Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Licensure of Athletic Trainers [18 VAC 85 ‑ 120]
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4/7/25  10:08 pm
Commenter: Todd McCloskey

Athletic trainers will harm the public
 

Dear [Recipient or Team],

I want to take a moment to address an important public health and professional scope of practice concern regarding the use of dry needling by athletic trainers.

Dry needling, while often framed as a technique rather than a form of acupuncture, involves the insertion of solid filiform needles into the body—an invasive procedure that carries significant risk if not performed with proper training. Licensed acupuncturists complete thousands of hours of training, including in-depth study of anatomy, needling technique, and safety protocols, supervised clinical training to ensure patient well-being.

Athletic trainers typically receive far less instruction—often in the range of 20–50 hours—which does not meet the standards of safe or competent needle insertion. This gap in training poses a real risk to public safety, including punctured organs, nerve damage, infection, and other adverse outcomes.

Beyond individual patient safety, allowing undertrained practitioners to perform needling also creates a broader community risk by undermining standards for credentialing, informed consent, and professional accountability. It contributes to confusion among patients about who is qualified to offer this kind of care and weakens the integrity of scope-of-practice laws designed to protect the public.

As healthcare professionals, we must advocate for responsible, well-regulated use of any invasive technique—and dry needling should be no exception.

Warmly,
Dr. Todd McCloskey
Director, Acupuncture & Herbal Medicine Program
Lotus Professional College,Richmond VA. 

CommentID: 233556