Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Licensure of Athletic Trainers [18 VAC 85 ‑ 120]
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4/7/25  1:36 pm
Commenter: Joshua Elliott

Stand for Integrity: Oppose the Amendment to 18VAC85-120-110
 

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)

CommentID: 233550