I am writing in opposition to 18VAC85-120-110 that would allow athletic trainers to perform dry needling. Dry needling  is an invasive medical procedure requiring advanced knowledge of human anatomy, physiology, and extensive clinical training. Legislators should not back this bill as it will increase unnecessary risk for patients. Only trained certified providers should be able to perform invasive techniques. Complications due to poor needle insertion skills include collapsed lung, punctured artery, bleeding, nerve damage, broken needle, migration of needle, infection and more if not properly trained.