I strongly oppose 18 VAC 85-120 due to serious public safety concerns.

Allowing undertrained practitioners to perform filiform needling increases the risk of complications such as infection, nerve injury, pneumothorax, and misdiagnosis.

Redefining this invasive technique under a separate regulatory banner creates confusion for patients and providers alike, undermining transparency, informed consent, and public trust.

Lastly, filiform needling is acupuncture in both method and effect, regardless of whether it is called “dry needling” or “trigger point therapy.” This amendment unjustly encroaches on the scope of licensed acupuncturists and weakens established professional standards at the expense of patient safety. 

Respectfully submitted,

Joyce Kawalchuk