I oppose the proposed amendment to 18VAC85-120-110, which would allow athletic trainers to perform dry needling.  Dry needling is a misnomer for a small piece taken from the umbrella of Chinese Medicine, which should only be under the auspices of those fully trained in the art. This atrocity is being done by people who see acupuncture as nothing more than putting a needle into tissue, where in fact there is an entire system of understanding developed over 5,000 years that is best administered by a practitioner who is fully trained and possesses a Masters or Doctoral Degree in Chinese Medicine.  It is a known fact that different point combinations can have profound effects on the body’s chemistry.  To properly treat an individual one needs to be able to discover their exact energetic imbalance and do a complete evaluation to receive the desired effect, it is not solely about putting needles into muscles and tendons, which is sadly a gross misunderstanding by the undereducated.  This proposal threatens public safety, increases risk and liability to the Board of Medicine, and undermines the rigorous education and licensure standards that licensed acupuncturists must meet and are already enacted by Virginia Law and regulations.

thank you for rethinking this action.