Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Licensure of Athletic Trainers [18 VAC 85 ‑ 120]
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4/30/25  7:47 am
Commenter: Dr. Jodi Knauer, D.Ac., L.Ac, Dipl.Ac.

Strongly Oppose AT perfoming Dry Needling
 

Dry Needling is Acupuncture. It is internal medicine using a surgical type instrument that penetrates the skin to affect physiological changes in the body both locally and distally.

Dry Needling has been renamed from acupuncture to bypass existing laws, rules and regulations. Dry Needling is the same as Acupuncture Physical Medicine or Trigger Point Acupuncture.

I have seen first hand the result of dry needling done by improperly trained non-acupuncturists. These results include nerve injuries, systemic infections, mental and physical trauma and life threatening pneumothoraxes requiring ED hospitalizations when non-acupuncturists with minimal training, no standardized testing or evaluation use dry needling as an add-on to their practices to an unaware public.

If the goal is to increase hospitalizations in Virginia, increase lawsuits for medical malpractice for inadequately trained providers and burden doctors and nurses in our hospitals with preventable injuries then by all means, pass this bill.

Why do educational requirements, national board exams and standards exist if this not standard for all medical professionals performing acupuncture/dry needling in the commonwealth of Virginia? As medical professionals we are all sworn to first do no harm. This bill will cause harm to the public.

For the safety of the public in Virginia, I strongly oppose a profession with minimal training bypassing basic standards of education that are required for acupuncturists, medical doctors and chiropractors to practice any invasive procedure using a surgical filiform needle.

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