On behalf of the Acupuncture Society of Virginia (ASVA) and our members, we respectfully 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.

Concerns Regarding Patient Safety & Proper Training

1. Insufficient Training Standards: Athletic trainers undergo extensive training in musculoskeletal assessment and rehabilitation, but their education does not include the rigorous study of needling techniques, acupuncture points, meridian theory, or safety protocols for needle insertion that licensed acupuncturists undertake. The proposed amendment does not specify adequate training standards to ensure the safe and effective practice of dry needling by athletic trainers.

2. Risk of Injury and Infection: Improper needling techniques can result in serious complications and life-threatening incidents, including nerve damage, pneumothorax, infection, and excessive bleeding. Licensed acupuncturists in the state of Virginia undergo a minimum of 1,900 hours of comprehensive training, including needle insertion safety, sterilization techniques, and extensive supervised clinical practice. The proposed amendment does not ensure equivalent or sufficient training standards for athletic trainers to mitigate these risks.

3. Lack of Regulatory Oversight: The practice of acupuncture, including dry needling, is prescribed under Virginia law and regulated by the Board of Medicine’s acupuncture regulations. Allowing athletic trainers to perform dry needling under a separate regulatory structure, without the same rigorous oversight required of licensed acupuncturists, creates a dangerous precedent that compromises patient safety. Licensed acupuncturists in Virginia also maintain national board certification that further ensures patient safety with ongoing recertification requirements and a national ethics and disciplinary review process.

Legal & Professional Scope of Practice Issues

1. Violation of Scope of Practice: Athletic trainers are not currently authorized under Virginia law to perform invasive procedures involving needle insertion. Expanding their scope of practice to include dry needling would require clear legislative action (similar to physical therapists in § 54.1-3482), rather than a regulatory amendment, to ensure proper accountability and public protection. The side-by-side definitions (§ 54.1-2900) of the practice of acupuncture and the practice of athletic training clearly delineate the use of needles for acupuncturists and not athletic trainers. 

2. Public Misperception and Consumer Confusion: Patients seeking dry needling may not be fully aware of the differences in training and qualifications between licensed acupuncturists, physical therapists and athletic trainers. This amendment could lead to consumers receiving treatment from inadequately trained practitioners, thereby undermining public trust in regulated healthcare professions.

Given the substantial risks associated with inadequate training, the potential for patient harm, and the need to uphold professional standards in healthcare, the Acupuncture Society of Virginia strongly opposes the proposed amendment to 18VAC85-120-110. We urge the Board to reject this petition and uphold the current regulatory framework, which ensures that invasive needling procedures remain within the scope of appropriately trained and licensed healthcare providers.

Greetings honorable representatives, I send this to express my strong objection to athletic trainers performing dry needling. Following an injury I had dry needling done on myself by a physical therapist who I later discovered had very little training. It ended up making my condition much worse. Athletic trainers will not be undergoing any more training than physical therapists, and most likely even less. This makes the potential for harm that much greater. I have done quite a bit of research on dry needling since then and I assure you this is not as simple a technique as athletic trainers and physical therapists would have you believe.

I ask you to please vote no on this proposed bill. Thank you for your time and your service.

Respectfully,

Tyme Gigliotti

Any time that the skin is penetrated by a sharp object, ANY type of needle or scalpel, extraordinary care must be exercised.  It is not only an opportunity for infection, but the practitioner is altering blood flow, a person's essence and chemical make-up. Without the essential knowledge of the interactions between the primary organ systems and how the systems (heart, kidney, intestines, spleen, stomach...) support or counteract, there could be unintentional consequences that neither the patient nor an uneducated practitioner would anticipate.

I respect the field of sports medicine. However I don't know about the expertise of athletic trainers. I would suggest that the educational requirements for trainers needs to be reviewed and analyzed for the surgical aspects that is dry needling. Even physicians who perform acupuncture are aware of the consequences of penetrating a patients skin in order to alter a condition.

Absolutely against ATs doing DN. This is an invasive procedure to be performed only by medical professionals. We acupuncturist spend years training to use a needle.

Allow this and endanger public health.

Harry F Lardner L.Ac

As a licensed acupuncturist in the state of Virginia, I  strongly oppose athletic trainers practicing dry needling. Dry needling is in fact a form of Acupuncture. All licensed acupuncturists have spent thousands of hours in school, earning masters degrees and doctorates and we take extreme pride in knowing we have mastered our skill. Acupuncture and dry needling are not skills that can be aquired with a weekend certification, nor are they skillsets to be taken lightly. This simply puts patients and individuals at risk for injury due to untrained professionals, and diminishes the skillset acupuncturists have earned.

Why do we as a country and state require Licensed Acupuncturists to got through 3-4 years of graduate school followed by rigorous testing before we trust them to use needles in this manner, but let athletic trainers, with no graduate level training and only a few weekend course hours required for a ‘certification’ treat in virtually the same way? It defies logic. If you think this is ok for athletic trainers to do, then why not get rid of the high standards required for acupuncturists? Or, if you think these educational requirements for acupuncturists are justified, as I do, then it is inconsistent, and frankly dangerous, to let athletic trainers do functionally the same treatment with comparatively minuscule levels of training.

For the term "dry needling", it is another translation of the Chinese medicine term "Zhen". Same meaning as the "Acupuncture".

Some professionals want to actually practice acupuncture, using "dry needling" to bypass the acupuncture law. This is not safe for the general public and not fair to acupuncture profession either for licensed acupuncturists or medical (physician) acupuncturists.

Acupuncture law requires for a licensed acupuncturist: (1) a student graduates from a national agency-accredited acupuncture school (before applying the school, should with q minimal 60 credits from an accredited college); (2) three years of graduate study at least at a master's degree (minimal 90 credits); (3?pass national examination of the National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM); (4) get a acupuncture license from the state.

Acupuncture law requires a licensed physician(MD) to practice acupuncture: (1) with MD license (this requires 4 years post-undergraduate college study); (2) 250-300 hours of acupuncture training in an accredited Medical Acupuncture training agency.

Any other professionals, like athletic trainers, need to follow the acupuncture law and get a formal education in an acupuncture school. I oppose using "dry needling" to bypass the acupuncture law, and practicing dry needling (actually acupuncture), without enough training.

Hello.  Dry needling should be performed by licensed acupuncturists rather than physicians, as acupuncturists have extensive and specialized training in the techniques, anatomy, and safety protocols required for effective treatment. Their expertise ensures proper needle placement, reducing risks of injury and maximizing therapeutic outcomes. Physicians may lack this specialized skill set.  They should not be allowed to perform it.  

There comes a moment when silence is no longer an option—not because we seek conflict, but because truth demands a voice.

This is not a matter of professional rivalry. It is a matter of public safety, of principled standards, and of honoring the path of those how have earned the title of “Licensed Acupuncturist.”

Dry needling is acupuncture. Let’s not pretend otherwise. The insertion of a solid filiform needle into muscle tissue to elicit a response is not a new invention. It is a fragment of a medicine that is thousands of years old, reduced, renamed, and repackaged—stripped of its root and context.

To allow someone to wield a needle with a weekend course or a brief certification is not only dangerous—it is a betrayal of the patient’s trust. Licensed acupuncturists in Virginia complete thousands of hours of rigorous medical education, including in-depth anatomy, physiology, safety, and supervised clinical training. We undergo national board examinations and state licensure. This is not bureaucracy—it is earned expertise.

When the barrier to entry is reduced, it is not just the profession that is diminished. It is the public that is left vulnerable. Dry needling, when done poorly, can cause significant harm—punctured lungs, nerve injuries, infections. These are not theoretical risks. They are documented outcomes. And they are preventable—by insisting that only those who are thoroughly trained, tested, and licensed be permitted to perform this invasive technique.

What we permit reflects what we value. Do we value thoroughness, competence, and the wisdom that arises from long study? Or do we reduce a complex medical art into a marketable skill that anyone can pick up with a few hours of instruction?

This proposed amendment is a slippery slope. If we allow one profession to bypass the safeguards that exist for a reason, others will follow. The erosion will not stop at dry needling. And what will remain is not integrated care—it is fractured care, where expertise is replaced by expedience and the sacred trust between healer and patient is treated as a commodity.

There is a time to cultivate. And there is a time to defend the field.

This is that time.

To our colleagues in other professions—we do not oppose collaboration. We believe in integrative care, where each provider brings their highest skillset to the table for the benefit of the patient. But integration must be built on respect, not appropriation.

To lawmakers and regulators—we urge you to pause and consider the long-term implications of this amendment. Public trust in healthcare is already fragile. The right response is not to lower standards, but to uphold them. The answer is not to create shortcuts—but to honor the depth and diligence that true healing demands.

To fellow acupuncturists reading this comment: let us be rooted like the pine, resilient like the bamboo. Let us not resist the storm with fury, but redirect it with wisdom. And above all, let us remain in service to the one truth that guides all healing professions:

First, do no harm.

Joshua Elliott

USNA '15

VUIM '26 (tentative)

We have a profession that requires 3+ years of didactic education and hundreds of clinical hours, plus passing a series of national board exam. It's called an "acupuncturist". They are sufficiently trained and experienced to needle patients to address various health concerns. Why does the state keep trying to take needling from acupuncturists? First to chiropractors, physical therapists, now trainers? Let's keep the common sense about ourselves and let acupuncturists needle patients.

I oppose dry needling by any profession other than acupuncturist.

Acupuncturists have far more experience in needling. Not only is a 27 hour course not enough for trainers, PT's and Chiropractors not enough for needling in general, it is also dangerous. Acupuncturists need to go to school for at least 1,850 hours. PT's, chiropractors, and now what you'd like to carry into athletic trainers are only required to go to school for 27 hours, and oftentimes are not required to do this training in person. It is not only dangerous and can create long-term issues due to mismanagement of muscle release and pneumothorax, but PT's, Chiropractors and Athletic trainer's have no understanding of the theory behind. They do not know contraindicated points for people who are pregnant nor do they know contraindications for people with various diseases. It is extremely dangerous. I wouldn't trust myself, and you shouldn't trust me either as an acupuncturist who knows the body and skeletal system through and through to take a weekend course in Chiropractic care and crack your neck on Monday. You should apply this same thinking to Chiropractors, PT's and now athletic trainers. I behoove you to rather than employ these non-acupuncturists, to encourage them to refer out to REAL acupuncturists and have a better cross-occupational relationship, and we will continue to refer out when things are out of our scope of practice. Do not allow more people to practice acupuncture without a license. 

It does not seem that invasive procedures with the potential for complications is within the AT scope of practice. Any addition of this invasive procedure to the AT scope should include a requirement for additional training and testing, including how to manage complications, coverage of clean needle technique, and red flags for referral.

Dear [Recipient or Team],

I want to take a moment to address an important public health and professional scope of practice concern regarding the use of dry needling by athletic trainers.

Dry needling, while often framed as a technique rather than a form of acupuncture, involves the insertion of solid filiform needles into the body—an invasive procedure that carries significant risk if not performed with proper training. Licensed acupuncturists complete thousands of hours of training, including in-depth study of anatomy, needling technique, and safety protocols, supervised clinical training to ensure patient well-being.

Athletic trainers typically receive far less instruction—often in the range of 20–50 hours—which does not meet the standards of safe or competent needle insertion. This gap in training poses a real risk to public safety, including punctured organs, nerve damage, infection, and other adverse outcomes.

Beyond individual patient safety, allowing undertrained practitioners to perform needling also creates a broader community risk by undermining standards for credentialing, informed consent, and professional accountability. It contributes to confusion among patients about who is qualified to offer this kind of care and weakens the integrity of scope-of-practice laws designed to protect the public.

As healthcare professionals, we must advocate for responsible, well-regulated use of any invasive technique—and dry needling should be no exception.

Warmly,
Dr. Todd McCloskey
Director, Acupuncture & Herbal Medicine Program
Lotus Professional College,Richmond VA. 

As an acupuncturist, I oppose the amendment to 18VAC85-120-110 

I am deeply concerned about the implications this amendment would have on public safety, professional standards and patient's trust in Virginia healthcare providers if it were to be passed. Dry needling is an invasive procedure that requires extensive knowledge of anatomy, physiology, pathology and safety protocols , especially regarding clean needle technique and depth awareness to avoid complications pneumothorax or nerve injury - which we have unfortunately seen, especially from those practicing with less training hours regarding dry needling. 

The proposed amendment would allow athletic trainers to perform DN, who have a core curriculum that does not involve invasive needling techniques, with only a fraction of the training required of other healthcare professionals licensed in Virginia, and with less formal education and training regarding the body outside of needling, too. This creates a significant risk to public safety and sets a dangerous precedent for lowering standards in the interest of expanding scope without appropriate oversight or education. 

DN is not part of their Board Exam nor are training requirements for it standardized in their licensing procedures. Their focus is on superficial musculoskeletal assessment and care. 

To put this in perspective, licensed acupuncturists have over 3,000 hours of needling training with a minimum of a Master's degree; chiropractors may only be required to have 100-200 hours of needling training, but they also have a higher level of education and training regarding physiology and anatomy of the body. 

I strongly urge the rejection of this amendment and instead support policies that protect patients, respect professional boundaries and maintain the high standards of healthcare delivery in the Commonwealth. 

Please say NO to unsafe 18VAC85-120-110. There is a major concern regarding the use of dry needling by athletic trainers—a practice that poses significant risks without proper training. Dry needling involves inserting solid needles into the body, an invasive procedure that requires extensive expertise.

Licensed acupuncturists undergo thousands of hours of rigorous training in anatomy, technique, and safety protocols, ensuring patient welfare. Athletic trainers, in contrast, often receive only 20–50 hours of instruction, which falls far short of the necessary standards for safe needle use. This lack of training increases risks such as organ punctures, nerve damage, and infections.

Additionally, allowing inadequately trained practitioners to perform dry needling compromises patient trust, informed consent, and professional accountability. It blurs the lines of scope-of-practice laws meant to safeguard public health.

Responsible and regulated practices are essential for any invasive technique, and dry needling is no exception.

Thank you for your consideration.

As a second year grad student studying acupuncture and Chinese medicine, I find it alarming that unlicensed professionals are using dry needling. A Master’s degree that takes 3 years is required for us to practice acupuncture legally, and for good reason, as the human body is intricate and interconnected in ways that are not obvious to someone who has not studied the art and science of acupuncture. Allowing someone who is not a licensed  acupuncturist to needle their clients is not only dangerous for the patient, but it is also disrespectful to those of us who are investing large sums of money, our time, and our energy to a degree that will enable us to safely and effectively help our patients. Dry needling is essentially the same idea as someone who is an unlicensed surgeon being permitted to cut into somebody with a scalpel. We are required to have vigorous training to ensure that we understand the risk and benefits of acupuncture, and I believe that those who wish to perform dry needling should be required to undergo the same training, if they are interested in needling, to provide safe and effective treatment for their patients.

I am currently a Doctor of Acupuncture and Herbal Medicine student at Virginia University of Integrative Medicine, located in Vienna, VA. I have a focus on orthopedic needling as well as undergraduate athletic training experience. As such, I oppose the legislative proposal to allow athletic trainers to adopt dry needling into their scope of practice. Needling should be left to those with extensive years of training and certification in Clean Needle Technique (CNT) to preserve the safety of both patients and clinicians everywhere.

If accepted, this proposal will overshadow the precautionary measures and thorough experience obtained only by acupuncturists. This includes but is not limited to three to five years minimum of formal training as outlined by our national certification commission (NCCAOM) and accredited alternative medicine institutions across the country. To accept this proposal is to deny patients optimal care, as the needling training in question is minimal and not strictly regulated or overseen by any state or national evaluation system. I plan to integrate my studies into the sports medicine realm. I am aware of plenty of my peers who wish to do the same upon graduation. I have competent professors who have already been doing so for years. There is no shortage of acupuncturists who are qualified and experienced in orthopedic needling, therefore the practice should not be treated as such.

I have not only practiced dry needling but have been the recipient of it as a patient both in physical therapy and acupuncture clinics, such as the VUIM Student Clinic. After observing various techniques, I am no longer comfortable receiving dry needling therapy outside of an acupuncture clinic. This is due to the technique variability and CNT violations I have observed numerous times by those clinicians who do not have the experience and licensing standards my peers and I share. Ignorance of the aforementioned protocols increases the risk of adverse events in patients, such as infection or pneumothorax. This is a threat to public safety, trivializes the integrity of the acupuncture profession, and undercuts the rigor of acupuncture education and licensing standards. Vote NO on 18VAC85-120-110.

As a patient of an acupuncturist and doctor, I highly oppose athletic trainers being allowed to dry needle. Acupuncturists have spent countless hours and thousands of dollars training for certifications and mastering the specialty.  Allowing athletic trainers who have little training would put patients at high risk and also diminish the work of highly trained acupuncturists.  I hope you reconsider this bill. 

Dry needling should absolutely not be integrated into athletic training programs because it involves complex physiological processes, including but not limited to the nervous system and musculature, that require specialized training beyond the scope of standard athletic training curricula. Additionally, safety protocols and the extensive years of education needed to properly administer dry needling make it an intervention best suited for licensed acupuncturists who have undergone professional training and licensure. To ignore these facts would be grossly negligent and overlook the seriousness for potential risks and adverse events associated with improper application, which could lead to harm or injury to athletes if not performed by adequately trained professionals. 

The proposed ammendment 18VAC85-120-110 threatens the safety of patients undermining the rigorous education and license necessary to ensure minimal  harm to patients.

NO to 18VAC85-120-110

Dry needling is acupuncture. Athletic trainers do not have the specific and comprehensive training to attempt dry needling. Call it what you want, dry needling uses acupuncture needles and acupuncture and dry needling is internal medicine. Without adequate training and medical knowledge and specific knowledge of acupuncture, dry needling is dangerous. It is also misleading to the public to call it dry needling when dry needling is acupuncture. This is a dangerous trend this dry needling and athletic trainers DO NOT have enough knowledge, skill and training specific to the use of acupuncture needles for any purpose. This is a terrible idea, many people will get hurt. I have over 2000 hours of training and 25 years of clinical experience. Athletic trainers should not be allowed to dry needle.

I strongly oppose the proposed amendment to 18VAC85-120-110 that would permit athletic trainers to perform dry needling with minimal training. Dry needling involves the insertion of needles into muscle tissue and requires a deep understanding of anatomy, potential risks, and clinical judgment—skills that are developed through extensive, specialized education. Allowing individuals to perform this technique without the rigorous training required of other healthcare professionals jeopardizes patient safety and lowers the standard of care. I urge the Board to prioritize public health and safety by rejecting this amendment.

No to 18VAC85-120-110

NO to 18VAC85-120-110!!

No to 18VAC85-120-110

No to 18VAC85-120-110

No to 18VAC85-120-110

NO to 18VAC85-120-110

No to 18VAC85-120-110

no! 

No to 18VAC85-120-110

I am writing to express my support for amending current regulations to allow certified, Virginia-licensed, and American Medical Association (AMA)-recognized athletic trainers to perform the modality of dry needling.

At present, the Commonwealth lacks a standardized definition of dry needling. However, two widely accepted interpretations classify it either as a mechanical or invasive modality. Athletic trainers are qualified under both interpretations.

The athletic training practice act permits the use of mechanical modalities when the provider is trained or certified in the modality and operates under the direction of a physician. Since dry needling is often categorized as a mechanical modality, it appropriately falls within the scope of practice for athletic trainers.

Moreover, dry needling is also classified by some as an invasive procedure. Accredited athletic training programs—governed by the Commission on Accreditation of Athletic Training Education (CAATE)—already require training in invasive techniques such as emergency IV access, lidocaine injections, and wound closure using staples or sutures. These competencies demonstrate the rigorous clinical preparation athletic trainers receive.

During the COVID-19 pandemic, the Governor of Virginia issued an emergency order recognizing the qualifications of athletic trainers to administer vaccines after appropriate training, further underscoring their capabilities as healthcare professionals.

It is important to distinguish dry needling, grounded in Western medicine and focused on myofascial trigger point therapy, from acupuncture, which follows Eastern medicine and meridian theory. Arguments against athletic trainers performing dry needling often commingle these two distinct practices. For discussions to be productive, they must remain consistent in scope and terminology.  The amendment brought forth is not focused on the practice of acupuncture, but the modality of dry needling, furthermore the argument of opposition should remain on dry needling and the mention of acupuncture is, in its core essence, not the congruent modality as defined by that providers’ stated education requirements, certification, licensure and clinical practice.

Certified athletic trainers, who possess a minimum of a master’s degree, are extensively trained in clinical procedures. They are trusted in diverse, high-stakes environments such as surgical suites, military operations, law enforcement, emergency medical services, physician practices, and air medical transport. Their impact spans from Olympic and professional athletes to rehabilitation centers and high schools, all underpinned by state regulatory standards.

As a profession, athletic trainers remain committed to practicing within our defined scope and under the supervision of a licensed physician. We also value and support our fellow healthcare providers, working collaboratively for the benefit of our shared patients.

Thank you for considering this important amendment. It will not only reinforce the capabilities of athletic trainers but also enhance patient access to safe and effective care.

Dry needling and accupuncture are not the same thing (different theory and practice) but puncturing the skin, primarily in extremities, with the proper training, poses few risks to patients.  As athletic trainers, we are doing this on the field or during play, it is a controlled clinical skill with well supported outcomes.  Physiotherapists (our European equivalent) have been using this technique safely for years.  We are actually slow to implement in the USA.  

I support ATs being able to use dry needling as part of their practice.

I am writing to express my strong support for amending Virginia's regulations to authorize certified, Virginia-licensed athletic trainers to perform dry needling. 

Currently, Virginia defines dry needling as an advanced procedure requiring additional post-graduate training, including emergency preparedness, contraindications, needle techniques, and physiological responses. This training comprises didactic and hands-on laboratory education, culminating in theoretical and practical examinations. 

Notably, during the COVID-19 pandemic, Virginia recognized athletic trainers' qualifications by permitting them to administer vaccines after appropriate training, highlighting their role as healthcare professionals.

Allowing athletic trainers to perform dry needling, under proper training and physician oversight, would enhance patient access to effective care. Incorporating dry needling into athletic trainers' skill sets aligns with Virginia's commitment to utilizing healthcare professionals' full capabilities to meet patient needs. This amendment would not only improve patient outcomes but also optimize the use of healthcare resources within the state.?

I respectfully urge the consideration and adoption of this amendment to empower athletic trainers and enhance patient care in Virginia.

Athletic trainers are licensed healthcare providers and should be allowed to dry needle as part of the scope of practice in the care of their patients

I would like to agree with the rest of the athletic trainers on this matter, in support of dry needling inclusion in the scope of athletic training in the state of Virginia. As licensed medical professionals, we are trained in several skills and aspects of healthcare and a wide variety of subjects. Dry needling is also a topic we have been taught about, yet unable to perform due to the legal writings of our scope of practice. As a form of therapeutic intervention, dry needling has been shown to make drastic improvements for patients suffering from many types of injuries, including acute and chronic injuries. Dry needling has been approved in many other states and has been pulling athletic trainers to those states because of it. If Virginia would approve of this as well, then there could be more athletic trainers willing to work in Virginia. Please vote to allow athletic trainers to add dry needling to their toolbox in Virginia!

I support the Athletic Trainers ability to perform dry needling in the healthcare of their patients!

This definitely should be a part of our scope of practice!

As Healthcare Professionals, Athletic Trainers have extensive training in the care and treatment of our patients. Dry Needling falls in line with our education in modalities, often being labeled as mechanical modalities, which Athletic Trainers are allowed to perform in their clinics. Athletic training programs are now teaching dry needling in their curriculum, which allows for these students to be trained and prepared to perform this technique, along with other invasive practices such as IV access and wound closure. I fully support the amendment to allow Athletic Trainers the ability to dry needle. 

Dear Virginia Board of Medicine, 

I am writing in support of the amendment to allow athletic trainers to use dry needling techniques during patient care. 

Certified athletic trainer's (ATC) in the state of Virginia are certified and licensed allied-healthcare professionals with a breadth of knowledge in patient care. Currently, as expressed in the State Practice Act that governs athletic training practice, athletic trainers may use appropriate modalities as part of patient care if they are appropriately trained and certified in these techniques as well as having express, written permission from the supervising physician to perform these techniques. Dry needling should be considered no differently.

Additionally, any concerns regarding an ATC's educational background to provide the requisite skills necessary to engage in dry needling techniques are patently unfounded. For example, regarding the concerns that ATCs cannot perform 'invasive' procedures, ATCs, as part of the modern education standards established by the Commission of Accreditation of Athletic Training Education, are required to be taught techniques related to emergency IV access, lidocaine injections, and wound closure with sutures or staples. These skills are further highlighted by the ever expanding professional setting of ATCs working along physicians both clinically and in the operating room where I have personally witnessed immense skill in conducting 'invasive' techniques. 

In short, Virginia has been and continues to be at the forefront of allowing ATCs to utilize all of the skills they have acquired as part of their education. Furthermore, ATCs are dedicated healthcare professionals that wish for nothing but to ensure patient health and well-being throughout their life. It is with this I reiterate my immense support for the amendment that will allow properly trained, certified, and licensed ATCs to provide dry-needling techniques as part of their practice. 

Thank you,

Cade Watts, MS, MPH, LAT, ATC

I strongly support amending current regulations to allow certified licensed ATs to perform the modality of dry needling.

Two accepted interpretations of dry needling in VA view it as either as a mechanical or invasive modality. Athletic trainers are qualified under both interpretations.

Dry needling as a mechanical modality: The athletic training practice act permits the use of mechanical modalities when the provider is trained or certified in the modality and operates under the direction of a physician. 

Dry needling as an invasive procedure: accredited athletic training education programs—governed by the Commission on Accreditation of Athletic Training Education (CAATE)—require training in invasive techniques such as emergency IV access, lidocaine injections, and wound closure using staples or sutures. These competencies demonstrate the rigorous clinical preparation athletic trainers receive.

Dry needling focuses on myofascial trigger point therapy. Acupuncture follows Eastern medicine and meridian theory. The amendment brought forth only allows ATs the modality of dry needling. 

Certified athletic trainers, who possess a minimum of a master’s degree, are extensively trained in clinical procedures and are regulatory permitted to perform invasive procedures in the Commonwealth of Virginia - under the supervision of a physician and with appropriate industry standard training for dry needling (which we’ve previously established is NOT acupuncture.) 

Athletic trainers are committed to practicing within our defined scope and under the supervision of a licensed physician. We value and support our fellow healthcare providers, working collaboratively for the benefit of our shared patients.

Athletic trainers  work in diverse, high-stakes environments such as surgical suites, military operations, law enforcement, emergency medical services, physician practices, and air medical transport. Their impact spans from Olympic and professional athletes to rehabilitation centers and high schools.

Thank you for considering this important amendment.

No to 18VAC85-120-110

Athletic Trainers are highly educated, board-certified, healthcare professionals with extensive training in the evaluation, diagnosis, and treatment of musculoskeletal conditions. As such, they are uniquely qualified to safely and effectively integrate dry needling into clinical practice. 

Dry needling is a skilled, evidence-based intervention used to treat neuromuscular dysfunction, relieve pain, and improve functional movement. Athletic trainers already possess the anatomical knowledge, clinical judgement and manual therapy expertise essential for this technique. With appropriate post-professional education, they are fully capable of incorporating dry needling into their treatment repertoire. 

Denying athletic trainers the ability to perform dry needling not only limits access to timely and effective care for physically active populations but also underutilizes the capabilities of a critical segment of the sports medicine workforce. In states where dry needling by athletic trainers is allowed, outcomes have been positive and safety records remain strong. 

Therefore, I strongly advocate for legislative and regulatory frameworks that recognize dry needling as within the athletic training scope of practice--when performed by professionals who have completed recognized post-certification education and training in the modality. 

Supporting athletic trainers' ability to perform dry needling enhances patient care, expands access to evidence-based interventions, and reflects the evolving standards of modern sports medicine.

Athletic Trainers are highly educated, board-certified, healthcare professionals with extensive training in the evaluation, diagnosis, and treatment of musculoskeletal conditions. As such, they are uniquely qualified to safely and effectively integrate dry needling into clinical practice. 

Dry needling is a skilled, evidence-based intervention used to treat neuromuscular dysfunction, relieve pain, and improve functional movement. Athletic trainers already possess the anatomical knowledge, clinical judgement and manual therapy expertise essential for this technique. With appropriate post-professional education, they are fully capable of incorporating dry needling into their treatment repertoire. 

Denying athletic trainers the ability to perform dry needling not only limits access to timely and effective care for physically active populations but also underutilizes the capabilities of a critical segment of the sports medicine workforce. In states where dry needling by athletic trainers is allowed, outcomes have been positive and safety records remain strong. 

Therefore, I strongly advocate for legislative and regulatory frameworks that recognize dry needling as within the athletic training scope of practice--when performed by professionals who have completed recognized post-certification education and training in the modality. 

Supporting athletic trainers' ability to perform dry needling enhances patient care, expands access to evidence-based interventions, and reflects the evolving standards of modern sports medicine.