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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4/24/25  9:56 pm
Commenter: Dr. Raven Seltzer, Back to Balance Wellness

The safety of the general public is at stake here.
 

I'm very upset and surprised to see this legislation up for consideration in your great Commonwealth of Virginia. It is quite unreal that you are actually considering placing needles in the hands of people who are not educated, trained or licensed as acupuncturists, and then setting them loose on athletes and other members of the community?! This is negligent at best.

We have a national certification organization (NCCAOM) which protects our education standards AND the general public through the administration of 3-4 national board exams -- these are required, post-Master's degree and pre-licensing. We also have State Associations which oversee our licensing rules and procedures.

Any athletic trainer who is truly interested in using acupuncture needles and giving "treatments" to their clients, is more than welcome to apply to and enroll in an accredited university/college program in order to begin their journey towards a degree and license in acupuncture, but they should not be allowed to take this massive SHORT CUT which puts the general public at risk and gives a false experience of "acupuncture" and "dry needling.:" 

As a doctor of acupuncture, I trained for 6 years and was required to log over 2,000 initial clinical hours seeing patients in hospital and community health care centers, under a supervisor's watchful eye. Before any of us students were allowed to use needles on patients in our school clinics, we had to have 1.5 to 2 years of training which included clean needle technique, point location, anatomy and physiology, biomedicine, actions and effects of the acupuncture points, foundations of Chinese medicine, and so much more. 

Dry needling is not that different than what we do. The physical therapists use acupuncture needles to deliver trigger point therapy. Though some training is required for PT's, I can tell you that I've seen many patients over the last 10 years who were injured through dry needling: patients with punctured lungs, kidneys, knicked sciatic nerves -- all because the PT's did not know enough about internal medicine and didn't know at what depth to insert the needles and at what depth to stop. And these injuries came from PT's with training. 

Again, I see this bid for athletic trainers to now have the right and privilege of sticking needles in other humans and I am completely puzzled as to why this is even being entertained as an idea that is "good"??

Please contact our national organization, NCCAOM, for more information on the kind of education and standards that should be required for ANYONE wanting to administer acupuncture needles to their clients or patients.

Thank you for your consideration in this matter.

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