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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4/16/25  7:37 pm
Commenter: Thien V

Opposition for AT's to do DN
 

As a licensed massage therapist and current student of acupuncture with extensive training in anatomy, physiology, and patient care, I strongly oppose allowing anyone other than licensed acupuncturists or medical doctors to perform needling procedures that involve penetrating the skin to alleviate pain.

Acupuncturists undergo thousands of hours of rigorous training—not just in needle technique, but in comprehensive diagnostics, channel theory, clean needle technique, patient safety, and clinical judgment. These are not skills that can be sufficiently learned in a weekend seminar or short-term course. If practitioners from other fields wish to incorporate needling, they should be required to complete a level of education comparable to that of licensed acupuncturists, ideally taught by experienced acupuncturists themselves.

While acupuncture is about more than just inserting needles, it’s undeniable that our identity and scope are often reduced to “needling” in public perception. Because of this, allowing other professions to utilize invasive needling techniques without equivalent training not only puts patient safety at risk, but also undermines the legitimacy and value of the acupuncture profession.

This concern is not hypothetical—there is documented risk associated with dry needling when performed by non-acupuncturists. Pneumothorax, a potentially life-threatening condition in which air enters the pleural space and causes a collapsed lung, has been reported in multiple cases involving dry needling by physical therapists or athletic trainers:

In fact, I have a client who personally experienced this. They received dry needling from a non-acupuncturist and suffered a pneumothorax as a result. This is not just a theoretical risk—it’s a real harm I’ve witnessed firsthand, and one that could have been prevented with better training and regulation.

In contrast, acupuncture has an extremely low incidence of pneumothorax when performed by licensed acupuncturists:

These statistics, alongside personal experience, clearly show that patient safety is compromised when needling is performed by individuals with minimal training. If we are going to expand therapeutic options, we must ensure they are grounded in appropriate education and clinical experience.

I understand the desire to integrate needling into broader healthcare practices. However, if we are going to branch out, we should still honor and protect the root. Let’s preserve the integrity of this powerful medicine and ensure that any use of needles for therapeutic purposes is carried out with the highest level of education, safety, and respect.

CommentID: 233732