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]
Previous Comment     Next Comment     Back to List of Comments
4/30/25  1:03 pm
Commenter: Kelly Meyer

Opposing the Expansion of Dry Needling to Athletic Trainers in Virginia
 

As a concerned practitioner and advocate for safe, effective patient care, I strongly oppose any efforts to allow athletic trainers or other healthcare professionals without formal acupuncture training to perform dry needling.

Acupuncture is not a technique—it is a comprehensive medicine. Licensed acupuncturists complete a minimum of four years of rigorous, graduate-level education focused on anatomy, physiology, needling technique, safety, diagnosis, and the principles of East Asian medicine. This extensive training ensures that needling is performed with precision, care, and clinical insight.

Dry needling, often described as a musculoskeletal intervention, is essentially acupuncture stripped of its foundational context and depth of training. While the terminology may differ, the physical act of inserting needles into the body remains the same—and so do the risks. Practitioners without the appropriate education are not equipped to recognize potential complications or ensure the safety of their patients.

Allowing athletic trainers to perform dry needling undermines public safety and the integrity of acupuncture as a profession. It sets a dangerous precedent for allowing invasive procedures without adequate education. Needling the human body without the proper clinical background can lead to serious harm, including nerve damage, pneumothorax, and infection.

We urge the regulatory board to protect the public and uphold the standards of professional healthcare by requiring that any use of filiform needles—including dry needling—be restricted to licensed acupuncturists who have completed the necessary education and clinical training.

Thank you for your time and attention to this critical matter.

As a concerned practitioner and advocate for safe, effective patient care, I strongly oppose any efforts to allow athletic trainers or other healthcare professionals without formal acupuncture training to perform dry needling.

Acupuncture is not a technique—it is a comprehensive medicine. Licensed acupuncturists complete a minimum of four years of rigorous, graduate-level education focused on anatomy, physiology, needling technique, safety, diagnosis, and the principles of East Asian medicine. This extensive training ensures that needling is performed with precision, care, and clinical insight.

Dry needling, often described as a musculoskeletal intervention, is essentially acupuncture stripped of its foundational context and depth of training. While the terminology may differ, the physical act of inserting needles into the body remains the same—and so do the risks. Practitioners without the appropriate education are not equipped to recognize potential complications or ensure the safety of their patients.

Allowing athletic trainers to perform dry needling undermines public safety and the integrity of acupuncture as a profession. It sets a dangerous precedent for allowing invasive procedures without adequate education. Needling the human body without the proper clinical background can lead to serious harm, including nerve damage, pneumothorax, and infection.

We urge the regulatory board to protect the public and uphold the standards of professional healthcare by requiring that any use of filiform needles—including dry needling—be restricted to licensed acupuncturists who have completed the necessary education and clinical training.

Thank you for your time and attention to this critical matter.

Sincerely, 

Dr. Kelly Meyer DACM

CommentID: 234020