the same organization that the CST is, (the NCCA), so this is absolute discrimination against this credential, and anyone who has earned it. This law, as it is written, allows only 1 of the 2 equally accredited and legitimate certifications to hold employment as a surgical technologist in your state. This has a direct negative impact on the citizens of Virginia, its businesses and the safety of its patients.  Specifically, it affects the surgical technology workforce by limiting recruitment opportunities for employers and denying qualified surgical techs the right to practice and achieve gainful employment in their chosen field.  This will also limit the public access to safe, surgical care by further exacerbating a healthcare workforce shortage.  Schools that offer the TS-C certification, that cannot meet the imposing requirements of becoming a degree bearing program, will be forced to close their doors.  Experienced TS-Cs, like myself, will not be able to consider Virginia when relocating - because they will not be able to work in your state.  I ask you to please.  Take this opportunity to reconsider allowing BOTH NCCA accredited certification into Virginia.  There are TWO, and right now, you only are allowing ONE.  This will help your hospitals, your patients, your students and the business of education in Virginia to not only get by, but to flourish.  Thank you for your time, and your consideration on this important matter. 

I am an NBSTSA certified surgical technologist, but strongly feel like both the NBSTSA and NCCT certification for surgical technologists should be allowed to practice in every single state. NCCT school programs teach the EXACT same content that an NBSTSA program would teach. It’s absurd that AST has lobbied for states to accept NBSTSA only because that’s what makes the AST money. Allowing only NBSTSA certified surgical technologists to practice is detrimental to patients, healthcare facilities, and in the long run, the economy.  Please reconsider this bill. I have plenty of experience with both entities and would be more than happy to answer and further questions regarding the issues at hand. 

This is ridiculous not to include NCCT/TS-C to register in  Virginia . I have schooled and trained as much as a CST and have same abilities and much more. To deny my right to make a living financially for my family as a TS-C  is a denial of basic human rights!!!! this is obsured  to deny me and others to do what they have trained to do!  I pay taxes in this state and because I chose Ncct over CSt is awful. Shame on you to deny someone to make a living!!!  How about not credentialing DO because they went the route of doctors of osteopathy and not MD’s.  

sincerely

concerned person who like to make a living as a TS-C 

I have been a TS-C for over 10 years, I received my certificates from NCCT. Before that 

I had on the job training for another 10 years. To think that I couldn’t continue to work as a

a surgical technologist in this state is terrible. It is hard enough to find people to work in this profession. My credentials are from the same organization that is CST.  I am asked to precept the new CST students that come to my place of work. This is not fair.  Please reconsider allowing NCCT surgical technologist to get certified in VA and let us continue taking the best care of our patients that we can. Thank you for you time 

AMEND 18VAC85-160-51 B.1. to include NCCT  

To whom it may concern,

I graduated from a Surgical Technology program in 1997. I joined the AST who now works closely with NBSTA. In 2016 I was informed about the change from VA notice of becoming a member of the board of Medicine for my practice. Which I am a member of.  I have traveled the country as a Traveling Surgical Technologist. Coming across many years of experiences in Surgical Technology. I have trained CST to scrub in surgery. I feel the push to get everyone on board is essential. But , not at the cost of experienced staff who have paved the way! AORN stood beside their fellow diploma nurses at a time when there job was losing accreditation. The students like myself who attended a Surgical Technology program graduated proudly with knowledge to pave way for the next generation. We should be grandfathered in with same intent as the nurses who led the community before taking the nclex was the only excepted license to become a nurse. More importantly, the patient deserve skilled competent staff working along side their Surgeons. 

I see how this works.  During covid I was burned out as TS-C in surgery, but I pushed through to help our patients.. instead of being treated equal your going to pull my credentials away and take my job.  You realize the staffing crisis your going to create and jobs you will be taking from hard working individuals that fundamentally stood up to covid for this county to take care of our sick!!!!  This is perfect thanks Virginia for standing by all the techs that are with NCct theta stood buy our country 

I am concerned about potential changes to certification and regulation of surgical technicians. I am a plastic surgeon in Charlottesville, Virginia. I have been in practice for 24 years. During that time I have had wonderful surgical technicians that have had a varied background and training history. Some were trained on the job, some went through more formal ST programs, and of course an increasing few started as LPN/RNs. I have found that  proficiency at their job is less dependent on the initials after their name, and more dependent on their ability to understand the surgical process and anticipate the needs of the surgical team. Some go above and beyond their job description with help to the entire team. In my practice I have personally employed two surgical technicians that would go to the operating room with me and were individually employed by my, or employed by the hospital/surgery center in which I worked (as I am now employed). Both of these surgical technologists would no longer be able to certify under the proposed change. One in particular is a fantastic surgical tech that has gone on to train in additional first assisting and has been my "right hand"  in the OR. To lose such a valuable employee is a detriment to our community, particularly in the current hospital environment in which we are already severely short staffed. This particular pathway tends to be older techs so we would be selecting out the techs that have maturity, experience, and strong work ethic for younger, less experienced technologists. I am always willing to have students and new techs, but it does impact my surgical experience. Having reliable experienced techs in my cases is safer, and more efficient. To eliminate these through a random regulatory amendment without scientific backing is wrong. They should be allowed to continue to recertify and provide the same quality assistance they have been providing. Thank you for your time. 

To whom it my concern,

 I’m writing you as a NCCT Surgical Technician. I went to a vocational school in Fl. In the early 90’s, back in those days being certified was not required or there was wasn’t any incentive to become certified.After working at the same hospital  for over 24 years I decided to move to another state at this time most hospitals preferred certification. I decided to call AST to find out bout how to go about and get my certification, I was told the would not let me take the test unless I retook the surgical technologist schooling, obviously I wasn’t going back to school for two years to learn something I’ve been doing for 24 years. In my research I found NCCT, I told them my situation and told them all the years I’ve been a surgical tech and the set me up with taking the test. I ordered some studying books and after two months I took the test I was so nervous, the test was hard but thankfully I passed. I was able to move to TN and get hired as a certified surgical tech. Sense then I moved to VA. To work in a level 1 trauma hospital and they also recognize NCCT certification. I hope you will consider recognizing NCCT, I have to do 14 hours of continuing education every year. Without NCCT I wouldn’t have been able to do the job I love to do. Thank you for your time, Frank Magnes

I have been a Certified Surgical Technologist for 24 years and received my licensure with the VA Board of Medicine back in 2021. I am appalled to find out that might not be good enough to continue practicing. Receiving a certification through another governing body will  not change the way I practice. I am unclear if this means completing another course or if I just need to sign up with the other certification body. I feel that my tenure justifies a grandfather in reason, as it is too late in the game to be deciding these changes. This decision should be considered for new graduates moving forward!

Wendi Straub

Good evening, I am a Certified Surgical Technologist. I currently hold a license from NCCT. I have 19 years experience as a surgical Technologist. I have been certified through NCCT since 2009. I currently work at Pediatric Specialist of Virginia in Fairfax Virginia. I believe having a license from NCCT is just as great and rewarding as AST license. I work hard and help assist in some surgical procedures. I also am aware of my scope of practice when it comes to being an assist in the surgical Operating room. We should be recognized and acknowledged that we can scrub any surgical procedures when it come to our patients and acknowledge the safety of our patients. I would love to keep my license from NCCT. It’s a great educational, certified and utilization program. That helps worker like myself stay licensed and go travel anywhere across the United States of America as well as international. We are the first responders and the frontliner’s in healthcare. We are much needed in hospital and surgical centers as well. Please take us into consideration when it comes to being a certified Surgical Technologist, from NCCT. We are the Techs In Surgeries. Thank you, Tabitha B. 

I have been a surgical tech for 15years.  I have played a major role in surgical care at my facility, I am a NCCT TS-c and have never been discriminated against as such.  I hope you guys reconsider to include as as equals and make this fair.  I am very disappointed .  I know in my heart I have made a difference in my career which is disheartening to think all I have done , all of us has been for nothing with no recognition what so ever

DAN

I agree with everyone on this forum..   please reconsider us as equals

I graduated at the beginning of the pandemic(2020). I went on to pass my ncct exam successfully and I did not go right into work because of the pandemic. But I maintained my certification(TS-C) and now I am working for Bon Secour in the roll of surgical tech as of June. I feel that yes anyone who have gotten certified through NCCT is operating in the same capacity as a CST. Yes they are 2 different titles and exams but they are the same roles and because we have taken the necessary time to complete and pass the exams. We deserve the same opportunities.

AMEND 18VAC85-160-51 B.1. to include NCCT 

Karen D. Richards

Been doing this a long time as a NccT certified TS-c. And I concur  This is outright discrimination against my title and job   ,  please amend to allow us to keep practicing 

thanks 

james

Please reconsider allowing NCCT to register in Virginia 

david

Please reconsider to include!!!  We are valuable assets to healthcare community!!

nate

AMEND 18VAC85-160-51 B.1. to include NCCT!!

The TS-C and the CST are both NCCA accredited certifications and both should be eligible to work in Virginia!

To whom it may concern,

This is really unacceptable, and unfair to all the surgical technologist who have gotten certified with NCCT. Many of those didn’t even have the option to do it through NBSTA as I myself who didn’t have the option, I did it through my highschool with zero experience in the medical unit which I’m extremely grateful NCCT and my school work together. NCCT is associated with my school and it has helped me to where I am now. Those who are certified through NCCT have the same role as those who are certified NBSTA. There is no difference between the two roles they are equally accredited by NCCA and they both work the same. Changing it now will bring a negative impact to the healthcare society and it will deny qualified surgical technologist who have been doing for so many years and had made this role their passion into helping patients. I hope this can make a change and help you realize the importance of surgical technologist are in the healthcare world and how they make a change in this society. Different certification but same way of doing work as a certified surgical technologist. 

thank you,

Zandy Mazariegos

This is unacceptable to not allow NCCT surgical techs to register in the state!!!

please reconsider, negative impacts across the board in healthcare and my own personal life to provide for my family.   I want to keep working as a proud surgical technologist and please allow me to

joe

There are two national certifying examinations for Surgical Technologists that are both accredited by National Commission for Certifying Agencies (NCCA).

The two nationally recognized, Surgical Technology certification exams are offered by the National Center for Competency Testing (NCCT) and the National Board of Surgical Technology and Surgical Assisting (NBSTSA). 

However, section 51 of this chapter only allows or recognizes a certification from one of the two nationally accredited certifying bodies.

This unnecessarily limits by half, both the employment opportunities and employer recruitment abilities for surgical technologists within the Commonwealth of Virginia. 

Both testing entities (NCCT & NBSTSA) had to achieve the same benchmarks and requirements to obtain National accreditation for their Certified Surgical Technologist examination; therefore section 51.B should recognize either certification as the requirement to become a registered surgical technologist in Virginia and not limit to only 1 of these 2 equivalent exams. 

Section 51.B.1 should read as follows: 

Successful completion of an accredited surgical technologist training program and or a current credential as a certified surgical technologist from the National Center for Competency Testing (NCCT) or the National Board of Surgical Technology and Surgical Assisting (NBSTSA) or it's successors; or  

Please amend this regulation to improve the employment opportunities for NCCT Certified Surgical Technologists in Virginia and to not contribute to the increasing healthcare provider shortages by limiting employers from being able to hire NCCT Certified Surgical Technologists, like me, in Virginia.

Please give strong consideration to my request for the language of this regulation to be amended allowing more fair and equitable opportunities for employees and employers of Surgical Technologists in Virginia. 

I am a Tech in Surgery - Certified  with more than 37 years of surgical experience, that currently practices in a level one trauma center in Virginia. How this regulation is currently written, I am not eligible to register with the Virginia Board of Medicine as a Certified Surgical Technologist. There are many more like me all across the Commonwealth that have been or will continue to be negatively affected by this regulation if unchanged. 

Thank you for your consideration.        

I support expanding the accepted credentialing of surgical technologists to include those trained and credentialed by either of the nationally recognized organizations.  This would include surgical technologists who have met the requirements of the National Center for Competency Testing.

This would allow more of these experienced, available and needed professionals to register and help the citizens of Virginia.

There are two national certifying examinations for Surgical Technologists that are both accredited by the National Commission for Certifying Agencies (NCCA). NCCT is associated with my school, and I am extremely grateful for that relationship. Those of who are certified though the NCCT have the same role as those who are certified with the NBSTA. There is no difference between the two roles, they are equally accredited by the NCCA, and they both work the same. Allowing only the NBSTSA certified surgical technologists to practice is detrimental to patients, healthcare facilities and overall, the economy of Virginia. As a student who has almost completed his program, I would have to wait months after I graduate to sit for the CST exam, instead of being able to take the NCCT exam and start my career immediately as a Surgical technologist as planned.

This regulation unnecessarily limits employment opportunities for NCCT-certified techs, as well as limits potential available employees in an already understaffed field, ultimately hurting and burdening hospitals and patients. Please consider making this change!!

I am not only surgical tech but an educator as well. While I hold the CST credentials I feel that the NCCT credentials hold just as much value to potential techs in the field. I have used both exams for my students and I have them succeed and be great techs. The CST being the only credentials comes down to Pride and not being educated on the value of the NCCT. Please consider reviewing this legislation and including NCCT. There is a National shortage on surgical techs and this could help ease some of those shortages by offering more ways to get certified. 

As an operating room nurse at VCU Health for the past 25 years, I really do not understand the need or reasoning for any changes to the current law related to CST certification. I feel that this is yet another way for another certification body to collect fees and impose their regulations unnecessarily. If this law is passed, it will negatively affect several very good & very experienced operating room techs. We cannot do our jobs without them on the team. In this time of extreme staffing shortages, I would suggest not placing any more obstacles in the way of people doing their job. "If it ain't broke......."   Thank you for listening, Lou Alexander, RN CNOR

AORN is the national membership organization for perioperative registered nurses. Perioperative nurses work in the operating room as RN circulators, in the scrub role, and as first assistants at surgery. Perioperative nurses work closely with surgical technologists working in the scrub role as the scrub role is a delegated nursing function. AORN has long supported specialty certification for surgical technologists without endorsement of any particular certifying body.

AORN's Position Statement on Orientation of the Registered Nurse and Surgical Technologist confirms AORN's belief that allied health care providers including surgical technologists should be graduates of accredited education programs or should successfully complete a specialty certification process. Recognizing only one certifying body (NBSTSA) limits employment and recruitment opportunities for hospitals and surgery centers without any corresponding patient safety or public health benefit. We urge the board to recognize additional certifications equivalent to NBSTSA in registering surgical technologists in the state.

Thank you for your consideration.

I recommend this regulation be amended to include both national certifications for Surgical Technologist and not just certification through NBSTSA.  I agree that national certification should be a requirement to register and practice as a Surgical Technologist; however, I do not support limiting certification recognition to only one of the two national certifying bodies.  

I have been in healthcare for over twenty five years and spent twenty three of those as a Certified Surgical Technologist.  I have practiced in multiple states and disciplines of healthcare.  I have been witness to a lot of changes throughout the years, but today's healthcare staffing shortage is at an all time low.  During this national clinical staffing crisis regulations should support our healthcare systems and not contributing to the shortage by unnecessarily limiting skilled and credentialed resources from employment opportunities.    

Without amending this regulation to support both national certifying exams for Surgical Technologist, the state of Virginia is limiting job opportunities and recruitment ability therefore negatively affecting the healthcare system in the Commonwealth of Virginia. 

NCCT should be included not just NBSTSA. 

I am a current surgical tech student. As an upcoming graduate, I would personally like to see the NCCT as well as the NBSTA available as they both hold equal value. Limiting surge techs to one certification would limit opportunities.

As a Director of Surgical Services, I have worked with many surgical techs throughout the years.  I have seen no difference in competency between those certified via the NCCT or NBSTSA.  Students should have a choice through with agency they use to become certified.  This promotes competition between the agencies and ensures they both participate in continuous performance improvement.  Thank you for this consideration.

Amend to allow other National Certifications

There are a limited number of schools for us here is va i have only seen the ncct test begin offered please consider most of the older and new grads including myself .

As the law is currently written, allowing only 1 of the 2 equally accredited and legitimate certifications, has a negative impact on many citizens of the Commonwealth of Virginia, businesses and individuals.  Specifically, it affects the Surgical Technologist workforce by limiting recruitment opportunities for employers and denying qualified surgical techs the right to practice and achieve gainful employment in their chosen field.  This would also limit the public access to safe surgical care by further exacerbating a healthcare workforce shortage. Surgical technologists certified by NCCT work side by side performing the same job duties as NBSTSA certified surgical technologists. 

Similar legislation was passed in 2015 in Oregon, where NBSTA and the Oregon chapter of the Association of Surgical Technologists promised there would be more graduates in the future and no shortages would occur. A significant shortage occurred, so much that we passed new legislation this last session to rectify and allowing NCCT to be an option alongside NBSTA. NBSTSA and OAST were very challenging to work with to find any solution and fought the updated legislation. I highly recommend addressing this issue now and provide adequate bandwidth by having NCCT alongside NBSTA and CAAHEP for providers.

I have been in this profession for 24 years and have been certified through NCCT for many years. I do not have the time nor money to take another course associated with my career as it would not change the way I practice. I am asking that you please grandfather in those that are already certified and licensed in this new bill trying to be passed.

Thank you,

Wendi Straub

I would greatly appreciate if you could amend to include NCCT.  We learn the same exact material as those who are credentialed under NBSTSA. Every O.R in VA and across the nation is experiencing a shortage in staff, surgical techs included. I feel like this would greatly impact our already small numbers and most definitely be a hindrance to our patient population. Thank you for your time and consideration in the matter.

Current law, as written, prohibits anyone that holds a "Tech in Surgery-Certified (TS-C)" by National Center for Competency Testing (NCCT) from being registered as a Certified Surgical Technologist with the Virginia Board of Medicine. NCCT is a nationally recognized credentialing organization with rigor similar to that of other certifying bodies. Current legislation limits employment opportunities for citizens of the Commonwealth and recruitment opportunities for our struggling healthcare systems.

We ask that consideration be made to allow NCCT-Tech in Surg Certification exam to be an available option for Surgical Tech graduates.  Chester Career College graduates are equally trained and qualified to work as Surgical Technologist as evidenced by the many graduates who took the NCCT certification and are already employed in many local ORs.  There is no evidence in considering their employability to be different than any other techs certified by NBSTSA.  Our graduates are employed at several local and out of state hospitals working alongside other NBSTSA certified Surgical Technologists.  This law change had a major impact on graduates of the college in that they have been left to feel that their education was inferior to other colleges when in fact they have had the same level of training from qualified industry professionals who are also certified; some by NCCT and others by NBSTSA.  Both NCCT and NBSTSA are accredited by the same accrediting body (NCCA) and must meet the same requirements for their accreditation.  One organization should not have the monopoly of being the only available test if they are equally accredited.  Patients in receiving surgery do not ask nor are they made aware of an ST’s certification; however, we all agree that we want the best professionals in the ORs who are accountable, well trained, and qualified.  This law change could potentially have many negative affects upon our state and other states where graduates may choose to live in a time where we need these trained individuals the most.   We should not want to limit available employees to the hospitals at this time nor should we want to deny qualified trained graduates the opportunity to work in their chosen field.  Again, we ask that NCCT testing be an option for Certification for Surgical Tech graduates.

I have seen students from both of these types of schools and I do not see a difference.  I believe that the NCT students should also be able to be certified.  

Jeanette Christy, RN, MSN, CNOR

Thank you for providing an opportunity to respond to 18VAC85-160-51 B.1.  I am the Executive Vice President of Centura College, an institution of higher education with five campuses in Virginia, providing a range of Allied Health programs, including Biotechnical Equipment Technician, Medical Assisting, and a range of other certified professional programs.  Due to the vast shortage of Surgical Technicians expressed by the health care providers who employ our students, we have been in development of a Surgical Technology program, in order to increase the supply of trained and certified technicians in Richmond and Hampton Roads.  The current regulation, as proposed, has caused us to cease development of our program, and if this law passes as written, we will likely not continue to develop the program.  Thank you for letting me explain why.

The law, as currently written, allows only 1 of the 2 equally-accredited and legitimate certifications to be recognized in Virginia.  This practice would be counter to the national trend, which clearly favors allowing both NCCT and NBSTSA certification as the industry-recognized credential for professional Surgical Technologists.  By limiting Virginia to recognizing only one of two equivalent certifications, we would  be harming students and professionals who hold the NCCT certification, and arbitrarily choosing  NBSTSA as the only option.  This would have a negative impact on many citizens of the Commonwealth of Virginia, businesses and individuals.  Specifically, it effects the Surgical Technologist workforce by limiting recruitment opportunities for employers and denying qualified surgical techs the right to practice and achieve gainful employment in their chosen field.  This would also limit the public access to safe surgical care by further exacerbating a healthcare workforce shortage.

Today, surgical technologists certified by NCCT work side by side with and perform the same job duties as NBSTSA-certified surgical technologists.  If this legislation passes as written, NCCT-certified professionals would either have to go back to school to relearn what they've already learned in order to pass a second exam, or they would be forced to choose other career paths in healthcare than the one they are skilled, certified, and passionate about filling.  Why would we want to invalidate the credentials of so many passionate NCCT-certified technicians, when the national standard is that both of these certifications are accepted interchangeably?

Centura College stands to help hospitals and doctors offices by adding at least two Surgical Technician programs to Virginia's inventory of educational programs, and our program is fully designed around the NCCT certification.  If this law takes effect and the only certification option is NBSTSA, we will be forced to immediately scrap the program we have developed in partnership with local hospitals, surgeons, and physicians, and under the guidance of nationally-adopted NCCT programs begin taught around the country.  If we have to halt this program because of 18VAC85-160-51 B.1., it is likely that Surgical Technician will go to "the back of the line" for our new program development, and we would probably not offer the program at all within the foreseeable future.

We hope very much that you will reconsider this limiting bill and allow both NCCT and NBSTSA certifications to serve as the recognized credential for Surgical Technologists in Virginia.

Sincerely,
Dr. Joel A. English
Executive Vice President
Centura College

Amend

Current law, as written, prohibits anyone that holds a NCCT certification from being registered as a Certified Surgical Technologist with the Virginia Board of Medicine. NCCT is a nationally recognized credentialing organization and accredited by NCCA just as NBSTSA.  Both NCCT and NBSTSA techs should be eligible to work in Virginia.  Current legislation discriminates against NCCT certified techs by not allowing them to work in the state of Virginia.

I am a Surgical Technology graduate of a college in VA, and my husband is serving in the U.S Navy. Immediately upon graduation in 2021, I moved to Louisiana and was hired to work as an ST in New Orleans, LA. That year the law changed in Virginia which potentially will prohibit me from being able to ever come back to VA to work as a ST because I cannot sit for the NBSTSA exam. I can only take the NCCT certification as my school at the time I graduated only offered the NCCT exam. I hope that this law can be amended so that when I return to my home in Virginia after my husband completes his service time, I can work in my field as a Surgical Technologist. Please amend this law to include NCCT. I want to be able to get certified. 

I have been an Instructor of Surgical Technology for over 13 years and have been a Surg Tech for over 25 years.  I am Registered and Certified.  As an Instructor I know that no matter which test a student takes they have to be taught the skill and knowledge to be able to perform the duties required of them in the OR.  Both NCCT and NBSTSA are accredited by the same accrediting body so neither of them should have more value than the other.  Students should be able to test with whichever agency they choose.  As an Instructor we train students with the knowledge to be success on either test but one agency shouldn't have leverage over the other.  Its more important to afford every student opportunity for a successful career as a ST.  This could nave a negative outcome on filling jobs in hospitals if we limit the type of test to one agency.  Please amend this law to include NCCT as an option for testing to benefit all.  

I am requesting that the NCCT-Tech in Surg Certification exam remain as a valid option for Surgical Tech graduates. As a former Librarian at Chest Career College, I saw many well-trained, qualified Surgical Tech graduates with NCCT certification successfully launch careers in their field. Removing NCCT certification qualifications would negatively impact these surgical tech students by denying them the right to employment, which they are trained and qualified to do. Offering students the opportunity to choose either NCCT certification or NBSTSA certification - both of which are equally accredited by NCCA - benefits students, businesses, and the accreditation institutions themselves by removing the risk of one group having a monopoly over the industry.

I ask that consideration be made to allow NCCT-Tech in Surgery Certification exam to be
an available option for Surgical Technology graduates. As a retired educator from Chester Career College, I have seen so many graduates become successful Surgical Technologists. Chester Career College graduates are equally trained and qualified to work as Surgical Technologist as evidenced by the many graduates who took the NCCT certification and have been employed in many local Hospital ORs and Surgery Centers. There is no evidence in considering their employability to be different than any other technicians certified by NBSTSA. Our graduates are employed at several local and out of state
Hospitals and Surgery Centers working alongside other NBSTSA certified Surgical Technologists. This law change had a major impact on graduates of the college in that they have been left to feel that their education was inferior to other colleges when in fact they have had the same level of training from qualified industry professionals who are also certified; some by NCCT and others by NBSTSA. Both NCCT and NBSTSA are accredited by the same accrediting body (NCCA) and must meet the same requirements for their accreditation.
One organization should not have the monopoly of being the only available test if they
are equally accredited. Patients in receiving surgery do not ask nor are they made aware
of an ST’s certification, however, I all agree that I want the best professionals in the
ORs who are accountable, well trained, and qualified. This law change could potentially
have many negative affects upon our state and other states where graduates may choose
to live in a time where we need these trained individuals the most. We should not want
to limit available employees to the hospitals at this time nor should we want to deny
qualified trained graduates the opportunity to work in their chosen field. Again, I ask
that NCCT testing be an option for Certification for Surgical Tech graduates.

The purpose of this communication is to urge necessary and appropriate amendment of the referenced regulation which relates to Commonwealth of Virginia’s approval of surgical technologist certifications.  For reasons that are set forth below the current regulation and supporting statute should be amended to include either of the following suggested provisions:

1.    “Successful completion of a surgical technologist training program, and a current certification issued by a NCCA accredited certification program;” 

OR

2.       “Successful completion of a surgical technologist training program, and a current certification issued by the National Center for Competency Testing (NCCT), the National Board for Surgical Technology and Surgical Assisting (NBSTSA), or their successors,”

To briefly explain the need for this amendment, there are two organizations, the NCCT and NBSTSA, that issue certifications for surgical technologists.  The certification programs of both entities are equally accredited by the same accrediting agency, the NCCA. The NCCA, which is the benchmark of the national credentialing industry, has determined that both certification programs meet the same standards.   However, the current regulation does not permit persons holding NCCT certification who do not qualify to be grandfathered in to move from one surgical facility to another within Virginia, or who choose to move from another state, to practice their profession in the Commonwealth. 

There is no justification for the current distinction.  The effect of the statute and regulation, again without justification, prevents persons certified by the NCCT from practicing in Virginia. Under the current regulation a surgical technologist holding NBSTA certification can practice while a surgical technologist holding NCCT certification cannot practice.  Again this distinction is made in spite of the fact that both the NCCT and the NBSTA certification programs are accredited by the by the same agency, the NCCA.

Unless corrected by the foregoing proposed language or similar language, the regulation will continue to have an adverse impact on individuals and businesses in the Commonwealth of Virginia. More specifically, it effects the surgical technologist workforce by limiting recruitment opportunities for employers.  It denies qualified surgical technologists the right to practice and achieve gainful employment in their chosen field.  The regulation also limits the public access to safe surgical care from certified and qualified surgical technologists.  It also exacerbates the current shortage of surgical technologists.

Today, in many states, surgical technologists certified by NCCT work side by side performing the same job duties as NBSTSA certified surgical technologists.  There is no basis for this regulation which permits NBSTSA certified technologists but denies NCCT certified technologists. This needless distinction adversely impacts many individuals, employers, and schools.

Finally, from a legal standpoint, the current regulation gives NBSTSA an unfair and monopolistic competitive advantage. The proposed revision will not eliminate either the NBSTSA or the NCCT from serving the citizens of your state.  It merely creates a level playing field for all.  The proposed language does not eliminate competition but rather promotes fair competition and educational opportunities.

After thorough review of this regulation, we believe you will conclude that this regulation should be amended.

Please accept this comment as a request to amend current VA law/regulation 18VAC85-160. This regulation currently only recognizes surgical tech certification from the NBSTSA and excludes the certification from NCCT. There is no measurable/appreciable difference between the two psychometrically sound and legally defensible Surgical Tech certification exams. This undetectable difference in the exams extends to the surgical techs in my employ - I couldn’t tell you by the work they contribute who took which exam.  As a large employer of certified surgical technologists, I’m gravely concerned that this intentional exclusion of the NCCT certification will negatively impact the employability of many of our current surgical techs. If I am unable to retain these well-qualified surgical techs who have been positive contributing team members up until now, it will directly impact our ability to provide necessary surgical care in our capital region. Additionally this will unnecessarily limit the recruitment pool from which we can hire. As a regionally and nationally recognized level 1 trauma center, burn center, transplant center, pediatric surgical center, stroke center, and other surgical specialties - this loss of workforce would have drastic impact on our accreditation status and abilities to continue providing care. I appreciate your attention to this matter and urge you to reevaluate this intentional exclusion of the NCCT certification. 

I feel that the NCCT should be considered for amendment because we've all worked hard to pass this exam and get our certification. Most of us have been working in our field of study for years and shouldn't have to take another exam because the state of Virginia doesn't acknowledge the one we sat for. It's not fair to us that this exam basically doesn't count for anything. This exam should definitely be included.