Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Licensure of Athletic Trainers [18 VAC 85 ‑ 120]
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4/16/25  4:34 pm
Commenter: Karine Martimbianco

Disagreement with Allowing Athletic Trainers to Practice Dry Needling
 

I respectfully vote no on the proposal to permit athletic trainers to practice dry needling.

Dry needling is an invasive procedure that requires extensive anatomical knowledge, precision, and clinical training. While athletic trainers are highly skilled in sports medicine and rehabilitation, dry needling falls outside the traditional scope of their practice. It involves puncturing the skin and working near neurovascular structures, which poses risks if not performed by practitioners with comprehensive training in needling techniques and differential diagnosis.

Furthermore, current regulations in many states restrict dry needling to licensed professionals such as physical therapists or medical doctors who undergo specialized education and clinical supervision. Expanding this scope without standardized, rigorous training requirements could compromise patient safety and professional accountability.

For these reasons, I do not support expanding athletic trainers’ scope of practice to include dry needling.

CommentID: 233729