The proposed regulations do not appear to allow for the use of National Registry testing for initial certification courses for FR/EMR, EMT-B/EMT, EMT-E/AEMT.  As written, this section specifically requires an Office of EMS written and practical exam.  The regulations clearly recognize that National Registry exams are not the same due to the ALS section calling for the use of the NR tests for I & P, and also makes allowance for the state to take over I testing if/when NR discontinues the test.  As written, every initial certification course and/or the entire OEMS would require a variance to send students to National Registry testing.  The sections that follow 1455 very clearly spell out the state's responsibility for maintaining and administering state tests (which NR does not follow), establishes a percentage based passing score requirement (which NR's CBT does not follow), and spells out retesting requirements (that are different from NR's).  Further, 12VAC5-31-1567 speciffically states "A. All state written examinations shall be conducted by the Office of EMS."  As proposed, either OEMS must revert to state testing for all level other than I & P, or must delay implementation and rewrite the certification sections to remove the state testing requirements to continue the National Registry testing implemented this summer.