Hello, My name is Sarah Shupe Hung and I am a Virginia licensed acupuncturist with offices in Burke and Alexandria. I would like to express my concerns about the proposal for athletic trainers to perform dry needling.

A main concern is public safety related to iInsufficient training standards. Athletic trainers. The proposed amendment does not specify adequate training standards to ensure the safe and effective practice of dry needling by athletic trainers. Most dry needling courses involve only a one or two weekend training.  They also do not include supervised clinical training, which is critical to mastering needle techniques.  Supervised clinical training provides the real world experience that has been key to acupuncture’s strong reputation for safety and effectiveness. 

In comparison to the one or two weekend training dry needlers attend, acupuncturists in Virginia are required to have at least 1900 hours of comprehensive training including 705 hours of acupuncture-specific didactic material and 660 hours of supervised clinical training. The proposed amendment does not ensure equivalent or sufficient training standards for athletic trainers to mitigate these risks.

Besides the public safety risk, I also agree with Acupuncture Society of Virginia’s statement of on risk of injury, lack of regulatory oversight and legal and scope of practice issues.  For these reasons I strongly oppose the proposed amendment to 18VAC85-120-110.

Sarah Shupe Hung L.Ac.