I am writing in strong opposition to the proposed changes to 18VAC85-120 of the Virginia Administrative Code that would permit athletic trainers to perform dry needling after receiving limited training and physician screening.

Dry needling is an invasive procedure involving the insertion of solid filiform needles into soft tissue. While it is often framed as distinct from acupuncture, in practice, dry needling is acupuncture by another name — and it carries the same potential risks if performed without appropriate training.

Licensed acupuncturists receive extensive education and clinical training in anatomy, clean needle technique, orthopedic needling, and the prevention of adverse outcomes such as nerve injury, organ puncture, and infection. This training takes place over the course of a graduate-level medical program and includes direct, supervised clinical experience.

In contrast, athletic trainers do not receive comparable instruction in needle insertion, sterile procedure, or the identification of contraindications for invasive needling. A short training course is not sufficient preparation for performing an invasive procedure with real and serious risks.

Allowing dry needling by athletic trainers, even with physician oversight, poses a public safety concern. It undermines the regulatory standards designed to protect patients and sets a dangerous precedent for delegating invasive procedures to providers without the necessary depth of training.

I urge the Board to reject the proposed changes and maintain patient safety as the highest priority.