Dear Board of Physical Therapy,

"Dry needling" is acupuncture and should not be included in the scope of practice of other medical professionals. It uses acupuncture needles. Throwing away 3,000+ years of clinical experience by a multitute of practiioners and renaming it "dry needling" doesn't change that simple fact. There is a 71% correlation between the location of traditional acupuncture points and trigger points. These studies have been around a long time. Saying you needle only trigger points and not traditional acupuncture points is completely inaccurate - and impossible. I do not expect to be able to practice physical therapy with a CEU course and am happy practicing within my scope of practice and having great referral relationships with PTs in my area. I expect that you will recognize that dry needling is acupuncture. Show some professional respect please; create partnerships and coordinate care with your local acupuncturists - they are highly trained in what they do. If you want to needle patients, go get an acupuncture degree and really learn it, you will not be disappointed.

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:

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;

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;

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,

Alicia Rosselle