Sample comment: 
  
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. This would be the equivalent of me performing orthopedic adjustments on my patients. Yes I could probably figure it out but no I am not a qualified expert with enough training to responsibly care for patients in this way. The patients don't know the difference in training and it is up to the board to protect them. In my practice alone I have seen multiple patients come in with serious injuries from dry needling. I have yet to see any injury from a licensed acupuncturist. I have 3000 hours and 4 years of training with needles. I had to take national board exams and needle competency testing before being able to practice. To allow physical therapists to use the exact same needles in the exact same points (please note many dry needling training seminars are actually teaching and using acupuncture points!) with ridiculously little training would be considered negligence by the board. 

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;
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.  

  
Thank you for considering my comments. 
  
Sincerely,  Ashley Will, Lac