As an advocate for high standards of patient care and professional competency, I am writing in support of the petition to amend 18VAC85-120-110 to allow licensed athletic trainers to perform dry needling with special training and physician oversight.

Dry needling is an established technique of managing musculoskeletal pain and dysfunction through the insertion of thin filiform needles into trigger points and connective tissue. It is founded on Western biomedical concepts and has a growing evidence base. It is distinct in theory and practice from acupuncture, which is founded on Traditional Chinese Medicine (TCM) concepts and the movement of energy along meridians.

Athletic Trainers Are Highly Qualified

Athletic trainers (ATs) are nationally certified and state-licensed allied health professionals who receive intensive education by CAATE-accredited programs. This includes masters-level education in anatomy, physiology, injury diagnosis, and therapeutic interventions just to name a few. Most programs also include hands-on experience in invasive procedures such as IV administration, wound closure, and the use of injectable, local anesthetics during more uncomfortable procedures. These competencies are already recognized under Virginia law, which has acknowledged the clinical readiness of athletic trainers in related procedures.

Research has shown that the majority of foundational knowledge and clinical competencies required for the safe and effective application of dry needling are already included in the educational coursework to become certified in athletic training. This solid educational foundation readies ATs for structured post-professional education in dry needling, contrary to arguments of inadequate "weekend course" preparation. With appropriate continuing education and physician supervision, ATs are well-positioned to safely and effectively incorporate dry needling into patient care.

Addressing Misconceptions about Scope and Safety

While I appreciate the concern expressed by members within the acupuncture community, it is important to delineate that dry needling, as performed within a Western biomedical model, is not TCM or traditional acupuncture. Athletic trainers are not claiming the right to practice acupuncture, and I strongly oppose such misrepresentation. ATs simply want to utilize a treatment modality within their practice set of musculoskeletal evaluation, rehabilitation, and performance enhancement.

Patient safety issues must be taken into account for any invasive procedure, and I applaud those on this forum who are putting that at the forefront. These concerns can and should be addressed through the establishment of overt training requirements, standardized continuing education, scope of practice limitations, and physician supervision. Such safeguards already exist for other professions, including physical therapists, who have successfully and safely incorporated dry needling into practice. There is no reason that athletic trainers cannot meet those same standards for the incorporation of this modality into our practice.

Broad Precedent and Multidisciplinary Support

Athletic trainers in a number of states, including Florida, North Carolina, Georgia, Illinois, Maryland, and Iowa, have been authorized to practice dry needling following appropriate training. This policy shift highlights the increasing recognition by legislators, regulatory bodies, and healthcare organizations that dry needling, when performed by trained athletic trainers, is both safe and effective.

Furthermore, public endorsement of this amendment within this forum has come from a wide range of healthcare professionals including physicians, physical therapists, chiropractors, and academic leaders in the field. Such widespread endorsement speaks volumes to the trust in athletic trainers' clinical skill and collaborative practice. Opposition to this amendment has largely come from within the acupuncture community, often based on philosophical differences or scope protection, not necessarily concerns grounded in objective risk or training deficiencies.

It is also important to point out that allowing multiple professions to share the same tools does not dilute the identity or integrity of any single discipline. As with other areas of healthcare, such as joint manipulation, exercise prescription, or therapeutic taping/wrapping, qualified practitioners from multiple disciplines can safely share these techniques when supported by adequate training and supervision.

Improving Access and Patient Outcomes

Dry needling is a time-sensitive treatment that can reduce pain, restore mobility, and expedite return to activity, particularly in athletes and the physically active population. ATs are on the front lines of care in these high-demand environments such as collegiate athletics, professional sports, and orthopedic clinics. Delaying treatment due to referral limitations or interprofessional silos can result in prolonged dysfunction, higher costs of care, and unnecessary burden on patients

Likewise, permitting ATs to perform dry needling under a physician's supervision facilitates earlier access to treatment, reduces unnecessary referrals, and permits appropriate allocation of resources throughout the healthcare system. It also promotes continuity of care because athletic trainers are often the lead provider coordinating an athlete's rehabilitation plan.

A Collaborative Path Forward

Expanding access to dry needling under a structured and regulated framework does not devalue the practice of acupuncture or any other profession. It only acknowledges the evolving needs of our patients and those professionals who work with them. Virginia has already demonstrated its trust in the clinical abilities of athletic trainers, including during the COVID-19 pandemic when ATs were authorized, with physician oversight, to administer vaccines under VA Executive Order 51. That same level of trust, along with sound guidelines and standards, should be applied here today.

I urge the Virginia Board of Medicine to support this petition with careful attention to training, safety, and collaboration across disciplines. By doing so, the Commonwealth can ensure that patients receive timely, effective, and evidence-based care from the qualified professionals best equipped to deliver it.

Thank you for your time and consideration.

- Lauren Morris, MS, LAT, ATC