I support the comments of the ASVA and also second the opinion of Ms. Heller of Shen Dao Clinic with regards to section 18VAC85-110-100. 

"I support the comments of the ASVA.  Particularly, section 18VAC85-110-100, regarding the requirement that all new patients must sign a form recommending that they see a physician, chiropractor, or osteopath if they have not brought written proof with them that they have recently seen such a provider.  As acupuncturists, we are trained well and know when it is necessary to refer to other providers.  Additionally, many patients come to acupuncturists for treatment when other methods have left them wanting, but rarely do they have written proof that they have seen such other providers."

~ Heller, Shen Dao Clinic