We respectfully urge the board to oppose the proposed amendment to 18VAC85-120-110, which seeks to grant licensed athletic trainers the authority to perform dry needling following training and physician screening.

Dry needling is an invasive procedure involving the insertion of filiform needles into myofascial trigger points and other soft tissue structures to relieve pain and dysfunction. While it is often distinguished from acupuncture in terminology, the technique is fundamentally identical to acupuncture as defined in traditional and contemporary medical practice. Allowing athletic trainers—who do not possess the requisite education, clinical training, or licensure in acupuncture—to perform this procedure poses significant risks to public health and safety.