I am writing to express my support for amending current regulations to allow certified, Virginia-licensed, and American Medical Association (AMA)-recognized athletic trainers to perform the modality of dry needling.

At present, the Commonwealth lacks a standardized definition of dry needling. However, two widely accepted interpretations classify it either as a mechanical or invasive modality. Athletic trainers are qualified under both interpretations.

The athletic training practice act permits the use of mechanical modalities when the provider is trained or certified in the modality and operates under the direction of a physician. Since dry needling is often categorized as a mechanical modality, it appropriately falls within the scope of practice for athletic trainers.

Moreover, dry needling is also classified by some as an invasive procedure. Accredited athletic training programs—governed by the Commission on Accreditation of Athletic Training Education (CAATE)—already require training in invasive techniques such as emergency IV access, lidocaine injections, and wound closure using staples or sutures. These competencies demonstrate the rigorous clinical preparation athletic trainers receive.

During the COVID-19 pandemic, the Governor of Virginia issued an emergency order recognizing the qualifications of athletic trainers to administer vaccines after appropriate training, further underscoring their capabilities as healthcare professionals.

It is important to distinguish dry needling, grounded in Western medicine and focused on myofascial trigger point therapy, from acupuncture, which follows Eastern medicine and meridian theory. Arguments against athletic trainers performing dry needling often commingle these two distinct practices. For discussions to be productive, they must remain consistent in scope and terminology.  The amendment brought forth is not focused on the practice of acupuncture, but the modality of dry needling, furthermore the argument of opposition should remain on dry needling and the mention of acupuncture is, in its core essence, not the congruent modality as defined by that providers’ stated education requirements, certification, licensure and clinical practice.

Certified athletic trainers, who possess a minimum of a master’s degree, are extensively trained in clinical procedures. They are trusted in diverse, high-stakes environments such as surgical suites, military operations, law enforcement, emergency medical services, physician practices, and air medical transport. Their impact spans from Olympic and professional athletes to rehabilitation centers and high schools, all underpinned by state regulatory standards.

As a profession, athletic trainers remain committed to practicing within our defined scope and under the supervision of a licensed physician. We also value and support our fellow healthcare providers, working collaboratively for the benefit of our shared patients.

Thank you for considering this important amendment. It will not only reinforce the capabilities of athletic trainers but also enhance patient access to safe and effective care.