Subject: Opposition to Dry Needling by Non-Licensed Acupuncture Professionals

Title: Dry Needling Should Be Performed Only by Licensed Acupuncturists to Ensure Patient Safety

As a licensed acupuncturist practicing in Virginia, I respectfully oppose the proposed amendment to 18VAC85-120 that would permit athletic trainers to perform dry needling.

Dry needling involves the insertion of acupuncture needles into muscular and connective tissues. Regardless of terminology, this is an invasive procedure that carries real risks and requires significant clinical skill and experience to perform safely. Patient safety must always be the top priority in any healthcare decision.

Licensed acupuncturists in Virginia complete thousands of hours of graduate-level education, including detailed instruction in anatomy, physiology, pathology, and supervised clinical practice. We are nationally certified through rigorous board examinations, such as those administered by the National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM), and are held to high ethical and legal standards.

The use of acupuncture needles should remain within the scope of professionals who are specifically trained and licensed to use them. Expanding this procedure to professions without equivalent training in needle technique, clinical risk management, and diagnostic reasoning could compromise patient safety and public trust.

Patients deserve the assurance that any procedure involving needles is performed by a licensed and board-certified professional trained specifically in that modality. This is not a matter of professional territory—it is a matter of safety, accountability, and quality of care.

If any profession seeks to use invasive needle techniques, they should be held to the same standards of education, supervised clinical training, and national board certification required of licensed acupuncturists. Anything less compromises patient safety.

I respectfully urge the Board to reject this rulemaking proposal to preserve patient protection and uphold high standards in healthcare delivery.

Sincerely,
Seonim Cho, DAcHM, MSOM, Dipl. Ac, L.Ac.
Licensed Acupuncturist, Commonwealth of Virginia