The proposed regulation compares Virginia's pass rates to North Carolina and Maryland.  However, both North Carolina and Maryland have one-third, approximately 300 and versus 1100, number of nursing graduates that successfully pass the NCLEX and become nurses compared to the Commonwealth of Virginia.  Is the public policy of the Board of Nursing of Virginia to create regulations to reduce the number of nursing graduates and Licensed Practical Nurses in the Commonwealth of Virginia?  Pass rates for first time test takers should not be used to create public policy without research.  Virginia needs to improve the quality of nursing programs while not reducing the number of graduates in the State.