Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Licensure of Athletic Trainers [18 VAC 85 ‑ 120]
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5/7/25  11:46 am
Commenter: Peter Liebenthal L.Ac.

Strongly oppose!
 

I strongly oppose the amendment to 18VAC85-120-110. Dry needling is an invasive technique that should only be performed by trained, licensed acupuncturists. Acupuncture is a very safe modality when practiced by licensed acupuncturists. Dry needling is certain, aggressive style of acupuncture, that should only be practiced by licensed acupuncturists.Allowing athletic trainers to do this without equivalent education is a serious risk to public safety.

I’ve spent over 2,000 hours studying anatomy, needle technique, clean needle safety, and supervised clinical practice to become a licensed acupuncturist. Granting dry needling privileges to athletic trainers, who do not undergo similar training, is dangerous and irresponsible. I have heard from Physical therapists that they are able to practice dry needling after taking a single weekend course on it. I strongly urge the Board to deny this amendment.

I’ve treated patients injured by unqualified dry needling-2 patients of mine had their lungs punctured by dry needling. In order to safely needle people, one needs training not only in the anatomy of the musculoskeletal system, but also on the location of the internal organs. The lungs are close to the surface and based on my experience with my patients getting their lungs punctured by dry needling, some of those who practice dry needling do not thoroughly understand the location of the Lungs. Please don’t lower Virginia’s standards. Protect our communities by keeping dry needling within the scope of licensed acupuncturists.



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