I am writing to express my strong opposition to the proposed amendment that would permit athletic trainers to perform dry needling (DN). This is a matter that deserves thoughtful and thorough consideration, as it directly impacts patient safety and the integrity of healthcare standards in the Commonwealth of Virginia.

Dry needling is an invasive procedure that requires in-depth training in anatomy, physiology, differential diagnosis, and needling techniques. Licensed professionals who currently perform DN undergo rigorous education and clinical instruction to ensure safe and effective care. Allowing athletic trainers—whose educational programs do not include invasive procedures—to perform DN after significantly limited training raises serious concerns. It lowers the threshold of clinical competence and risks undermining public confidence in our healthcare system.

It is also important to note that dry needling is not part of the Board examination for athletic trainers, nor is it included in standardized licensing requirements for their profession. Their training primarily focuses on non-invasive musculoskeletal support and rehabilitation—not on procedures that involve penetrating the skin and interacting with deep anatomical structures.

In contrast, licensed acupuncturists in Virginia must complete over 2,000 hours of training, including substantial hands-on experience in needling, and earn at least a Master’s degree. Even chiropractors—though permitted to perform DN with comparatively fewer needling hours—have comprehensive academic and clinical preparation in anatomy and diagnosis, which athletic trainers do not.

Expanding the scope of practice in this way, without equivalent educational and clinical requirements, poses a tangible risk to patient safety and sets a concerning precedent for lowering regulatory standards without adequate evidence or justification.

For these reasons, I respectfully urge the Board to reject this amendment. Doing so will help preserve the safety of Virginia’s residents, uphold professional standards, and maintain the public’s trust in our healthcare system.

Thank you for your time and thoughtful consideration.