I am firmly against the proposed amendment to 18VAC85-120-110. Dry needling is a complex and invasive procedure that should only be performed by licensed acupuncturists with specialized training. Allowing athletic trainers to perform this technique without the same level of education poses a significant risk to public safety.

As a licensed acupuncturist, I have completed more than 1,900 hours of comprehensive education in anatomy, needle technique, clean needle protocols, and supervised clinical work. Athletic trainers do not receive equivalent training, and expanding their scope in this way is both unsafe and unjustified. I respectfully urge the Board to reject this amendment.