Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the regulations present a serious threat to public health and would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy that has been adopted by the Virginia General Assembly. 
  
I encourage you not to draft regulations because:

 
1. 54 hours of training is a completely inadequate level of training to qualify a physical therapist to safely insert acupuncture needles into patients and the regulations therefore are a serious threat to public safety.  This amount of training is not adequate to perform the art of acupuncture needling.  The amount of hours of training received in acupuncture school is focused on the art of oriental medicine and cannot be duplicated by "Dry Needling techniques".

 2. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training required for acupuncturists and even medical doctors; 

3. The dry needling rules are illegal, because they would allow physical therapists to engage in acts that are outside the legal scope of practice for physical therapy as defined by Virginia's General Assembly. There is nothing to support that the General Assembly ever intended to allow physical therapists to insert acupuncture needles into patients absent the same level of training required for licensed acupuncturists.  

4. Physical therapists need to learn how to referr to an acupuncturist who possess the techniques and best application of acupuncture needles to the human body.

5.  There is an art to acupuncture that is only completed when the 8 Limbs of Chinese Medicine are incorporated into the treatment plan. "Dry Needling" will not  be an affective treatment and could actually cause more harm to the general public, as your board already knows of reported cases of damage and harm which are pending litigation around the misuse of  "Dry Needling".

Thank you for considering my comments. 
  
Sincerely, 
Robert A. Hoffman N.C.C.A.O.M. Lic. Ap.