I would like to directly address the letter from the Acupuncture Association of VA, as it is full of inaccuracies, misleading information and bias.   

First, they state: “Allowing athletic trainers—who do not possess the requisite education, clinical training, or licensure in acupuncture—to perform this procedure poses significant risks to public health and safety.”

This point is inaccurate and not proven.  A recent study in the Journal of Sports Medicine and Allied Health Science (Hortz et al., 2019) found that 89% of the tasks required for competent dry needling performance are already covered within entry-level athletic training education.

Also there is no evidence to show that ATs dry needling increases risk to public health in any other state.

Second, they write “athletic trainers undergo extensive training in musculoskeletal assessment and rehabilitation, but their education does not include the rigorous study of needling techniques, acupuncture points, meridian theory, or safety protocols for needle insertion that licensed acupuncturists undertake”.

While this is true, it is misleading.  Athletic trainers are educated in western pathophysiology, anatomy and neurology.  They do not need to know meridian theory, as they are not trying to practice acupuncture, which is rooted in Eastern Medicine.  They are western medicine practitioners.  Also, athletic trainers are well trained in much more than musculoskeletal assessment and rehab.  They are educated in internal medicine, immediate care, physiology and pathophysiology, neurology, anatomy, suturing, spinal manipulation and more.  I would urge you to refer to the BOC Standards of Professional Practice and the CAATE Guide to the 2020 Standards for the full scope of athletic training education

Third, they write that “the proposed amendment does not specify adequate training standards to ensure the safe and effective practice of dry needling by athletic trainers”.

Via the rules process, standards for education will be implemented. Now is not the time to define that.  Many states have included specific standards for education in their dry needling legislation. States including Alaska, Alabama, Arizona, Arkansas, Colorado, Delaware, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Maryland, South Carolina, North Carolina, Kentucky, Tennessee, Nebraska, and Ohio, among others, have successfully integrated specific standards for training, leading to improved patient outcomes, more access to comprehensive healthcare and consumer satisfaction.

Fourth, they write “Risk of Injury and Infection: Improper needling techniques can result in serious complications and life-threatening incidents” and “Licensed acupuncturists in the state of Virginia undergo a minimum of 1,900 hours of comprehensive training”.  Both points are true, however again, misleading. 

1. Again, athletic trainer’s education well prepares them for this skill, as the above stated paper reports 89% of of the tasks needed to safely needle is learned in school.  The other 11% is easily learned with additional post graduate training. 
2. Acupuncturists enter acupuncture school with zero training or education and therefore require fundamental training that athletic trainers already have upon completion of a CAATE accredited athletic training program as it relates to standard precautions, needle safety and use. Learning standard/ universal precautions in preparation for current athletic training standards such as suturing, IV administration, wound debridement and more are in the athletic training curriculum.
3. Athletic trainers are well trained in emergency care.  This is one of their primary areas of study.  If an accident of any kind were to occur, who better to handle an emergency than an ER physician or nurse, paramedic, and/ or an athletic trainer?

Finally, they discuss the “Lack of Regulatory Oversight”

Athletic trainers hold a license in the state of VA as well as a nationally accredited certification via the BOC. They are held to standards for continuing education and function with physician oversight and collaboration.  They absolutely have safety, physician oversight and continuing education standards of practice in place.

I would encourage the Virginia Department of Health Professions to allow the amend regulations to permit athletic trainers to use dry needling.