I strongly oppose the proposed amendment to 18VAC85-120-110. This proposal poses a significant threat to public safety, undermines the integrity of our profession, and diminishes the rigorous education and licensure standards that licensed acupuncturists are required to meet.

Allowing individuals without the necessary comprehensive training and expertise to perform procedures such as dry needling jeopardizes patient safety. Licensed acupuncturists undergo extensive education, including thousands of hours of training in anatomy, physiology, and safe needle techniques. These standards are in place to ensure that patients receive the highest quality of care and to minimize the risk of harm.

Furthermore, the use of needles in healthcare requires a profound understanding of the underlying dynamics of how a needle interacts with the body. This includes knowledge of acupuncture points, meridians, and the subtle effects on physical and energetic systems. Only licensed acupuncturists possess the extensive training necessary to safely and effectively use needles for therapeutic purposes. Allowing untrained individuals to perform such procedures risks causing unintended harm and undermines the trust placed in our profession.

This proposal not only endangers patients but also devalues the dedication and professionalism of licensed acupuncturists. It sets a concerning precedent by allowing individuals with significantly less training to perform complex procedures, which could lead to a decline in the overall quality of care provided to the public.

I urge the Board to reject this proposal and to uphold the rigorous standards that protect both the public and the integrity of our profession.