I’m writing to express my strong opposition to the proposed amendment to 18VAC85-120-110, which would allow athletic trainers to perform dry needling.

Dry needling is acupuncture. Calling it something else doesn’t change the fact that it involves inserting needles into the body, an invasive procedure that requires in-depth knowledge, clinical judgment, and extensive hands-on training to perform safely. Athletic trainers simply do not receive the level of education in anatomy, physiology, pathology, and needling technique that licensed acupuncturists are required to complete under the Virginia Board of Medicine.

As a licensed acupuncturist, I completed over 3,000 hours of rigorous training that included in-depth studies of anatomy, physiology, needle technique, and supervised clinical practice—all essential to minimizing risks like infection, nerve damage, or organ puncture. In contrast, some dry needling courses for athletic trainers require as little as 25 hours of instruction. That’s a staggering difference in preparation for an invasive procedure. The gap in training raises serious concerns about safety and clinical competency.

This amendment doesn’t just put public safety at risk, it also opens the door for other professions to claim privileges without the necessary training. Our regulatory standards exist to protect patients, and this proposal undermines them.

Please reject this amendment. It’s not safe, it’s not sound, and it does a disservice to both the public and the health professions governed by the Board.