As a Doctor of Acupuncture and Chinese Medicine and Licensed Acupuncturist, I strongly oppose 18VAC85-120-110. Virginia state will cause the citizens of Virginia a great risk when letting uneducated, untrained and unskilled persons insert acupuncture needles. We, acupuncturists, should complete at least 3000 hours in didactic and clinical training and after that, in order to obtain the license, must pass multiple national board certification exams, not to mention that 60 hours of high level of continuing education should be completed to hold the license status. 

Allowing athletic trainer who do not obtain this complex knowledge of medical therapy will bring harms to Virginia residents, and this will diminish the true value of Acupuncture and potentially destroy the credibility of Licensed Acupuncturists. 

As practicing in the state of New Jersey and New York, I already have treated numerous patients who have been injured by physical therapists, who used Dry Needling without proper acupuncture training, only to complete a few certification course. 

Currently, the Federal Law states that acupuncture needles are FDA regulated medical devices and should only be used by properly educated, trained and licensed acupuncturists. Dry needling IS acupuncture. 

Please consider my opposition regarding to this amendment. This proposal threatens public safety, increases risk and liability to the Board of Medicine, and undermines the rigorous education and licensure standards that licensed acupuncturists must meet and are enacted by Virginia Law and regulations.