I urge you to proceed with extreme caution in enacting any guidelines that will allow Physcial Therapists to perform "Dry Needling."  This practice is simply Acupuncture under a different name, and as a licensed Acupuncturist, I understand the extensive training required to safely insert needles into the body.  We learn needle depth, needle manipulation, needle angles, needle contraindications - all over the course of many hours of classroom training and, importantly, many more hours of clinical supervision.  The 54 hours proposed by Physcial Therapists in Virginia does not come close to the appropriate amount of training needed to avoid harm to patients.  This is simply not safe and the fact that this group of Physical Therapists are proposing only 54 hours demonstrates how little they understand about the practice they desire to use.  Sincerely, Kimberly Ertl