I write in strong opposition to the proposed amendment permitting athletic trainers to perform dry needling (DN). This matter demands serious consideration, as it directly concerns patient safety and the integrity of healthcare standards in the Commonwealth.

Dry needling is an invasive procedure that should only be performed by licensed healthcare professionals with comprehensive training in needling techniques, anatomy, physiology, and differential diagnosis. Athletic trainers, whose core curricula do not include invasive procedures, would be permitted under this amendment to perform DN after completing only a fraction of the training required of other Virginia-licensed providers. This represents a significant reduction in the threshold of competence and undermines public trust in our healthcare system.

Importantly, DN is not included in the Board examination for athletic trainers, nor are there standardized requirements for DN training in their licensing process. Their professional scope centers on non-invasive musculoskeletal support and rehabilitation—not on puncturing the skin or interacting with deep anatomical structures.

By contrast, licensed acupuncturists in Virginia must complete more than 2,000 hours of training, including extensive hands-on needling education, and hold at least a Master's degree. Chiropractors, though permitted to perform DN with less needling-specific training, possess a rigorous educational foundation in anatomy and clinical diagnosis that athletic trainers do not.

Permitting this expansion in scope without commensurate education and clinical standards poses a real risk to patient safety and sets a troubling precedent for lowering regulatory standards without adequate justification or oversight.

I respectfully urge the Board to reject this amendment in order to uphold the safety of Virginia’s residents, maintain professional integrity, and protect the high standards of care to which our healthcare system must be held.