Public Comment Opposing the Inclusion of Dry Needling in Athletic Trainers' Scope of Practice

I am writing to express my strong opposition to the proposed amendment to 18VAC85-120-110, which would allow athletic trainers to perform dry needling. This proposal poses a significant risk to public safety and undermines the rigorous education and licensure standards that licensed acupuncturists are required to meet under Virginia law.

Dry needling is not a simple technique—it involves the insertion of solid filiform needles into muscle tissue, often at deep anatomical levels. Licensed acupuncturists in Virginia undergo a minimum of 1,905 hours of graduate-level training, including over 660 hours dedicated specifically to acupuncture technique, safety, and clinical practice. In contrast, athletic trainers typically receive only a fraction of this training, and dry needling is not a standard component of their education.

As a practitioner, I have witnessed complications from improperly performed needling, including nerve damage, punctured lungs, and infections. These outcomes are rare in the hands of licensed acupuncturists but become far more likely when performed by individuals without sufficient training. Granting this authority to athletic trainers would expose patients to unnecessary risk and increase liability for the Board of Medicine.

This amendment sets a dangerous precedent by lowering the bar for who can perform invasive procedures. Public protection—not professional convenience—must remain the priority.

I urge you to reject this proposed amendment and uphold the standards that keep Virginians safe.

Sincerely,