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