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.