As a licensed acupuncturist with more than 20 years' clinical experience, I strongly oppose the proposed amendment to 18VAC85-120-110 that would allow athletic trainers to perform dry needling in Virginia. My opposition is grounded in concerns over patient safety, inadequate training standards, and the lack of regulatory safeguards that protect the public from serious harm.

1. Safety Risks and Adverse Events
Dry needling is an invasive procedure that involves inserting solid filiform needles into muscle tissue, often near critical anatomical structures. While minor side effects such as soreness and bruising are common, severe adverse events—including pneumothorax, nerve injury, and infection—have been documented, particularly when performed by practitioners with limited training in needle technique. Recent studies highlight that serious complications, such as pneumothorax, are more likely when physical therapists or other non-acupuncturists perform dry needling without sufficient training in invasive techniques12. For example, a 2024 analysis found that between 8% and 13% of physical therapists reported major adverse events, and pneumothorax remains the most frequently reported severe complication in dry needling performed by non-acupuncturists12.

2. Inadequate Training and Education
Licensed acupuncturists in Virginia are required to complete a minimum of 1,900 to 3,000 hours of comprehensive education, including over 1,000 hours of hands-on needle training25. This extensive training covers detailed anatomy, physiology, pathology, clean needle technique, and supervised clinical practice.  In order to be licensed in Virginia, acupuncture school graduates must be "Nationally Board Certified" by passing an 8-hour board exam developed through the National Certification Commission for acupuncture and Oriental Medicine (www.NCCAOM.org) which is certified through the Institute for Credentialling Excellence (https://www.credentialingexcellence.org). In contrast, athletic trainers typically receive only a fraction of this training—often less than 100 hours focused on dry needling, with little or no education in invasive needle procedures, depth awareness, or the management of complications25. This disparity in training directly correlates with increased risk to patient safety.

3. Clean Needle Technique and Bloodborne Pathogen Training
Acupuncturists are required to demonstrate mastery of clean needle technique and infection control, as mandated by national board certification and continuing education standards4. This includes rigorous training in sterilization, safe needle handling, and proper disposal to prevent the transmission of bloodborne pathogens and other infectious diseases34. While general bloodborne pathogen training is available to healthcare workers in Virginia3, the specific, hands-on training in clean needle technique required of acupuncturists far exceeds what is typically provided to athletic trainers. This gap increases the risk of infection and cross-contamination when dry needling is performed by inadequately trained individuals.

4. Regulatory Oversight and Public Protection
The proposed amendment does not specify adequate training standards or regulatory oversight for athletic trainers performing dry needling5. Allowing practitioners with minimal training to perform an invasive procedure undermines the rigorous safeguards established to protect the public. Licensed acupuncturists are subject to ongoing recertification, ethics reviews, and disciplinary processes to ensure high standards of care—protections not guaranteed by the proposed amendment for athletic trainers5.

Conclusion
Dry needling, regardless of terminology, is acupuncture by definition and should only be performed by those with the requisite education, clinical experience, and regulatory oversight. The evidence clearly shows that insufficient training leads to higher rates of adverse events, including life-threatening complications. For the safety of Virginia’s patients and the integrity of healthcare practice, I urge the Board to reject amendment 18VAC85-120-110.

Respectfully,
Bill Reddy, L.Ac.
Licensed Acupuncturist
www.BillReddy.com