I agree with all of the comments submitted by Janet L. Borges, MSTCM, L.Ac., on behalf of the Acupuncture Society of Virginia.

I offer the following two comments:

Regarding 18VAC85-110-90, Test of Spoken English requirements:  While I agree that such a requirement need not be enshrined in the regulations of the Code of Virginia, it is still worthwhile that all practitioners have a basic facility with the English language in order to understand what is required by government entities and what is asked by professional organizations.

18VAC85-110-100-General requirements:  Documentation of a diagnostic evaluation by a physician was inserted into the regulations at a time when the practice of acupuncture in the Commonwealth was very new. Some in the medical profession who served on the VA Board of Medicine did not yet trust the acupuncture profession to know when to refer to a medical physician.  The language used by New York State (and long since repealed there) was adopted to assuage these concerns.  After almost 20 years, it is clear that the language is no longer necessary as there have been no cases of problems arising from physician/acupuncturist referrals.