Honorable representatives,

I write to express my strong opposition to the proposed amendment to 18VAC85-120-110, which seeks to allow athletic trainers to practice dry needling without meeting the rigorous standards required for licensed acupuncturists. This proposal poses a significant risk to public health and safety, undermines the integrity of established healthcare regulations, and may lead to avoidable medical complications due to insufficient practitioner training.

First of all, dry needling is a type of acupuncture by definition and practice.  As such, we should stop using the term "dry needling" to avoid causing confusion in the public and creating many potential legal issues.

Any insertion of needles into muscle tissues, requiring a comprehensive understanding of anatomy, neurophysiology, and sterile technique to prevent adverse effects such as nerve damage, infections, and pneumothorax. Licensed acupuncturists undergo accredited master level education, including extensive foundational medicine study (in both Chinse Medicine and western medicine) and supervised clinical training, ensuring that they practice with the necessary expertise and safety measures. In contrast, the so called "dry needling" receives just minimal instruction on needling techniques, increasing the likelihood of unsafe procedures that could endanger patients.

Furthermore, this amendment sets a dangerous precedent, diluting healthcare standards and potentially placing patients at risk due to inadequate oversight. The Virginia Board of Medicine must prioritize patient safety by upholding strict professional licensure requirements for any invasive procedures.

I urge you to reject this proposal and uphold the integrity of healthcare practices in Virginia. Public health and safety must remain the foremost priority in all regulatory decisions.

Thank you for your time and consideration.

Respectfully,

Ningjiang Cheng