I am writing in strong support of amending the regulations in the state of Virginia to allow licensed athletic trainers (ATs) to perform dry needling as part of their scope of practice. Dry needling is a skilled, evidence-informed intervention that has demonstrated clinical efficacy in reducing pain and improving functional movement. Athletic trainers, by the nature of their education, clinical experience, and national certification standards, are highly qualified to perform this modality safely and effectively.

The Board of Certification for the Athletic Trainer (BOC) acknowledges the growing legislative trend to include dry needling within the AT scope of practice, aligning with national standards and the evolving demands of sports medicine and rehabilitation care (BOC, n.d.). Furthermore, the National Athletic Trainers’ Association (NATA) emphasizes that scope of practice should be based on education, training, and demonstrated competency—not arbitrary profession-based restrictions (NATA, n.d.).

Several states, including West Virginia, have already recognized the competency of athletic trainers in this area and have enacted clear regulatory language allowing trained ATs to perform dry needling (West Virginia Code of State Rules, §16-5-12). Virginia should follow suit by acknowledging that properly trained ATs—through rigorous continuing education courses such as those approved by Structure & Function Education—meet the criteria to perform dry needling within their practice safely (Structure & Function, n.d.).

Virginia’s current regulatory framework should reflect contemporary healthcare standards and allow ATs to utilize all tools within their scope to enhance patient outcomes. The Virginia Board of Medicine must recognize this opportunity to expand access to high-quality, non-pharmacological care, especially for physically active populations who already rely on athletic trainers for injury prevention, assessment, and rehabilitation (Virginia Board of Medicine, n.d.).

I urge the Board to support this necessary update to the scope of practice and allow qualified athletic trainers in Virginia to perform dry needling.