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 in-depth knowledge , specialized clinical training, to develop the safety needling technique as a licensed acupuncturist. 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 Board of Medicine, and undermines the rigorous education and licensure standards that licensed acupuncturists must meet and are enacted by Virginia Law and regulations.
I urge the Board to reject this amendment and uphold the standards that ensure only properly trained professionals are permitted to perform dry needling.