Massachusetts Surgical Technologist Requirements

Overview

Massachusetts does not issue a personal state license card for surgical technologists, but it does have a strong employment law that ties who facilities may hire to national education and certification standards.^[1][2][3] Under Massachusetts General Laws Chapter 111, Section 235, a surgical facility generally may not employ or retain an individual to perform surgical technology tasks unless that person has completed an accredited educational program for surgical technologists and holds and maintains a Certified Surgical Technologist (CST®) credential, or qualifies under a specific statutory exemption.^[1][2][3]

In practice, this framework makes Massachusetts function as a certification‑required state even though regulation occurs through facility‑employment provisions rather than a traditional professional licensure chapter.^[2][3] As a result, most surgical technologists in Massachusetts complete an accredited surgical technology program, obtain CST® certification, and maintain active certification to remain employable in hospitals and surgical facilities across the state.^[2][3][5]

State Classification

Massachusetts is classified as a **certification‑required** state for surgical technologists because Chapter 111, Section 235 conditions employment on accredited education and certification pathways, with limited exceptions.^[1][2][3] The Association of Surgical Technologists’ legislative overview lists Massachusetts among the states that have enacted surgical technologist laws requiring graduation from an accredited program and CST® certification, with a 12‑month grace period for new graduates and defined grandfathering for existing staff.^[2]

Statutory Requirements

Massachusetts General Laws Chapter 111, Section 235 defines “surgical technologist” as a person who provides surgical technology services but is not a licensed health care practitioner and sets standards for whom a surgical facility may employ to perform surgical technology tasks.^[1][3] Except as otherwise provided in the statute, a surgical facility may only employ or retain a surgical technologist who has successfully completed an accredited educational program for surgical technologists and holds and maintains a CST® credential administered by a nationally recognized certifying body accredited by the National Commission for Certifying Agencies and recognized by the American College of Surgeons and AST.^[1][2][3]

The statute also allows a temporary pathway for new graduates who have completed an accredited surgical technology program but have not yet obtained CST® certification, provided that they obtain CST® within 12 months of the graduation date.^[1][3] In addition, an individual employed as a surgical technologist in a surgical facility on July 1, 2013, may continue to practice under grandfathering provisions if they meet the conditions in Section 235, and the law recognizes certain military training and federal employment circumstances as additional qualifying pathways.^[1][2][3]

Section 235 further authorizes the Department of Public Health to grant waivers when a facility has made a diligent and thorough effort to employ qualified surgical technologists who meet the statutory requirements but is unable to employ enough for its needs, and it clarifies that licensed health care practitioners such as registered nurses may perform surgical technology tasks if acting within the scope of their license.^[1][3]

Employer Standards in Massachusetts

Because Section 235 regulates surgical technologists through facility hiring standards, Massachusetts employers play a central role in implementing the law and often go beyond the minimum statutory requirements.^[2][3] AST’s Massachusetts FAQ notes that while the law permits certain grandfathered or alternative pathways, many health care facilities choose to require all surgical technologists to graduate from an accredited program and hold CST® certification, regardless of their hire date, to maintain consistent practice standards.^[2]

Massachusetts surgical technology programs accredited by CAAHEP upon the recommendation of ARC/STSA describe curricula that combine classroom instruction, skills labs, and supervised clinical experiences and explicitly prepare graduates for the CST® exam and entry‑level perioperative employment.^[4][5] Employers rely on these accredited programs and national certification standards when developing job descriptions, credentialing criteria, and ongoing competency requirements for surgical technologists in their operating rooms.^[2][4][5]

Certification Requirements

CST® certification through the National Board of Surgical Technology and Surgical Assisting (NBSTSA) is the primary credential referenced in Massachusetts law and is effectively required for most new surgical technologist hires under Section 235.^[1][2][3] AST’s Massachusetts FAQ clarifies that graduating from an accredited surgical technology program alone does not satisfy the statute for long‑term employment; a person must both complete an accredited program and hold the CST® credential, unless they qualify under a defined grace period, grandfathering clause, or other statutory pathway.^[2][3]

According to NBSTSA, CST® eligibility typically requires graduation from a CAAHEP‑ or ABHES‑accredited surgical technology program or an approved military program and passing the CST® examination, with ongoing continuing‑education or periodic re‑examination required to maintain certification.^[4] Massachusetts technologists must therefore plan for both initial CST® certification and ongoing recertification in order to remain compliant with facility expectations and the intent of Section 235.^[2][4]

Registration or Licensure Requirements

Massachusetts does not issue a separate surgical technologist license, maintain a statewide surgical technologist registry, or require a personal state ST license number.^[1][2][3] Instead, regulation occurs through Chapter 111, Section 235 and related regulations, which govern who hospitals and other surgical facilities may employ to perform surgical technology tasks and reference accredited education and CST® certification as qualifying criteria.^[1][3][5]

Some national summaries describe Massachusetts as “no state license card, CST® required for employment” to highlight that enforcement is tied to facility compliance rather than issuance of individual licenses by a health professions board.^[2][5] Surgical technologists who also hold other Massachusetts licenses—such as registered nurse licenses—are regulated under those licensure statutes for work within those scopes of practice, while their surgical technology duties remain subject to Section 235 and facility policy.^[1][3]

Renewal Requirements

Because there is no personal Massachusetts surgical technologist license, the state does not impose a profession‑specific license renewal schedule, fees, or continuing‑education requirements for surgical technologists.^[1][3] Instead, renewal requirements come from NBSTSA’s CST® recertification rules—which require continuing education credits or periodic examination—and from facility policies that may require proof of active CST® certification and ongoing professional development to continue practicing as a surgical technologist.^[2][4]

Background Checks

Massachusetts surgical technologist law focuses on education and certification criteria rather than on a dedicated background‑check process for surgical technologists.^[1][3] As in other states, hospitals and surgical facilities in Massachusetts typically apply their standard onboarding and credentialing procedures—which may include criminal background checks, drug screening, immunization verification, and reference checks—to surgical technologists as part of broader perioperative staffing policies and accreditation requirements.^[2][5]

Scope of Practice

Chapter 111, Section 235 does not contain a detailed, enumerated scope‑of‑practice list for surgical technologists but defines surgical technologists by the surgical technology tasks and functions they perform in support of surgery.^[1][3] Consistent with national occupational descriptions, surgical technologists in Massachusetts typically assist in operations by preparing operating rooms, arranging instruments and sterile supplies, assisting with gowning and gloving, maintaining the sterile field, passing instruments and supplies, handling specimens, and participating in sponge and instrument counts under the supervision of surgeons and circulating nurses.^[2][4][5]

Section 235 and related regulations also make clear that licensed practitioners such as registered nurses and other licensed health care providers may perform surgical technology tasks if acting within the scope of their license, and that surgical technologists themselves do not independently diagnose, prescribe, or determine treatment plans; these responsibilities remain with licensed providers.^[1][3][4]

Governing Agency

Massachusetts surgical technologist requirements are codified in the public health statutes and regulations governing surgical facilities rather than in a stand‑alone professional‑licensing board chapter.^[1][3][5] The Massachusetts Department of Public Health, through its licensing and regulatory authority over hospitals and clinics, enforces compliance with Section 235 and related regulations, while NBSTSA and accreditation bodies such as CAAHEP and ARC/STSA manage national certification and program‑quality standards that employers use when hiring surgical technologists.^[1][2][4][5]

Statute Citations

• Massachusetts General Laws c.111, § 235: “Surgical technologists; standards and requisites for employment; waiver” – defines surgical technologists, sets accredited‑program and CST®‑based criteria for whom surgical facilities may employ, establishes a 12‑month grace period for new graduates, outlines grandfathering and military/federal pathways, and authorizes waivers when facilities cannot hire enough qualified surgical technologists.^[1]
• 105 CMR 140.621 – Surgical Technology: Massachusetts Department of Public Health regulation for clinics that mirrors the statutory requirements by prohibiting facilities from employing or retaining surgical technologists unless they have completed an accredited program and hold a CST® credential (with similar exemptions and waiver provisions).^[3]

Massachusetts Surgical Technologist Salary & Job Outlook

U.S. Bureau of Labor Statistics Occupational Employment and Wage Statistics (OEWS) for Surgical Technologists (SOC 29‑2055) report a national annual mean wage of about $60,900 for surgical technologists as of May 2023, based on full‑time employee wage and salary data across all industries.^[4] Using the same OEWS program, Massachusetts state occupational estimates show that allied health occupations, including surgical technologists, generally earn higher wages than the national average, reflecting the state’s higher cost of living and concentration of large hospital systems and academic medical centers; this suggests that full‑time surgical technologists in Massachusetts can expect earnings at or above national norms, particularly in metropolitan areas such as Boston.^[4][5] BLS and AST both note that nationwide demand for surgical technologists is supported by ongoing surgical procedure volumes and aging populations, indicating a steady or growing job outlook for CST®‑certified surgical technologists in Massachusetts’s regulated employment environment.^[2][4][5]

Summary

Massachusetts does not issue a personal surgical technologist license or maintain an ST registry, but Chapter 111, Section 235 effectively requires accredited education and CST®‑level certification—or another narrow statutory pathway—for individuals to be employed as surgical technologists in surgical facilities.^[1][2][3] In practice, Massachusetts operates as a CST®‑required state, so individuals who wish to work there as surgical technologists should plan to complete a CAAHEP‑ or ABHES‑accredited surgical technology program, obtain and maintain CST® certification, and meet any additional employer‑specific requirements for perioperative practice.^[2][4][5]

References

• [1] Massachusetts Legislature. “General Laws – Part I, Title XVI, Chapter 111, Section 235: Surgical technologists; standards and requisites for employment; waiver” – official statutory text establishing surgical technologist employment requirements, qualifying pathways, and waiver provisions. Available at: https://malegislature.gov/Laws/GeneralLaws/PartI/TitleXVI/Chapter111/Section235.^[web:990]
• [2] Association of Surgical Technologists (AST). “Massachusetts Surgical Technologist Law – Frequently Asked Questions” – professional FAQ explaining how Section 235 applies to employers and technologists, including accredited‑program and CST® requirements, the 12‑month grace period, grandfathering, military pathways, and facility waiver options. Available at: https://www.ast.org/legislation/documents/Massachusetts_Surg_Tech_Certification_FAQs.pdf.^[web:995]
• [3] Code of Massachusetts Regulations. “105 CMR 140.621 – Surgical Technology” – Department of Public Health regulation that applies Section 235’s standards to licensed clinics by requiring accredited education and CST® certification for surgical technologists, with similar exemption and waiver provisions, and clarifying that licensed health care practitioners may perform surgical technology tasks within their scope of practice. Available at: https://www.law.cornell.edu/regulations/massachusetts/105-CMR-140-621.^[web:994]
• [4] National Board of Surgical Technology and Surgical Assisting (NBSTSA). “CST® Certification” – official certification information describing eligibility pathways (CAAHEP‑ or ABHES‑accredited programs or military training), CST® examination details, and continuing‑education or re‑examination requirements for maintaining certification, which Massachusetts law references through its requirement for a nationally recognized CST® credential. Available at: https://www.nbstsa.org/cst-certification.^[web:983]
• [5] Commission on Accreditation of Allied Health Education Programs (CAAHEP) / ARC/STSA. Surgical technology accreditation standards and Massachusetts program accreditation information – describe the competencies and minimum standards for accredited surgical technology programs whose graduates are eligible to sit for the CST® exam and to meet Massachusetts Section 235 education requirements. Program‑level disclosures and catalogs adopt these standards when describing preparation for employment in Massachusetts. See CAAHEP: https://www.caahep.org and ARC/STSA program lists.^[web:978]
• [6] Association of Surgical Technologists (AST). “Legislative Overview – State Law Map” – national overview describing AST’s advocacy for state surgical technologist laws and listing Massachusetts among states with statutory requirements for accredited education and CST® certification for surgical technologists working in surgical facilities. Available at: https://www.ast.org/Public_Policy/Legislative_Overview/.^[web:881]
• [7] U.S. Bureau of Labor Statistics. “Occupational Employment and Wages, May 2023 – 29‑2055 Surgical Technologists” – OEWS national occupational profile and wage data for surgical technologists (national annual mean wage about $60,900 for full‑time employees) and state‑level estimates, including Massachusetts, used to benchmark wages and job outlook. Available at: https://www.bls.gov/oes/2023/may/oes292055.htm and Massachusetts state tables at: https://www.bls.gov/oes/2023/may/oes_ma.htm.^{[web:408][web:996]}