As a Doctor of Acupuncture, I strongly oppose the proposed amendment to 18VAC85-120-110. Dry needling is an invasive medical procedure that should only be performed by licensed acupuncturists with comprehensive training. Permitting athletic trainers to perform this technique without equivalent education and clinical experience poses a significant risk to public safety.

I have completed over 2,000 hours of rigorous academic and clinical training in Acupuncture & Integrative Medicine. The practice of acupuncture has already suffered from misrepresentation through the rebranding of our medicine as “dry needling.” To now further erode its integrity by lowering the standards for who may perform it is both reckless and disrespectful to the profession and the public.

It is important to note that when adverse events associated with “acupuncture” are reported, they are overwhelmingly linked to inadequately trained individuals performing dry needling, not to board-certified, highly trained acupuncturists. This amendment further endangers patients and undermines the very standards designed to protect them.