I am writing to express my extreme opposition to proposed rules allowing Physical Therapists to do "Dry Needling" with only 54 hours of training. Acupuncturists like myself are required to do 970 hours of clinical training in addition to 2,240 hours of didactic training. Allowing Physical Therapists to insert acupuncture needles with such inadequate training is wildly irresponsible. 

Dry Needling constitutes the practice of acupuncture under Virginia law, and there is no reason Physical Therapists should be allowed to practice acupuncture with such subpar training. 

Lastly, the Dry Needling rules are illegal, as it is beyond the scope of practice of a Physical Therapist to insert filiform needles, thereby performing acupuncture, without having met the same requirements as an acupuncturist. 

Thank you for your time,

William Ferguson