Honorable Members of the Health and Human Services Committee, I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. Thank you for your time and for your commitment to protecting the health and safety of Virginians.

Honorable Members of the Health and Human Services Committee, I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. Thank you for your time and for your commitment to protecting the health and safety of Virginians.

I have major support for the temperature regulation. I have been to several facilities during summer months in which the heat was so stifling that it melted the glue holding things together in my cell. With extreme heat there is no real remedy. There aren’t but so many articles of clothing you can take off, ice in most facilities is limited, and the cold water from the cell sink is tepid at best.

These should be basic right standards. These cause less trauma, less injuries, deaths, and for a better society

Dear Distinguished Committee, My name is Ian McIntosh, a resident of Virginia, and Executive Director for Not Dead Yet, a national disability rights organization that fights against assisted suicide legislation and for access to the gold standard of healthcare for everyone. On behalf of Not Dead Yet members in Virginia, we strongly urge the committee to vote Yes on Delegate Levere Bolling’s bill, HB 435. For your consideration, I refer you to the article, “Economic Benefits of Investment in Palliative Care: An Appraisal of Current Evidence and Call to Action,” published in the January 2026 issue of the Journal of Pain and Symptom Management, published on behalf of the American Academy of Hospice and Palliative Medicine. (https://tinyurl.com/2x3xr4sp) Contrary to popular belief, palliative care is not just for the dying. When accessed early in diagnosis, palliative care sustains lives as well as saves lives. Moreover, proven scalable models have shown that integrating palliative care into accessible healthcare coverage improves sustainable financing; A true win-win situation. A vote for HB 435 represents an imperative ethical and economic step towards strengthening and protecting Virginia’s most vulnerable in their time of need, and positioning healthcare resources for greater patient-centered success. An investment in palliative care in Virginia is a hedge against catastrophic health expenditures for all Virginians, especially by leveraging Virginia’s existing funding mechanisms to those most vulnerable in underserved urban and rural areas. By establishing The Palliative Care and Quality of Life Advisory Council in tandem with the Palliative Care Information and Education Program, HB 435 would afford Virginians access to clear, transparent, verifiable and authoritative information, which in turn enables informed decision making while enjoying the benefits of improving quality of care that simultaneously helps control health care cost for our great state. Sincerely, Ian McIntosh Executive Director Not Dead Yet - The Resistance

Distinguished Committee, I respectfully submit this written testimony in strong support of the palliative care provisions included in House Bill 435. These provisions represent evidence-based, patient-centered policy that will improve the quality of care delivered across the Commonwealth of Virginia while supporting patients, families, clinicians, and health care systems. Palliative care is a core component of high-quality modern medicine and is distinct from hospice care in that it may be delivered at any stage of serious illness. The palliative care additions in House Bill 435 appropriately reflect this reality and align Virginia law with established national standards of care. House Bill 435 establishes a statewide Palliative Care Information and Education Program to ensure that patients with serious illness and their families have access to accurate, standardized information regarding palliative care services. This provision addresses a well-recognized gap in health care delivery. Many patients and families mistakenly equate palliative care with end-of-life care, resulting in delayed referrals, unmanaged symptoms, and care that is misaligned with patient goals. A formal education program will promote earlier understanding of palliative care as supportive, patient- and family-centered care focused on quality of life. The bill establishes a clear definition of palliative care as patient- and family-centered care addressing physical, emotional, social, and spiritual needs and not limited by prognosis or life expectancy. This clarity is essential. By explicitly stating that palliative care may be provided at any stage of illness and concurrently with curative treatment, the bill removes ambiguity that often limits access to services. A clear statutory definition supports appropriate referrals, reduces variation in care delivery, and ensures patients receive symptom-focused support based on need rather than prognosis alone. House Bill 435 also requires licensed hospitals, nursing homes, and certified facilities to identify patients who may benefit from palliative care. This promotes proactive, systematic identification of patients with significant symptom burden or complex medical needs. Structured identification will improve equity in access and support earlier care planning and coordination. In addition, the bill requires facilities to provide information about palliative care and facilitate access to available services. This ensures that integration extends beyond recognition to meaningful action. Finally, the bill establishes a Palliative Care and Quality of Life Advisory Council to provide ongoing guidance and recommendations. This council will ensure that palliative care policy in Virginia remains informed by clinical expertise, evolving best practices, and the needs of diverse communities, including rural and underserved populations. In conclusion, House Bill 435’s palliative care additions represent prudent and compassionate policy that strengthens Virginia’s health care system while honoring patient dignity and autonomy. For these reasons, I respectfully urge support of the palliative care provisions in House Bill 435. Thank you, Dr John Daniel Markley Practicing Internal Medicine and Infectious Disease Physician, Richmond Virginia Medical Society of Virginia, Active Member

Please, vote for this bill. This bill will help educate patients of the benefits of palliative care and establishes standards that can help mitigate competitive practices. Often when patients here "palliative/hospice care" brought up by their doctor, it can create a sense of unease due to the perception that palliative/hospice care is for people "who have given up". For patients reaching the end of their journey, palliative care enhance the remaining time they have and often, prolong patient longevity. I urge you to vote for this bill.

The attached document is a public comment from the Virginia Association of Centers for Independent Living (VACIL) in support of HB 435, legislation focused on expanding access to palliative care. The comment explains how the bill improves education, informed choice, and access to palliative care for people with disabilities, while preserving self-determination and individual control over medical decisions. It highlights the alignment of the legislation with the Independent Living philosophy by promoting dignity, quality of life, and equitable access to information and services across the Commonwealth

My name is Theresa Gaffney, PhD, MPA, RN, CNE. I am a nursing professor and serve as the Commissioner for Nursing Education for the Virginia Nurses Association. I am writing today in strong support of House Bill (HB) 815. Virginia currently lacks a consistent, comprehensive lens through which to understand and plan for its nursing workforce. As a result, the Commonwealth is perpetually in a reactive posture—constantly playing catch-up as workforce gaps deepen. Projections indicate that Virginia will face a shortage of more than 20,000 registered nurses in the coming years, compounded by serious maldistribution challenges, both geographically and across care settings. At the same time, national data show that 30 to 50 percent of newly licensed nurses leave the profession within their first two years. This level of attrition threatens not only workforce stability, but the health and safety of Virginians who rely on timely access to quality care. To meet the healthcare needs of every resident, Virginia must shift from a reactive approach to a proactive, data-driven strategy—one that aligns nursing education capacity with workforce demand. The Nursing Workforce Center established in HB 815 provides exactly that: a centralized hub to collect, analyze, and act on workforce data. This infrastructure is essential to building and sustaining a stable, well-prepared, and resilient nursing workforce. For these reasons, I respectfully urge your support of House Bill 815. Thank you for your time and consideration.

Protect the public. Physical therapists have a documented history af adverse events of dry needling including organ damage and pneumothorax (lung puncture) - don't make the same mistake with trainers. Leave needling to properly trained professionals - Board Certified Licensed Acupuncturists.

Honorable Members of the Health and Human Services Committee, I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. Thank you for your time and for your commitment to protecting the health and safety of Virginians.

I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. Thank you for your time and for your commitment to protecting the health and safety of Virginians.

I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. Thank you for your time and for your commitment to protecting the health and safety of Virginians.

Please vote no on HB841. As a parent, I do not want my kids to be treated by athletic trainers with dry needling. AT's do not get enough education to practice this type of medicine. I have been receiving acupuncture for years and I respect the profession and the number of years of training acupuncturists receive. Please do not diminish their profession by allowing athletic trainers to practice "dry needling" which is a form of acupuncture. Thank you.

I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841.

Please do not allow trainers needling clients as a licensed acupuncturist in the state of Maryland along with the rest of the acupuncturists community I am voting against it. And as an Accupuncture school is a 4!!! years full-time program which includes getting certified in clean needle technique, So enabling athletic trainers needle will harm and traumatize Patients. And introduces a huge risk to the patient due to high probability of infection risk, pneumothorax and bursting blood vessels. Acupuncture schools are super expensive and trains, you extensively on proper needle in techniques, clean field, and Ethics of the profession - neither of which are available to athletic trainers. Please, NO!!!!

Honorable Members of the Health and Human Services Committee, I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. Thank you for your time and for your commitment to protecting the health and safety of Virginians.

Honorable Members of the Health and Human Services Committee, I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. I have TRAINED 4 years for Acupuncture degree---why should someone who takes a "weekend certification class" on dry needling be afforded the same trust that I have meticulously put in for 4 years. This bill is NOT SAFE FOR THE PUBLIC!!!! Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. PLEASE VOTE NO FOR HB 841!!!! Thank you for your time and for your commitment to protecting the health and safety of Virginians.

Honorable Members of the Health and Human Services Committee, I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. Thank you for your time and for your commitment to protecting the health and safety of Virginians.

I respectfully urge the committee to oppose HB 841, which seeks to expand the scope of athletic trainers to include dry needling. While athletic trainers play an important role in sports medicine, dry needling is an invasive procedure that requires extensive, specialized education in anatomy, physiology, pathology, and needling safety. Allowing practitioners without this level of training to insert needles into the body places the public at unnecessary risk. Licensed acupuncturists complete thousands of hours of supervised clinical training, including comprehensive instruction in clean needle technique, differential diagnosis, depth and angle of insertion, risk‑mitigation strategies, and the recognition and management of adverse events. This level of preparation is essential for preventing complications such as pneumothorax, nerve injury, infection, and vascular damage. These are not theoretical concerns — they are well‑documented risks when needling is performed without adequate training. Dry needling is not simply a manual therapy technique; it is a form of acupuncture. Changing the terminology does not change the procedure. If the General Assembly allows individuals with minimal needling education to perform this technique, it lowers the standard of care and compromises patient safety. This bill also undermines the integrity of regulated healthcare professions. Scope expansions should be based on demonstrated competency, not convenience. When invasive procedures are performed by those without the necessary depth of training, the public bears the consequences. For the safety of Virginia’s patients and the preservation of professional standards, I strongly urge you to reject HB 841. The risks are real, the training matters, and Virginians deserve protection from preventable harm.

As an Acuouncturist , Herbalist and RN of twenty years, I have watched as less experienced and less educated medical practitioners have practiced Acupuncture calling it other names and without Chinese Medicine Theory. The end results are less effective, less consistent and comprehensive and more importantly- harmful to many patients. Giving a group of trainers who have significantly less education this right is not only wrong but a grave liability to the greater public. Please vote NO in passing Acupuncture to athletic trainers. Leave this to the professionals who have been immersed in study and committed solely to this medical modality.

I vote against having AT performing dry needling. I am an acupuncturist performing dry needling. Dry needling can be a dangerous procedure if the performer is not trained thoroughly. Acupuncturists have a lot more extensive needling training than athletic trainers do.

Honorable Members of the Health and Human Services Committee, I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. Thank you for your time and for your commitment to protecting the health and safety of Virginians.

Honorable Members of the Health and Human Services Committee, I have serious concerns about this bill for three key reasons: First, the Board of Medicine already reviewed and rejected this proposal. The Board declined to amend its regulations to allow athletic trainers to perform dry needling. HB 841 does not resolve the issues identified by the Board; instead, it overrides that decision through statute and, through its amendment, bypasses the normal public regulatory process. Second, the bill fails to address critical training disparities that directly affect patient and athlete safety. HB 841 authorizes an invasive procedure without defining “dry needling” in statute and without establishing a clear, evidence-based standard for education, clinical competency, or supervised training. There is no established consensus on what constitutes adequate preparation to safely perform this procedure. Third, the bill provides no meaningful patient protections or accountability mechanisms. HB 841 does not require clean needle technique, does not establish enforceable safety standards, and does not clearly define practitioner accountability in the event of patient harm. For these reasons, I respectfully ask that you oppose HB 841. Thank you for your time and for your commitment to protecting the health and safety of Virginians.

I am writing as a licensed acupuncturist to express serious safety concerns regarding the proposed legislation (HB841) that would expand the use of dry needling to AT with limited training. While the intent of the bill is to increase access to care, and I believe athletes can benefit from dry needling, the current language raises significant patient safety issues. Dry needling involves the insertion of thick needles into deep muscular, which carries inherent risks including pneumothorax, nerve injury, vascular injury, and infection when performed without adequate and supervised training. As written, the proposal does not require the level of education, anatomical training, or clinical oversight necessary to ensure patient safety. This is particularly concerning given the proximity of dry needling techniques to critical structures such as the lungs, major blood vessels, and nerves. Expanding scope without clearly defined, rigorous training standards exposes athletes and young adults to preventable harm. Licensed acupuncturists complete extensive education in anatomy, physiology, clean needle technique, and thousands of hours of supervised clinical training specifically focused on safe needle insertion. Allowing practitioners with significantly less needle-specific training to perform invasive techniques creates an uneven and unsafe standard of care. Thank you for considering revisions to the bill to ensure the highest standard of patient and athlete safety. Kindly, Ericka Schaefer L.Ac

Honorable Delegates, Can you please tell me the definition of Dry Needling everyone is using to make this vote today? Because there is no clear Virginia definition, I ask you to oppose this bill. As a mom with kids in sports and as a Doctor of Acupuncture and Licensed Acupuncturists, I have people constantly asking me what Dry Needling is. The public is very confused because there is no definition in Virginia Code. Because Virginia does not define it, I use Dry Needling language defined at the national level by PTs but it reads nearly identical to Virginia's definition of Acupuncture. This is confusing for the public and healthcare providers. ATs will claim, "the Physical Therapists got it passed in legislation without being defined, why do we need it defined?" Just because the cart was put in front of the horse the first time, doesn't make it correct or the right thing to do now. Honorable Delegates, you have all the power here to correct a wrong and stand up for proper legislation and public safety, all-in-on. Please oppose this bill to pause it and force all the stakeholders to DEFINE "DRY NEEDLING" legally so legislators, stakeholders, and the public know what they are voting on and for? The Athletic Trainers are going to say the DHP/Department of Health Professions will make sure the education requirements and supervisory roles are clear after the bill is passed, but look at the current admin code created by the DHP for the PTs. It is SO vague! It leaves room for a lot of error, risk, and public confusion. This type of vague language is a public safety risk. Please stand for public safety and force the PTs, ATs, and Licensed Acupuncturists to work together by pausing this bill and requiring an agreed upon definition of Dry Needling in Virginia first. Thank you for your consideration and service to this Commonwealth, Dr. Jennifer Drake, DACM

·  Vote NO on the current version of HB 841 due to significant patient and student-athlete safety concerns, especially to minors and pediatric patients ·  Do not advance HB 841 without defined education and training standards for the use of acupuncture filiform and dry needles. We ask that these standards be set to protect the practitioners, professions, and patients in the discussion of public safety. We would request a mandatory clinical practice component comparable to existing standards for Medical Doctors and Licensed Acupuncturists. If Athletic Trainers are permitted to perform dry needling, require at least 100 total hours of didactic and supervised clinical training, reflecting their more limited needling background compared to Licensed Acupuncturists. Recognize that most serious adverse events occur among practitioners with inadequate training. Licensed Acupuncturists complete approximately 64 times more training and have a fraction of the reported adverse events compared to Physical Therapists and Medical Doctors. ·  Amend supervision requirements to mandate oversight by providers, including Licensed Acupuncturists, or medical providers with equivalent needle training. This should be DIRECT supervision and in a controlled clinical setting to prevent harm. ·  Require a clear statutory definition of “dry needling.” The bill currently authorizes the use of acupuncture filiform needles without defining the procedure or its clinical scope. ·  Prohibit dry needling on minors. This should be limited to college-aged athletes and adults. Pediatrics require specialized training, anatomical considerations are different, and allowing this on minors violates basic medical ethics and public safety standards. ·  Align policy with Virginia’s leadership in Whole Person Health and hospital-based care. These standards directly support ongoing work in Commerce and Labor to keep Virginia competitive in integrative and hospital-based care—particularly for senior populations and workforce retention. ·  Uphold professional standards through Virginia-based education. Virginia is home to a large, accredited institution capable of offering rigorous training and representing national professional standards—policy should reflect and reinforce that expertise.

RE: OPPOSITION to HR841 Athletic Trainers and Dry Needling   Dear Honorable Willett and Members of the House Health and Human Services Committee: The National Certification Board for Acupuncture and Herbal Medicine (NCBAHM™) writes to express concerns regarding HR841 and the lack of clearly defined education, training, and practice requirements that would permit athletic trainers (ATs) to perform dry needling in the Commonwealth of Virginia. Dry needling is an invasive procedure that utilizes solid filiform needles inserted into the body and carries risks that are well documented in the medical literature, including infection, nerve injury, vascular injury, organ puncture, and pneumothorax. These risks are directly related to a practitioner’s level of anatomical education, supervised clinical training, and demonstrated competence in invasive needling techniques. Regardless of terminology, procedures that involve penetrating the skin with needles near vital anatomical structures require rigorous, standardized training to ensure public safety. The mission of the NCBAHM is to protect the health and welfare of the public and to advance the professional practice of acupuncture and herbal medicine by establishing and promoting national, evidence-based standards of competence and credentialing. NCBAHM National Board-Certified Acupuncturists™ complete extensive education and clinical training that includes hundreds of hours in anatomy, physiology, pathology, clean needle technique, risk management, and supervised hands-on clinical practice. This depth of training prepares practitioners to safely perform invasive needling procedures and to recognize and respond appropriately to potential adverse events. Safe and effective outcomes from acupuncture and dry needling procedures depend on far more than the mechanical placement of needles. These interventions require comprehensive anatomical knowledge, clinical judgment, and a foundational understanding of invasive procedures to minimize risk and prevent harm. Without clearly defined and adequately rigorous education and licensing standards, patients may be exposed to unnecessary and preventable risk. NCBAHM respectfully urges the Commonwealth of Virginia to recognize the importance of consistent, evidence-based training and licensure requirements for all healthcare practitioners performing invasive needling techniques. As acupuncture and related therapies continue to be integrated into the broader healthcare system, it is essential that public policy prioritize patient safety through appropriate regulation. For these reasons, NCBAHM urges you, in the interest of public welfare, to vote no on HR841. I hope you will find this information helpful. For additional context, we encourage you to review the NCCAOM Dry Needling Position Statement, which reflects nationally recognized credentialing standards related to needling safety and competence. NCBAHM remains available as a resource for information on education, certification, and standards of practice within the field of acupuncture and herbal medicine. Please feel free to contact me by phone (703-314-2908) or by email (mlarson@ncbahm.org) if I can offer further information on this topic. Sincerely, Mina M. Larson, M.S., MBA, CAE Chief Executive Officer

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.

Please see my attached testimony.

Good evening, I am registering in support of HB 1347 on behalf of Veterans Exploring Treatment Solutions (VETS). Please see my written testimony attached. Respectfully, Logan Davidson Legislative Director

I am testifying in support of HB 1347. Please see my written comments attached.