I am writing to oppose the above captioned proposal regarding the regulations governing the licensure of athletic trainers to add acupuncture (aka dry needling) to their scope of practice. Athletic trainers are currently licensed under the Board of Medicine in Virginia, as are Licensed Acupuncturists, and I was in the room during multiple athletic trainer advisory board meetings wherein this topic was proposed. At the time, it was strongly encouraged by the Board of Medicine that athletic trainers go through a legislative process rather than a regulatory one to fully take into account what such a change might mean in terms of protecting the public. While I am appreciative of the enthusiasm for the treatment modality of acupuncture by athletic trainers, and while I also appreciate the many benefits that athletic trainers provide to their clients, it needs to be stated again that there is STILL no standardized training or competency requirements for athletic trainers (or any other practitioner save licensed acupuncturists) to provide acupuncture / dry needling within the Commonwealth of Virginia. Dry needling can be taught in as little as a weekend by for-profit companies that bear no responsibility for what happens to that practitioner after that weekend course. This is absurd, no matter the quality of the training. I do not understand why the Board of Medicine has failed to require any standardization for this treatment modality to date, given that there are clear guidelines and definitions for acupuncture training going back to when licensed acupuncturists were first given licensure in Virginia. I have been in practice for over 20 years, largely working with musculoskeletal issues, and am not here to debate who can wield an acupuncture needle more efficiently for the benefit of a positive patient outcome. I am here to oppose 18 VAC 85-120 because the regulatory boards under purview of the Virginia Department of Health Professions need to do their due diligence to standardize language and training / certification requirements respective to invasive medical procedures such as acupuncture (aka dry needling) before allowing another profession to add this  needling modality to their scope of practice. I hope that the Board of Medicine will thoughtfully consider adding more precise education and certification requirements before this proposed regulation advances any further. Thank you.