As we continue the important dialogue regarding the proposed amendment to permit Board-Certified Athletic Trainers to perform the modality of dry needling, it is essential to address and clarify several points raised in opposition.

• Athletic Trainers Are Not Personal Trainers: Certified athletic trainers complete a minimum of six years of higher education through university-based, nationally accredited programs. Their education follows a rigorous, competency-based approach that integrates both classroom instruction and clinical experience. Utilizing a medical-based educational model, certified athletic trainers are trained to deliver comprehensive patient care across five key domains of clinical practice:

1. Risk Reduction, Wellness, and Health Literacy
2. Assessment, Evaluation, and Diagnosis
3. Critical Incident Management
4. Therapeutic Intervention
5. Healthcare Administration and Professional Responsibility

Coursework includes advanced studies in anatomy, physiology, nutrition, therapeutic modalities, orthopedic assessment, and therapeutic exercise. In addition, students complete hundreds of hours in diverse clinical settings, ensuring they graduate with extensive hands-on experience and the skills necessary to support a wide range of patient populations.

• Training in Invasive Procedures: Accredited athletic training programs, overseen by the Commission on Accreditation of Athletic Training Education (CAATE), require training in sterile technique and invasive procedures. This includes intravenous (IV) administration, wound closure using sutures and staples, and lidocaine injections. These competencies have been formally recognized and approved by overwhelming majorities in both chambers of the Virginia General Assembly in 2023.
• Virginia Board of Medicine Licensed: Code of Virginia §54.1-2900
• Public Health Precedent During COVID-19: During the COVID-19 pandemic, the Governor of Virginia, executive order number 51, authorized athletic trainers to administer COVID vaccinations—a needle-based medical procedure—based on their foundational education and with clinical training, that did conclude June of 2021.  This authorization was not extended to acupuncturists, underscoring the difference in the Commonwealth’s recognition of clinical competence.
• Dry Needling vs. Acupuncture: Dry needling, a technique rooted in Western medicine and focused on musculoskeletal trigger points, differs fundamentally from acupuncture, which is based on Eastern medicine and meridian theory. Acupuncturists’ licensure documentation defines their practice under these Eastern philosophies. If some within the acupuncture profession now claim dry needling as their own, this calls for a reassessment of their scope of practice, as it may contradict their originally defined licensure.
• States that Allow Athletic Trainers to Practice Dry Needling:
• Alabama
• Arizona
• California
• Connecticut
• Maryland
• Florida
• Georgia
• Illinois
• Iowa
• Support from Diverse Medical Professionals: In reviewing public comments, a clear distinction emerges. Opposition to the amendment is largely from those within the acupuncture profession. In contrast, support for the athletic trainer comes from a broad range of healthcare professionals, including physicians, physical therapists, academic leaders, and hospital administrators. This multidisciplinary support reflects the confidence and trust the medical community places in the education, skills, and professionalism of board-certified athletic trainers.
• Grounded in Fact: The points presented above are not merely opinions—they are grounded in objective facts: the rigor of educational programs, regulatory recognition of clinical competencies, and professional endorsements from within the Commonwealth's healthcare system.

While public discourse naturally invites differing viewpoints, I trust that the decision-makers will weigh the evidence carefully.