Please vote no on 18VAC85-120-110, which proposes expanding the scope of practice to allow athletic trainers to perform orthopedic acupuncture, also known as dry needling. This is a matter of patient safety, training integrity, and professional standards.

Licensed acupuncturists complete a rigorous master’s-level program that includes years of focused education, medical oversight, and clinical training. We are nationally certified, maintain licensure through over 60 hours of continuing education annually, and are specifically trained in Clean Needle Technique to safely and effectively insert and remove acupuncture needles for therapeutic benefit.

Athletic trainers, while skilled in their own field, complete a bachelor’s-level education with no comparable depth in needling, diagnosis, or safety protocols related to this invasive procedure. Acupuncturists are already widely accessible to the public and well-equipped to collaborate with sports medicine teams when needed.

I have personally witnessed patient injuries and heard troubling feedback following the expansion of dry needling to physical therapists in the last decade. Patients have reported bruising, sharp pain, and a worsening of their original condition. Many have shared stories of family members or friends who now refuse to consider acupuncture at all—because of painful, negative experiences with improperly trained providers.

Acupuncture has maintained an exceptional safety record precisely because of the high level of training and oversight required for licensure. The more this standard is diluted, the more injuries and adverse events we will see.

You wouldn’t show up at an acupuncture office expecting to create a personalized injury plan for a football player—it’s just as negligent to apply the logic the other way. Please protect public safety and professional integrity by voting no on this proposal.