Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Physical Therapy
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
Action Practice of dry needling
Comment Period Ends 12/30/2015
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12/21/15  2:37 pm
Commenter: David W Miller, MD

Opposition to Rules

As a physician licensed to practice medicine in all its branches, and as a fully trained and licensed Acupuncturist, and as an individual who has done 45 hours of advanced training in Myofascial Trigger Point Therapy, I write in opposition to the illegal scope expansion of physical therapists in Virginia to include Dry Needling, which is in fact acupuncture renamed. 

The use of needles in practice represents a profound alteration in the way physical therapy would be practiced, and phenomenally increases the risks of receiving physical therapy.  This addition dramatically increases medicolegal risk to referring physicians, and also the medicolegal dangers of physical therapy.  Further, the random determination of 54 hours of training as adequate to practice Dry Needling is baseless, and merely serves to skirt existing laws surrounding the practice of acupuncture.   Signed statements for patients that they are not receiving acupuncture are misleading, as they are, in fact, receiving acupuncture, though from someone without adequate training.  Even for physicians after a minimum of 7 years of advanced training and extensive performance of invasive procedures, 300 hours of training is considered the baseline industry norm.

This direction in medical regulation represents a profound disservice to the public of Virginia, offering them neither good acupuncture, nor even good myofascial trigger point therapy, while putting them at considerably increased risk of harm.  Pneumothorax, other organ puncture, syncope, and psychological trauma have already occurred in other states because of shoddy regulation such as this, and I encourage Virginia to avoid the erroneous path other states have taken.  For the good of the public and the practice of quality medicine, I strongly oppose these highly questionable and arrogantly mis-conceptualized rules.


David W. Miller, MD, FAAP, LAc, Dipl OM