As both a licensed physical therapist and a certified athletic trainer, I write in strong support of proposed regulation 18VAC85-120-110.

In my practice as a physical therapist, I am legally authorized to perform dry needling and have completed all required coursework, certification, and additional hands-on training to ensure I deliver this technique safely and effectively. I have seen firsthand the positive impact dry needling can have on reducing pain, improving mobility, and accelerating recovery—especially in active populations and athletes.

Athletic trainers are uniquely qualified to perform dry needling in a pivotal moment of the rehabilitation process, when properly trained. Their foundational knowledge of human anatomy, neuromuscular function, and clinical decision-making aligns well with the requirements of this skill. Furthermore, athletic trainers regularly work under the supervision of physicians and within multidisciplinary teams, which provides a strong framework for oversight and collaboration in care.

Allowing ATs to perform dry needling expands access to timely, effective treatment—particularly in school-based, collegiate, and sports medicine settings where athletic trainers are often the first-line providers. The proposed regulation appropriately includes educational and competency standards to uphold patient safety, which is paramount.

From my dual perspective as both a PT and ATC, I can confidently say that this is a safe, logical, and progressive step forward for the athletic training profession and the patients we serve.