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 uses Acupuncture needles. Visually you could not differentiate two of them when these two treatments are performed. Drying needling also called as trigger point acupuncture in other countries. We should not allow Sports trainer to do dry needling because there is no such a way to identify whether he is doing Acupuncture or not. If we allow, then all sports trainer could perform Acupuncture without Acupuncture license, which requires a professional post graduate degree and 3600 clinical hours. 

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.