Dear Members of the Virginia Board of Medicine,

As a licensed acupuncturist, I respectfully urge you to oppose the proposed changes to 18VAC85-120-110, which would allow Athletic Trainers to perform dry needling.

Dry needling is an invasive technique that involves inserting acupuncture needles into muscle tissue. Despite its different name, it is fundamentally acupuncture and should be held to the same standards of safety and training.

Licensed acupuncturists undergo over 3,000 hours of training, including in-depth education in anatomy, physiology, pathology, clean needle technique, and supervised clinical practice. In contrast, athletic trainers often receive only a few hours of needling instruction, which is insufficient for safe practice.

Allowing this proposal to pass would:

• Endanger patient safety, increasing risks of complications such as pneumothorax and nerve damage;

• Weaken public trust in regulated healthcare professions;

• Overburden the Board with the responsibility for supervising undertrained practitioners in invasive procedures.

This change disregards the intent of existing Virginia laws that require strict education and licensure standards for acupuncture. It sets a dangerous precedent and threatens the safety and wellbeing of our communities.

I urge the Board to protect public health and uphold professional standards by rejecting this proposal.