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.
 
William Zhao L.Ac, Ph.D