Dear Virginia Board of Medicine,

I am writing to you on behalf of the Virginia Ambulatory Surgery Association( VASA), and the 61 CMS-certified ambulatory surgery centers in Virginia, as I wanted to share my concerns regarding the pertinent statute and regulation 18VAC85-160 and HB 598.  This legislation specifies that all surgical technologists in the state of Virginia maintain certification via one specific entity, the National Board of Surgical Technology and Surgical Testing.  By creating a de facto monopoly by requiring all surgical technologists to maintain certification through one entity while leaving out other fully accredited legitimate certification options, an already overburdened workforce will likely suffer tremendous challenges with recruiting and retaining surgical technologists. this is of particular concern for vulnerable patient populations in rural localities, where a shortage of surgical technologists is already an issue. I felt it prudent to bring this to your attention, as this legislation was never presented to VASA, and I am certain you will be compelled to move to amend this to include and recognize  both certifications on the behalf of all citizens of the state of Virginia.

Sincerely,

Shane Stanford

President

Virginia Ambulatory Surgery Association