As a current acupuncture student, I strongly oppose the amendment to 18VAC85-120-110 which would allow athletic trainers to perform dry needling with minimal training. Dry needling is not a simple technique—it is an invasive procedure often targeting the same muscular trigger points that our profession refers to as Ashi points. The difference is that licensed acupuncturists complete three to four years of rigorous postgraduate education to learn how to needle safely and effectively. In contrast, athletic trainers would be permitted to perform this procedure with only a fraction of that training. Other healthcare professionals with clinical backgrounds such as chiropractors, and physical therapists have caused serious injuries, such as pneumothorax, due to inadequate training with acupuncture needles. Allowing this amendment would put patients at increased risk of adverse outcomes by giving needling privileges to yet another profession with limited training, applying techniques that exceed their educational foundation and fall outside their clinical depth.