Dear Members of the Virginia Board of Medicine,

I am writing to express my strong opposition to the proposed amendment to 18VAC85-120-110, which would expand the scope of practice for athletic trainers to include dry needling.

While I respect and value the work that athletic trainers provide in the care and rehabilitation of patients, the inclusion of dry needling in their scope poses significant concerns regarding patient safety, quality of care, and the integrity of professional training standards.

1. Insufficient Training Compared to Licensed Acupuncturists

Dry needling weekend courses, often comprising as little as 20-50 hours of training, are grossly inadequate when compared to the rigorous education licensed acupuncturists receive. Acupuncturists complete thousands of hours of training in needle techniques, anatomy, orthopedics, safety, and clinical practice. This extensive education ensures a deep understanding of musculoskeletal conditions and the safe, effective use of needles.

2. Patient Safety and Complexity of Musculoskeletal Needling

Patients who require advanced needling techniques—often termed "dry needling"—are best served by licensed acupuncturists. These practitioners are not only proficient in orthopedic and musculoskeletal needling techniques but also possess comprehensive training in recognizing contraindications, managing adverse events, and integrating treatment with Western medical care. Allowing undertrained individuals to perform invasive procedures like dry needling increases the risk of complications, including nerve injury, infection, and punctured organs.

3. Collaborative Care and Optimal Patient Outcomes

Acupuncturists routinely work alongside physicians, physical therapists, and athletic trainers to provide integrative care that achieves the best possible outcomes for patients. Their expertise complements Western medical approaches and contributes to faster recovery, reduced pain, and enhanced function. Diluting the standards for needling practices by permitting inadequately trained practitioners to perform them undermines this collaborative model and may lead to suboptimal results for patients.

Conclusion

For the safety of Virginia’s patients and the preservation of high standards in healthcare, I respectfully urge the Board to reject the proposed amendment to expand dry needling privileges to athletic trainers. This decision should prioritize the welfare of patients and uphold the rigorous educational standards necessary for safe and effective needle-based treatments.

Thank you for your attention to this important matter. I would welcome the opportunity to provide further information or participate in discussions on this topic.

Sincerely,
Dr. Angela Lipson, Doctor of Chinese medicine, Licensed Acupuncturist