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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5/2/25  4:11 pm
Commenter: Licensed Acupuncturist

Strongly Oppose
 

Dry needling is another term for orthopedic acupuncture. Only licensed acupuncturists should be performing this invasive medical procedure, as they have received 2,000-3,000 hours of needle training in a graduate level program and passed several national board exams for state acupuncture licensure. Athletic Trainers are not in a profession that has historically included the use of needles and allowing them to perform dry needling with minimal training in a weekend workshop/continuing education course puts the general public at risk. If Medical Doctors are required 300 hours of acupuncture training for a certification in medical acupuncture before they are allowed to perform acupuncture, what is the logic in allowing Athletic Trainers to dry needle and essentially perform a style of orthopedic acupuncture without the same hours or more of training and licensure requirements as doctors? Dry needling and the re-branding of acupuncture to expand scope of practice within other allied health professions without acupuncture licensure and proper adequate training is a public health issue and needs to be stopped. 

CommentID: 234173