Dear Members of the Virginia Board of Medicine,

My name is John Yoo, and I serve as the Chief Executive Officer of the Virginia University of Integrative Medicine (VUIM). I am writing on behalf of VUIM to provide public comment on Petition 429, which seeks to amend regulations to permit licensed Athletic Trainers to perform dry needling.

At the outset, we sincerely appreciate the Board’s longstanding commitment to professional standards, public health, and patient safety. Our comments are offered in a collegial and constructive spirit, recognizing the valuable contributions that both Licensed Acupuncturists (LAc) and Athletic Trainers (ATC) make to patient care. However, we firmly believe that the proposed regulatory change raises significant concerns regarding training adequacy, patient safety, and professional scope.

For clarity, we present our perspective through four key points of discussion:

1. Dry Needling as a Subset of the Practice of Acupuncture
   • Dry needling is widely recognized as a narrow technique within the broader spectrum of acupuncture practice. In essence, Dry needling involves the insertion of solid filiform needles into trigger points, muscular structures, and connective tissues to relieve neuromusculoskeletal pain. Notably, even the definitions used in Athletic Training literature for “dry needling” closely mirror the legal definition of acupuncture.
     • The National Athletic Trainer’s Association (NATA) defines Dry Needling as: A skilled intervention that uses solid filiform needles to penetrate the skin and stimulate underlying myofascial trigger points, muscular, and connective tissues for the management of neuromusculoskeletal pain and movement impairments.
     • Coupled with the fact that the Athletic Training community has relied on a similarity to the education of Physical Therapists (PT) in discussions about Dry Needling, we can also reference “The Analysis of Competencies for Dry Needling by Physical Therapists” that defines dry needling as “using filiform needles to penetrate the skin and/or underlying tissues to affect change in body structure and function for the evaluation and management of neuromuscular conditions, pain, movement impairments, and disabilities.”
     • The Commonwealth of Virginia defines the practice of acupuncture in Chapter 29 of Title 54.1, Section 2900 of the Code of Virginia as “stimulation of certain points on or near the surface of the body by the insertion of needles to prevent or modify the perception of pain or to normalize physiological functions, including pain control, for the treatment of certain ailments or conditions of the body…”
   • Given the near-identical nature of the act, dry needling is properly understood as a modality of acupuncture. If the same invasive act is performed using the same instrument, it logically demands the same regulatory oversight.
   • Additionally, we note that references to physical therapists (PTs) being permitted to dry needle in Virginia are not directly transferable:
     • Virginia PTs received dry needling authority only after years of legislative debate, research review, and the imposition of minimum training and referral standards.
     • Other states such as California, New York, and Oregon have explicitly banned dry needling by non-acupuncturists, recognizing the safety risks involved.
   • Ultimately, each profession must be evaluated individually. Not all healthcare degrees and training programs automatically confer the privilege to perform invasive procedures.
2. Therapeutic Value, the Need for Sufficient Training, and the Concerns for Athlete (i.e. Patient) Safety
   • What is not being disputed is that dry needling represents a valuable form of patient care when performed by a practitioner appropriately trained and skilled in its application. However, the disparity in training between acupuncturists and those certified for dry needling is vast.
     • Licensed acupuncturists (LAc) in Virginia are required to undergo at least 1,900 hours of accredited graduate-level education through institutions such as VUIM, including extensive clinical internships. Every VUIM graduate completes no fewer than 690 clinical hours devoted entirely to mastering acupuncture needle techniques under professional supervision. By contrast, dry needling certifications often involve only 50–100 hours of coursework, sometimes delivered in weekend workshops.
     • Moreover, licensed Acupuncturists must pass national board exams (administered by the National Certification Commission for Acupuncture and Oriental Medicine, NCCAOM) and complete Clean Needle Technique (CNT) certification to ensure competency and safety.
     • This is all to say, mastery of a needle technique like dry needling requires more than anatomical knowledge; it demands fine motor skills, needle angle, insertion depth and other deep hazard zone identification, and clinical judgment honed through hundreds of patient encounters.
   • Documented adverse events, including pneumothorax, nerve injury, and infection, have occurred when dry needling was performed by minimally trained individuals. Comprehensive training in the use of the needle as -required for licensed acupuncturists - significantly mitigates these risks.
3. Pathways for Athletic Trainers Interested in Dry Needling
   • We recognize the genuine interest of many Athletic Trainers (and other Allied Health professions) in expanding their therapeutic skill sets. Rather than creating regulatory shortcuts, we encourage the use of established pathways for safe, comprehensive education:
     • In Virginia, Athletic Trainers can apply their prior education toward advanced standing programs in acupuncture, allowing credit for Western medical coursework and focusing additional study on the theory and techniques of acupuncture competencies.
     • For example, at institutions like VUIM, Athletic Trainers may complete a Master of Science in Acupuncture degree in as little as 18 to 24 months.
   • This approach helps to ensure:
     • Full competency in invasive needle therapies
     • Consistent public safety standards
     • Professional credibility without undermining regulatory integrity.
   • To date and across the country, institutions such as ours have successfully worked with and supported many students from the Physical Therapy and Athletic Training fields on their path toward attaining licensure as an acupuncturist.
4. Integrative, Team-Based Care that Marries Respect for Each Profession’s Scope & Expertise
   • Time and time again, a growing body of research indicates that Integrative, team-based care models are associated with improved patient outcomes. We have all come to understand that the broad spectrum of healthcare providers serving our collective athlete-patients (i.e. physicians, athletic trainers, acupuncturists, etc.) each bring a unique expertise that, when combined, leads to comprehensive, high-quality patient care.
     • With that being said, a Licensed Acupuncturist would never purport to specialize in surgery or athletic rehabilitation. In the same manner, the performance of invasive needle therapies should remain within the scope of those fully trained and licensed to do so.

In closing, VUIM respectfully opposes Petition 429 as written. We advocate for upholding the highest standards of training, professional excellence, and patient safety for any procedure involving needle insertion. For Athletic Trainers who choose to pursue licensure as Licensed Acupuncturists, the journey offers more than technical skills — it unlocks a deeper, more holistic approach to healing. As an ATC/LAc, you will be uniquely equipped to deliver exceptional, whole-person care, elevating the outcomes you can achieve for your athletes and setting a new standard of excellence in the field. While we encourage athletic trainers interested in dry needling to pursue the rewarding, life-changing academic and professional journey of becoming a licensed acupuncturist, VUIM remains committed to constructive dialogue and partnership on this matter, regardless of its outcome. Our institution's longstanding tradition of training other health care professions (PTs, MDs, ATCs) in the practice of acupuncture, and our deep desire to continue our collaboration with the Athletic Training community, informs our ongoing interest in partnership and dialogue.

VUIM welcomes the opportunity to assist the Virginia Board with additional information or resources to ensure that public health and patient safety remain paramount in any regulatory decisions.

Thank you for your careful consideration.

Sincerely,

John Yoo
Chief Executive Officer

Virginia University of Integrative Medicine
Virginia | New Jersey | Georgia