Title:  Needle Insertion Requires Formal, Licensed Training to Protect Patients.

While I previously submitted a formal comment opposing this proposal, I would like to follow up and further emphasize a key concern:

"While I respect the value that athletic trainers bring to sports medicine, the insertion of acupuncture needles remains an invasive procedure that must be governed by rigorous, board-recognized training and licensure standards. Patient safety should not be compromised by varied interpretations of scope of practice."

This is not a matter of professional competition or limiting care access. It is about ensuring that invasive procedures involving needle insertion are performed only by professionals who have completed formal, clinically supervised education specifically in acupuncture needle technique, passed national board certification in acupuncture (such as the NCCAOM), and are held legally accountable through licensure.

Possessing general anatomical knowledge or completing a short post-certification course in dry needling is not equivalent to the intensive, multi-year education and training required of licensed acupuncturists. Equating the two disregards the complexity and risks of needle-based therapies.

I respectfully urge the Board to preserve the integrity of regulated medical practice and protect the public by rejecting this proposal.

Respectfully submitted,
Seonim Cho, DAcHM, MSOM, Dipl. Ac, L.Ac.
Licensed Acupuncturist, Virginia