As a licensed Doctor of Acupuncture and Chinese Medicine, I strongly oppose the proposed amendment to 18VAC85-120-110, which would allow athletic trainers to perform dry needling.

Dry needling is, in essence, acupuncture—an invasive procedure involving the insertion of needles into the body. Licensed acupuncturists in Virginia undergo a minimum of 1,900 hours of comprehensive training, including extensive supervised clinical practice, to ensure patient safety and effective treatment.

In contrast, athletic trainers receive significantly less training in this area. For example, some dry needling certification courses for athletic trainers offer as few as 27 hours of instruction . This disparity in training raises serious concerns about the safety and efficacy of allowing athletic trainers to perform such procedures.

Allowing individuals with minimal training to perform dry needling not only compromises patient safety but also undermines the rigorous standards established for healthcare professionals. I urge the Board to reject this amendment to protect public health and maintain the integrity of our healthcare system.

Sincerely,
Dr. Deirdre Corrigan, DTCM, LAc, LMT
Boulder, Colorado