Dear Virginia Townhall,

I am writing to formally express my deep concern regarding the continued allowance or potential expansion of dry needling practices by individuals who are not licensed acupuncturists and have not undergone comprehensive training in Traditional Chinese Medicine (TCM) or supervised clinical instruction.

Dry needling is acupuncture—whether labeled as a “modern technique” or framed as something separate, it still involves the insertion of filiform needles into the body to manipulate physiological function. When performed without adequate training in the underlying diagnostic systems, channel theory, and the energetics of the body, it is not only unsafe, but misleading to the public.

Allowing non-acupuncturists such as physical therapists or chiropractors to perform invasive needling procedures after minimal weekend courses:

• Jeopardizes patient safety, as needling improperly can cause serious harm, including organ puncture, nerve damage, or infection.
• Erodes the integrity of the acupuncture profession, which requires years of rigorous biomedical and classical TCM education, including hundreds of hours of supervised clinical practice.
• Constitutes cultural appropriation, stripping away centuries of carefully preserved knowledge and reducing a holistic system of medicine into a mechanical, symptom-focused modality.
• Undermines public trust and devalues the commitment of licensed acupuncturists who have dedicated their lives to mastering this art and science.

I urge you to uphold public safety and professional integrity by:

1. Prohibiting the practice of dry needling by individuals without acupuncture licensure.
2. Recognizing dry needling for what it is—acupuncture—and regulating it accordingly.
3. Honoring the cultural and medical heritage of TCM, rather than allowing it to be fragmented and commodified without respect or understanding.

Thank you for your attention to this critical issue. I respectfully request that this statement be entered into the public record and considered in any policy decisions moving forward.