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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5/2/25  9:53 am
Commenter: Deguang He ? American TCM Association

No unlicensed DN practices by VA ATs
 

xz We Say No to Unlicensed DN Practices by VA ATs!

The reckless appropriation of acupuncture techniques-rebranded as "dry needling"-by unlicensed athletic trainers in VA is a clear threat to public safety. As licensed acupuncturists, we condemn this dangerous exploitation of invasive medical procedures by individuals lacking proper training, licensure, and oversight.

Dry needling is acupuncture. The National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM) unequivocally states that dry needling falls under the scope of acupuncture, defined as "the insertion of thin solid needles into anatomical locations to treat disease, injury, pain, or dysfunction". Attempts to rebrand this ancient practice under a different name do not alter its inherent risks or complexity.

The consequences of unqualified practice are severe. We have treated patients suffering from preventable injuries-punctured lungs, nerve damage, and chronic tissue trauma-directly linked to improper needling by athletic trainers. These individuals receive mere hours of cursory training, compared to the 3,000+ hours of rigorous education, clinical practice, and OSHA-mandated safety protocols required for licensed acupuncturists. For example, while physical therapists in Virginia must complete 54 hours of post-professional training, this pales in comparison to the decades of refined expertise acupuncturists bring to needle depth, angle, and anatomical precision.

Profit-driven negligence must end. Athletic trainers are not medical professionals. Their scope of practice-rooted in fitness and rehabilitation-does not entitle them to perform invasive procedures requiring mastery of human anatomy, pathophysiology, and sterile technique. Patients trust providers to act in their best interest, not to gamble their safety for revenue.

We demand immediate action:

*Enforce existing acupuncture licensure laws. Dry needling is acupuncture; its practice must require full acupuncturist licensure.

*Hold violators accountable. States like California, Hawaii, and New York already prohibit dry needling by non-acupuncturists-this standard must become universal.

Patient safety cannot be sacrificed for convenience or profit. Licensed acupuncturists stand united to end this dangerous charade.

Sincerely,

Name?Deguang He
Licensed Acupuncturist (L.Ac.), NCCAOM Diplomate
State?MA

CommentID: 234150