Athletic trainers have zero training on invasive procedures and how to mitigate the harm that invasive procedures can create. Even M.D.s who are trained to perform surgery and use hypodermic needles are required to complete several hundred hours in a nationally approved training program, followed by hundreds of hours of hands on clinical practice and a national board exam before adding this procedure to their scope of practice.

In addition to standard anatomy and physiology coursework that is common to many healthcare professions, acupuncturists complete a full course specific to needling/surface anatomy which is on its own twice the entire training requirement this bill would require. They additionally must complete training on the prevention of infections, both through a course in their schooling and through a national training program followed by national written and practical exams. These are in addition to the series of board exams that licensed acupuncturists are required to complete, the hundreds of hours of hands on training in safe needling, and the hundreds of hours of clinical experience needling patients that must be completed in a nationally accredited training program.

By contrast athletic trainers are asking to be permitted to perform this procedure with nothing more than an unaccredited certification that can be completed in a single weekend with no oversight or national certification ensuring even the most basic standards are met. These papermill programs do not sufficiently train athletic trainers to be safe and competent in the performance of this procedure and endorsing their practice of this procedure with such alarmingly insufficient training endangers the public.

Research has shown that while licensed acupuncturists cause serious adverse events at a rate of 0.08 per 10,000 treatments (https://pubmed.ncbi.nlm.nih.gov/34489268/) physical therapists and athletic trainers performing this procedure cause serious adverse events at a rate of 9.77 per 10,000 treatments (https://pmc.ncbi.nlm.nih.gov/articles/PMC7015026/), over 100 times more frequent. For a provider performing this procedure full time that is the difference of more than one serious incident per year versus less than one in an entire career for those with proper training. The most common serious adverse events include causing infections and puncturing vital organs. These are preventable events with proper training, but athletic trainers do not currently receive the training necessary to prevent them, and athletic trainers should not be permitted to perform this procedure until they have received the hundreds of hours of training necessary to bridge the gap between their schooling and the skills necessary to perform this invasive procedure safely.

Dry needling, or trigger point needling, is a specific technique within acupuncture under a category of acupuncture techniques called "ashi" needling. It is a procedure that is performed with acupuncture needles in the same way and for the same purpose as a licensed acupuncturist would do. While some outside the acupuncture profession may misunderstand it as being separate from acupuncture, it is an acupuncture technique originally taught to medical doctors by acupuncturists that spread to other professions thereafter. It is not separate from acupuncture but rather a small part of what acupuncturist might do within a treatment. When patients experience this treatment they understand that it is acupuncture no matter how it might be rebranded or labeled. When an athletic trainer causes an adverse event, even a minor one, the patient walks away associating that adverse event with acupuncture and then avoids receiving proper care from a fully trained acupuncturist.

Patients depend on their legislators to ensure those being permitted to perform medical procedures are properly trained to perform them safely and effectively. By permitting athletic trainers to perform this procedure without any training on invasive procedures in their education and with only a brief exposure to the topic in a papermill certification course with no oversight, the standard of care is being greatly reduced and patients are being unnecessarily put in harm's way. While I have actively supported other professions such as medical doctors and chiropractors adding this procedure to their scope of practice with proper training, the horrifyingly insufficient training that this bill would require has me asking you to please oppose this bill for sake of patients in Virginia.