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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4/8/25  12:41 pm
Commenter: Dr. Sarah Faggert-Alemi

Opposition to Allowing Athletic Trainers to Dry Needle
 

I am deeply concerned about the implications this amendment would have on public safety, professional standards and patient's trust in Virginia healthcare providers if it were to be passed. Dry needling is an invasive procedure that requires extensive knowledge of anatomy, physiology, pathology and safety protocols , especially regarding clean needle technique and depth awareness to avoid complications pneumothorax or nerve injury - which we have unfortunately seen, especially from those practicing with less training hours regarding dry needling. 

The proposed amendment would allow athletic trainers to perform DN, who have a core curriculum that does not involve invasive needling techniques, with only a fraction of the training required of other healthcare professionals licensed in Virginia, and with less formal education and training regarding the body outside of needling, too. This creates a significant risk to public safety and sets a dangerous precedent for lowering standards in the interest of expanding scope without appropriate oversight or education. 

DN is not part of their Board Exam nor are training requirements for it standardized in their licensing procedures. Their focus is on superficial musculoskeletal assessment and care. 

To put this in perspective, licensed acupuncturists have over 3,000 hours of needling training with a minimum of a Master's degree; chiropractors may only be required to have 100-200 hours of needling training, but they also have a higher level of education and training regarding physiology and anatomy of the body. 

I strongly urge the rejection of this amendment and instead support policies that protect patients, respect professional boundaries and maintain the high standards of healthcare delivery in the Commonwealth. 

CommentID: 233564