Commenter:
Illinois Society of Acupuncturists- ILSA
Illinois Society of Acupuncturists opposition to the proposed amendment to 18VAC85-120-110
The Illinois Society of Acupuncturists (ILSA) strongly supports the Acupuncture Society of Virginia (ASVA) in opposing the proposed amendment to 18VAC85-120-110, which seeks to expand the scope of practice for Athletic Trainers to include dry needling.
Dry needling is an invasive procedure that involves inserting acupuncture needles into soft tissue. Regardless of what it is called, this is acupuncture—an advanced medical intervention requiring rigorous education in anatomy, physiology, pathology, and clean needle technique, as taught comprehensively in accredited acupuncture and East Asian medicine programs.
Our concern is not theoretical—it is grounded in experience. Although Illinois permits Athletic Trainers to perform dry needling, they have never been in compliance with any formal educational requirements or competency examinations to ensure safe and effective practice. There is no evidence of adherence to national standards, no established pathway for proper certification, and no enforcement mechanisms in place. Despite this, the practice continues unchecked—putting public safety at risk and undermining professional standards. In fact, IL compliance entails meaningful educational and clinical competency benchmarks that would require an additional 6 months to 1 year of specialized training—training that is simply not part of their existing curriculum nor do they have the intent to comply further showcasing the lack of intention for patient safety and quality control.
We urge the Virginia Board of Medicine to reject this amendment and to uphold the integrity and safety of invasive medical procedures like dry needling.