I very strongly oppose the amendment to 18VAC-85-120-110.  Dry needling is an invasive technique that should only be qualified by trained, licensed acupuncturists. Allowing athletic trainers to do this without equivalent training is a serious risk to public safety. 

Acupuncturists have over 1900 hours of training in needling technique, clean needle safety, and supervision by Licensed Acupuncturists. In my training as an acupuncturist, I have over 500 hours of training in western medicine in areas such as internal medicine, gynecology, pediatrics, orthopedics, neurology, and psychiatry. Does this qualify me to practice western medicine in any of these areas? Of course not. And neither will the short course in dry needling for Athletic trainers qualify them to safely and effectively insert needles into their clients. I have had numerous patients come to my office stating that they had dry needling by someone other than a LAc., and it was painful and/or didn't work. 

I respectfully urge the Board to deny this amendment.