Please accept this comment as a request to amend current VA law/regulation 18VAC85-160. This regulation currently only recognizes surgical tech certification from the NBSTSA and excludes the certification from NCCT. There is no measurable/appreciable difference between the two psychometrically sound and legally defensible Surgical Tech certification exams. This undetectable difference in the exams extends to the surgical techs in my employ - I couldn’t tell you by the work they contribute who took which exam.  As a large employer of certified surgical technologists, I’m gravely concerned that this intentional exclusion of the NCCT certification will negatively impact the employability of many of our current surgical techs. If I am unable to retain these well-qualified surgical techs who have been positive contributing team members up until now, it will directly impact our ability to provide necessary surgical care in our capital region. Additionally this will unnecessarily limit the recruitment pool from which we can hire. As a regionally and nationally recognized level 1 trauma center, burn center, transplant center, pediatric surgical center, stroke center, and other surgical specialties - this loss of workforce would have drastic impact on our accreditation status and abilities to continue providing care. I appreciate your attention to this matter and urge you to reevaluate this intentional exclusion of the NCCT certification.