I strongly oppose the proposed amendment to 18VAC85-120-110 that would allow athletic trainers to perform dry needling.

Dry needling is acupuncture—rebranded, stripped of context, and dangerously oversimplified. Athletic trainers do not receive anywhere near the extensive, medically grounded training in needle technique, anatomy, and patient safety that licensed acupuncturists are required to complete. This amendment undermines public safety by granting invasive procedural privileges to individuals without sufficient education or clinical oversight.

As a licensed acupuncturist, I completed thousands of hours of supervised clinical training and coursework over several years to ensure competent, safe, and effective patient care. Allowing athletic trainers to insert needles into patients with just a fraction of that training not only endangers the public but devalues the integrity of health professions regulated by the Virginia Board of Medicine.

This proposal also sets a dangerous precedent, inviting other professions to bypass established medical training pathways and dilute standards of care. For the safety of Virginia residents and the future of responsible healthcare practice, I urge you to reject this amendment in full.