I am writing to express strong opposition to the proposed amendment to 18VAC85-120-110, which would permit athletic trainers to perform dry needling.

Dry needling is an invasive procedure that requires a licensed acupuncturist with in-depth knowledge, specialized clinical training who has well-developed the safe needling techniques. Insufficient education and training will cause potential complications such as infection, nerve damage, or pneumothorax.

This proposal threatens public safety, increases risk and liability to the practice of medicine, and undermines the rigorous education and licensure standards enacted by Virginia Law and regulations, which licensed acupuncturists must meet.

I urge the Board to reject this amendment and uphold the standards that ensure only properly trained professionals are permitted to perform dry needling.