The Army has changed the Holistic Health and Fitness program on manning in Brigade Combat Teams for budgetary reasons.  The authorizations for physical therapists are now replaced by strength conditioning coaches, i.e. athletic trainers in the Brigade Combat Teams.  For Soldiers with health issues, Army policy directs Soldiers to seek assistance through medical channels, and not from strength conditioning coaches.  Allowing the Virginia rulemaking to make needling available to athletic trainers will bring harm to Soldiers because it is against Army policy.  For this reason, athletic trainers in the public sector should be able to recognize their limitations on wellness training and be able to refer clients to proper medical channels, and not attempt to assume the high risks inherent from invasive medical procedures that are not covered by their malpractice insurance.

The secondary impact if this rulemaking is allowed to stand should be the requirement for accrediting training facilities as healthcare facilities.  One of the accrediting organizations will have jurisdiction in allowing the training facility to serve in a medical capacity.  The athletic trainers would require supervision on the scope of practice, forcing the owners of wellness and sports training facilities to budget and acquire medical supervision and documentation capabilities that currently don't exist.   The underwriting industry will have to calibrate the malpractice insurance to the level that current facilities of allied health professions pay for the same coverage.  For these reasons, the delivery of healthcare by athletic trainers in sports facilities is wrong and should be left to the trust of public safety from regulated professions such as medical doctors and licensed acupuncturists.