I am a Doctor of Acupuncture and licensed by the state of Virginia as well as Nationally board-certified. I strongly oppose HB841 allowing Athletic Trainers to use dry needling to their scope of practice. This would bypass measures integral to maintaining patient safety and proper oversight in the medical field. Dry Needling is an Aggressive Acupuncture Technique The opinion that dry needling is not acupuncture is incorrect. While the term “dry needling” is a western term and translation, the technique is clearly described in many ancient acupuncture texts dating back thousands of years. It is a technique that is taught in every acupuncture school and routinely utilized when treating patients with musculoskeletal concerns. That said, dry needling is a very aggressive acupuncture technique and is often not the best choice for a patient. Dry needling generally uses acupuncture needles that are much thicker than ones used in other acupuncture techniques. When dry needling, sometimes it is necessary to use very long needles (4”) and go through layers of muscles and navigate around vital organs. This is a very delicate procedure and carries a risk of side effects including local and systemic infection, organ puncture, excessive bruising and bleeding, fainting, dizziness, nausea, reduction in energy and the inability to participate in activities of daily living. A properly trained and licensed acupuncturist has the knowledge to avoid and reduce these risks. Athletic trainers would only have this needling technique at their disposal (which they learn in an inadequately short course) and the likelihood of applying this invasive procedure to patients for whom it is contraindicated, is very high. We are already beginning to hear reports of athletes and other patients being harmed by dry needling at the hands of trainers. Inadequate Training & Oversight Acupuncturists are required to undergo a minimum of over 2000 hours of training including almost 700 hours of clinical training directly involving needles. Acupuncturists are required to pass rigorous national (and in some cases state) board exams and have very strict oversight and continuing education requirements. Medical Doctors who perform dry needling and other acupuncture techniques have to undergo 300 hours of training in addition to their medical school education. Allowing a short course in an invasive acupuncture technique to be deemed adequate training is dangerous and poses a grave risk to public safety The American Medical Association’s Policy H-410.949: Dry Needling is an Invasive Procedure The American Medical Association has a policy on dry needling and recognizes the invasive nature of this acupuncture technique. “Our AMA recognizes dry needling as an invasive procedure and maintains that dry needling should only be performed by practitioners with standard training and familiarity with routine use of needles in their practice, such as licensed medical physicians and licensed acupuncturists.” https://policysearch.ama-assn.org/policyfinder/detail/dry%20needling?uri=%2FAMADoc%2FHOD-410.949.xml The current training and regulations in place for Athletic Trainers does not provide the proper education or oversight for this invasive treatment. This bill undermines medical safety, erodes public trust and endangers patient health while offering little in return.

Dear Honorable Delegates, Please consider my opposition to HB841, which would add dry needling (DN) to the scope of Athletic Trainers. I am speaking as a Doctor of Acupuncture and Oriental Medicine, licensed in Virginia (2022) and California (2003), Board Certified in Acupuncture Orthopedics (2006), Certified Myofascial Trigger Point Therapist (DN--gold standard for Physical Therapists, 2017), Diplomate and Continuing Education Provider for the National Certification Board for Acupuncture and Herbal Medicine (NCBAHM, 2021), founder of the Sports Acupuncture Clinic (2003). I have also served continuously since 2005 as a Professor at the Masters, Doctoral, and Continuing Education levels for 4 nationally-accredited colleges and universities of acupuncture, including the Virginia University of Integrative Medicine, on topics including sports and orthopedic acupuncture, professional ethics and risk management, dry/trigger point needling, and clinical safety, as a guest speaker for the RAMP Program (acupuncture training for US Air Force Physicians), and as a Guest Editor in Sports Acupuncture for Medical Acupuncture. I am also speaking as a professional who has served as an Expert Witness on over 30 civil and criminal medical malpractice and regulatory board investigation cases involving injuries resulting from dry needling and acupuncture performed by Physical Therapists, Physicians, and Licensed Acupuncturists. My professional experience also includes serving as an Athletic Training Assistant and Physical Therapy Aide. I have worked in Physician-lead orthopedics and pain management clinics, and in my current clinical practice at the Sports Acupuncture Clinic of Charlottesville, I treat many primary school, college, and professional athletes. I thus oppose adding DN to the scope of any additional professions unless it includes training requirements comparable to those required for licensure in acupuncture: 4-year Masters or First Professional Doctorate degree, and passage of a rigorous examination covering safety, competence and ethics, such as is administered by the NCBAHM: There is no public necessity to add dry needling to the scope of practice for Athletic Trainers. This modality is already widely available in Virginia through the services of over 500 Licensed Acupuncturists, as well as Physical Therapists and Physicians. Under-trained, under-regulated and unexamined providers present a high risk to public health and safety. Witness a pneumothorax (collapsed lung) injury suffered in 2025 by Pro Football player TJ Watt from dry needling. I have personally served as a consultant in litigation and regulatory investigations on 8 pneumothorax injuries caused by dry needling (including 1 death, and several resulting in permanent loss of lung function), as well as injuries to the brain stem and peripheral nerves resulting from dry needling. Even a cursory search of high-quality, peer-reviewed published case reports and literature reviews documents the risks of needling, that are thoroughly documented by the Clean Needle Technique Manual, Council of Colleges of Acupuncture and Herbal Medicine and available on public databases such as the NIH’s PubMed. For these reasons, I strongly oppose HB 841. Thank you for your consideration of my experience and recommendations. Sincerely, Anthony Von der Muhll, LAc, DAOM, DNBAO, FAIPM

If you need any further proof of the dangers of allowing non-acupuncture professionals to dry needle after just 50 to 100 hours of training (versus our minimum of 1,905 hours to practice), look no further than the recent emergency surgery that Pittsburgh Steeler's TJ Watt had to undergo on December 10, 2025 for a pneumothorax induced by an AT/PT for the Steeler's. From an ESPN article on Dec 12, 2025 : "Steelers inside linebacker Patrick Queen said he prefers to utilize acupuncture. 'Kind of two different things,' Queen said of the practices. 'One [acupuncture], you got to go to school for a longer period of time. There's a whole much more scientific thing that goes into it.'....Queen said the extra education required to administer acupuncture is why he uses it." That's directly from the mouth of the type of person who would be treated by an AT. Stop legislating legal loop holes around the current requirements for needling! These loop holes for AT's and PT's create life threatening circumstances for unwitting clients who don't understand the difference in training required amongst these professionals.

Athletic trainers have neither the background nor training to put needles into people. The practice of acupuncture, from which this "dry needling" nonsense has derived, is a precise and exquisite medical intervention. It is now being plundered by ignorant people just looking to cash in on the latest thing. Real harm can come from "dry needling" if the person does not have the proper training and licensure. Do not pass this bill, please

I am a licensed acupuncturist and a doctor of acupuncture and Chinese medicine licensed and practicing for 26 years. I am shocked and concerned to learn that athletic trainers are requesting to have dry needling in their scope of practice. Dry needling can be a hazard to public safety if done by unskilled providers. It can cause organ injury and even death by pneumothorax. This is not a technique that should be allowed for people with minimal medical training. I strongly recommend the committee not allow dry needling in the scope of practice of athletic trainers who may have minimal training in high-level anatomy and minimal needling training. Acupuncturists are trained in a four year professional (post graduate) training in order to be able to perform skills such as dry needling. Please for public safety reasons deny this request. - Tamara Brown, Licensed Acupuncturist, Doctor of Acupuncture and Chinese Medicine Licensed in Virginia and California

The ASVA asks that legislators do not advance SB728/HB841 as written. We believe that it’s important to keep invasive needling within professions that meet medical-level standards. At the very least, we request a formal safety review with Board of Medicine representatives, licensed acupuncturists, and other medical experts where training hours and competencies are considered. Dry Needling Is an Invasive Medical Procedure Dry needlining is not superficial. It penetrates muscle, fascia, and tissue near vital structures. Calling it “dry needling” does not change the anatomy, risk, or medical reality - it is acupuncture by another name. Training Standards Are Not Comparable Licensed acupuncturists in Virginia complete 1,900-3,000 hours of post- graduate clinical training. Includes anatomy, internal organ mapping, sterile technique, depth and angle of insertion, and hundreds of supervised treatments. Athletic trainers do not receive equivalent invasive-needle training as part of licensure. Proposed “certifications” may be as little as a weekend course. Risks Improper needling can cause: Collapsed lung (pneumothorax) Nerve damage Infection Vascular injury and bleeding Legal & Regulatory Conflicts The Board of Medicine recently reviewed this issue brought forth via petition, and voted to take no action, concluding that dry needling does not fall within the statutory scope of athletic training (§54.1-2900). Virginia regulations classify dry needling as an advanced invasive procedure, rather than an entry-level skill, requiring post-graduate training. Existing regulations, specifically 18VAC112-20-121, mandate that such procedures require rigorous post-graduate training, including didactic and hands-on laboratory education. SB728/HB841 bypasses those standards and weakens existing medical safeguards. Consumer Protection & Informed Consent Patients cannot tell the difference between: A provider with thousands of hours of needle training A provider with a short certification SB728/HB841 allows the same invasive act to be performed under dramatically different standards - undermining informed consent and public trust. Virginians deserve to know that invasive procedures meet consistent safety standards. Legal and Liability Risk Lower training thresholds increase malpractice exposure, weakens the standard of care, and places the Commonwealth in the position of defending preventable injuries The Commonwealth may be asked why it allowed invasive medical procedures without medical-level education. This bill lowers the bar for what constitutes negligence.

As a mom, I oppose this bill. This is not safe for our children who are being cared for by athletic trainers. As written, there are no education requirements for Dry Needling education in Virginia. Dry Needling is an invasive needle procedure using Acupuncture needles. As we all recently saw in December 2025 with TJ Watt, outside linebacker for the Pittsburg Steelers, dry Needling can cause life threatening conditions. His pneumothorax (lunch collapse) was caused by a well trained professional. Please require specific education requirements for Dry Needling, consumer education about dry Needling versus acupuncture, and supervision of ATs by people who have been trained in this modality before this bill is passed. Thank you.