I am currently a Doctor of Acupuncture and Herbal Medicine student at Virginia University of Integrative Medicine, located in Vienna, VA. I have a focus on orthopedic needling as well as undergraduate athletic training experience. As such, I oppose the legislative proposal to allow athletic trainers to adopt dry needling into their scope of practice. Needling should be left to those with extensive years of training and certification in Clean Needle Technique (CNT) to preserve the safety of both patients and clinicians everywhere.

If accepted, this proposal will overshadow the precautionary measures and thorough experience obtained only by acupuncturists. This includes but is not limited to three to five years minimum of formal training as outlined by our national certification commission (NCCAOM) and accredited alternative medicine institutions across the country. To accept this proposal is to deny patients optimal care, as the needling training in question is minimal and not strictly regulated or overseen by any state or national evaluation system. I plan to integrate my studies into the sports medicine realm. I am aware of plenty of my peers who wish to do the same upon graduation. I have competent professors who have already been doing so for years. There is no shortage of acupuncturists who are qualified and experienced in orthopedic needling, therefore the practice should not be treated as such.

I have not only practiced dry needling but have been the recipient of it as a patient both in physical therapy and acupuncture clinics, such as the VUIM Student Clinic. After observing various techniques, I am no longer comfortable receiving dry needling therapy outside of an acupuncture clinic. This is due to the technique variability and CNT violations I have observed numerous times by those clinicians who do not have the experience and licensing standards my peers and I share. Ignorance of the aforementioned protocols increases the risk of adverse events in patients, such as infection or pneumothorax. This is a threat to public safety, trivializes the integrity of the acupuncture profession, and undercuts the rigor of acupuncture education and licensing standards. Vote NO on 18VAC85-120-110.