To the Virginia Board of Medicine:

I write to express my strong opposition to any proposed regulation that would permit athletic trainers to perform dry needling in the Commonwealth of Virginia.

Dry needling is acupuncture by another name, involving the insertion of solid filiform needles into the body to treat pain and dysfunction. Despite semantic distinctions, dry needling uses acupuncture needles and engages with anatomical structures in ways that mirror traditional and biomedical acupuncture approaches. Allowing athletic trainers—whose education and training in needling is vastly inadequate compared to licensed acupuncturists—to perform this invasive procedure presents serious public safety risks and economic harm to the acupuncture profession.

1. Safety and Training Concerns

Licensed acupuncturists in Virginia undergo thousands of hours of education and at least hundreds hours of supervised clinical training. In contrast, athletic trainers advocating for dry needling privileges often complete short weekend seminars with minimal or no clinical oversight. This is profoundly inadequate for a technique that involves penetration of the skin and can risk pneumothorax, nerve injury, infection, and vascular damage when performed improperly.

There are documented cases of serious adverse events—including lung collapse—associated with dry needling performed by undertrained individuals. The Board's primary mandate is to protect public health and safety, and authorizing inadequately trained individuals to conduct invasive procedures contradicts that duty.

2. Economic and Professional Impact

The acupuncture profession is a regulated, licensed healthcare discipline with stringent educational and national certification requirements. Allowing athletic trainers—who are not required to undergo the same rigor—to perform needling devalues the profession and creates unfair economic competition. Acupuncturists invest significantly in their education and licensing; diluting the value of this training by opening invasive needling practices to those without comparable education undermines the integrity of the profession and threatens its sustainability.

Moreover, this move sets a dangerous precedent for scope-of-practice creep, where other professions may seek expanded privileges without requisite training, further destabilizing professional boundaries and public trust.

Conclusion

I urge the Virginia Board of Medicine to prioritize patient safety and uphold the standards of professional medical care by rejecting any proposal that would allow athletic trainers to perform dry needling. Doing so would not only compromise public safety but would also economically and professionally harm the acupuncture community in Virginia.

Respectfully submitted,

Dr. Justin Flinner, DAc, LAc, DiplAc