I strongly oppose the amendment to 18VAC85-120-110.  Dry needling is an invasive technique and should only be administered by trained, licensed acupuncturists. 

I am currently an acupuncture student, nearing graduation.  I will have spent almost 2000 hours studying anatomy, proper needling technique for the different parts of the body, how to use clean needle safety, and 18 months of supervised clinical practice in order to become a licensed acupuncturist.  

Granting dry needling privileges to athletic trainers without similar training is dangerous to patient care.  I strongly urge the Board to deny this amendment.