To whom it may concern,

I oppose the proposed amendment to 18VAC85-120-110, which would allow athletic trainers to perform dry needling.

Contrary to popular belief, acupuncture is not just placement of a acupuncture needle in the body. Proper location, diagnosis, technique, and selection are required for effective and safe treatment.

Athletic trainers lack the required training and knowledge to safely treat patients using acupuncture needles. They desire to perform acupuncture without taking the necessary training. Simply renaming it dry needling is disingenuous and dangerous for public safety 

This proposal threatens public safety, increases risk and liability to the Board of Medicine, and undermines the rigorous education and licensure standards that licensed acupuncturists must meet and are enacted by Virginia Law and regulations. 

Thank you,

Christopher Lee, L.Ac.