Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Physical Therapy
 
chapter
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
Action Practice of dry needling
Stage NOIRA
Comment Period Ended on 12/30/2015
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12/22/15  2:07 pm
Commenter: Jenifer Word

AAAOM Letter:Oppose DryNeedling By PT, from AmericanAssociation of Acupuncture and Oriental Medicine
 

American Association of Acupuncture and Oriental Medicine
(AAAOM) Position Statement on Trigger Point Dry Needling
(TPDN) and Intramuscular Manual Therapy (IMT)

Summary
The American Association of Acupuncture and Oriental Medicine Blue Ribbon Panel on Interprofessional
Standards has determined that dry needling and any of its alternate designations,
including intramuscular manual therapy, trigger point needling, functional dry needling,
intramuscular stimulation or any other method by which a needle is inserted to effect therapeutic
change, is, by definition, the practice of acupuncture.
Rationale
1. Acupuncture, as a procedure, is the stimulation of anatomical locations on the body,
alone and in combination, to treat disease, injury, pain, and dysfunction and to promote
health and wellness.
2. Acupuncture, as a procedure, includes the invasive stimulation of said locations by the
insertion of needles and the non-invasive stimulation of said locations by thermal,
electrical, chemical, light, mechanical or other manual therapeutic methods.
3. Acupuncture, as a therapeutic intervention and medical practice, is the study of how the
various acupuncture procedures are applied in health care.
4. Trigger point dry needling, dry needling, functional dry needling, and intramuscular
manual therapy, or any other pseudonym describing acupuncture procedures, are, by
definition, the practice of acupuncture.
5. In the interest of public safety, non-acupuncture boards should not regulate the practice of
acupuncture.
Nationally Recognized Acupuncture Standards
The AAAOM endorses the educational standards set forth by the Accreditation Commission of
Acupuncture and Oriental Medicine (ACAOM). The ACAOM is the sole agency recognized by
the United States Department of Education to set educational standards for the procedure and
practice of acupuncture.
The AAAOM endorses the state licensure qualifying standards set forth by the National
Certification Commission of Acupuncture and Oriental Medicine (NCCAOM). The NCCAOM
is the sole agency recognized by the Institute for Credentialing Excellence’s (ICE) National
Commission on Certifying Agencies (NCCA) to qualify acupuncturists for licensure.
March 11, 2013
AAAOM | 866-455-7999 | info@aaaomonline.org Page 2 of 4

State regulatory boards for licensed health care professions other than acupuncture have begun to
recognize the procedure and practice of acupuncture by other names, such as “dry needling” and
“trigger point dry needling.” At present, this is being done primarily by physical therapy boards
in an attempt to expand the scope of practice for the physical therapy profession. Scope of
practice expansion attempts made in this manner preclude necessary and adequate educational
and safety standards for the procedure and practice of acupuncture. Forty-four (six pending)
states plus the District of Columbia have statutorily defined acupuncture and the educational and
certification standards required for acupuncture licensure. Current medical literature is consistent
with the definitions of both the procedure and practice of acupuncture as provided by state
practice acts. 1-21
Historical Precedents
Trigger point dry needling and intramuscular manual therapy are aliases used in the marketing of
a subset of acupuncture techniques described in the field of acupuncture as “ashi point
needling.”2 A reasonable English translation of ashi points is “trigger points”, a term used by Dr.
Janet Travell in her landmark 1983 book Myofascial Pain Dysfunction: The Trigger Point
Manual.3 Dorsher et al.,4 determined that of the 255 trigger points listed by Travell and Simons,
234 (92%) had anatomic correspondence with classical, miscellaneous, or new acupuncture
points listed in Deadman et al.,5 an internationally-recognized acupuncture reference book.
Modern authorities agree and describe dry needling as acupuncture.6,7,8 Mark Seem discussed dry
needling in A New American Acupuncture in 1993.9 Matt Callison describes dry needling in his
Motor Points Index10 as does Whitfield Reaves in The Acupuncture Handbook of Sports Injuries
and Pain:A Four Step Approach to Treatment.11 Yun-tao Ma, author of Biomedical Acupuncture
for Sports and Trauma Rehabilitation Dry Needling Techniques, describes dry needling as
acupuncture and provides a rich historical explanation of why.12
C. Chan Gunn, “Acupuncture loci: A proposal for their classification according to their
relationship to known neural structures," American Journal of Chinese Medicine, 197613 and
Peter Baldry, Acupuncture, Trigger Points and Musculoskeletal Pain: A Scientific Approach to
Acupuncture for Use by Doctors and Physiotherapists in the Diagnosis and Management of
Myofascial Trigger Point Pain, 2005,14 also acknowledge dry needling procedure and practice to
be equivalent to acupuncture procedure and practice.
These examples demonstrate a Western medical movement to rename the procedure and practice
of acupuncture as dry needling by providers other than acupuncturists. The examples listed
above affirm that there is a literary tradition acknowledging the term “dry-needling” to be
synonymous with acupuncture.
AAAOM | 866-455-7999 | info@aaaomonline.org Page 3 of 4
Concerns
The AAAOM has the following additional specific concerns:
1) No standards of education have been validly determined to assure that physical therapists
(PT) using TPDN are able to provide the public with a safe and effective procedure.15
2) Redefining identical medical procedures and thereby circumventing or obscuring
established laws regarding their safe practice is irresponsible
3) In many states, the addition of TPDN to physical therapy practice is being determined by
physical therapy regulatory boards, deleteriously circumventing transparency and public
health safety protections provided by standard legislative process
The U.S. Department of Education recognizes ACAOM as the sole accrediting agency for
acupuncture training institutions as well as their Master’s and Doctoral Degree programs.16, 17
Standards of training in acupuncture are well established, and designed to support safe and
effective practice.18, 19 Attempts to circumvent acupuncture training standards, licensing or
regulatory laws by administratively retitling acupuncture as “dry needling” or any other name is
confusing to the public, misleads the public as to therapeutic intervention expected, and, through
lack of meaningful education and practice regulation, creates a significant endangerment to
public welfare.
This actual risk of endangerment to public welfare has been investigated by at least one
malpractice insurance company that has stated it will cancel polices for physical therapists
“engaging in a medical procedure for which they have no adequate education or training.”20
Recent actions by state medical regulatory authorities have identified and acted upon the
aforementioned risk.21
In conclusion, the AAAOM strongly urges legislators, regulators, advisory boards, advocates of
public safety, and medical professional associations to carefully consider the impact of trends in
scope of practice expansion issues.

1 http://www.ncbi.nlm.nih.gov/pubmed/15108608
2 Janz S, Adams J. Acupuncture by another name: Dry-needling in Australia. Australian Journal of Acupuncture and
Chinese Medicine. 2011; 6(2)
3 Travell J, Simons D. Myofascial Pain Dysfunction: The Trigger Point Manual. Philidelphia, PA: Lippincott
Willimas & Wilkins; 1983.
4 Dorsher PT. Trigger Points And Acupuncture Points: Anatomic And Clinical Correlations. Medical Acupuncture.
2006;17(3).
5 Deadman P, Al-Khafaji M, Baker K. A Manual of Acupuncture. Kingham, Oxfordshire Journal of Chinese
Medicine Publications
6 When To Select Observational Studies as Evidence for Comparative Effectiveness Reviews Prepared for: The
Agency for Healthcare Research and Quality (AHRQ) Training Modules for Systematic Reviews Methods Guide
www.ahrq.gov Effective Health Care Program. "The AHRQ Training Modules for the Systematic Reviews Methods
Guide:..." The AHRQ Training Modules for the Systematic Reviews Methods Guide: An Introduction. Ahrq.gov.
Web. 06 Feb. 2012. <http://www.slideshare.net/AHRQEHCProgram/the-ahrq-training-modules-for-the-systematicreviews-methods-guide-an-introduction>.
AAAOM | 866-455-7999 | info@aaaomonline.org Page 4 of 4
7 Alberta Heritage Foundation for Medical Research Health Technology Assessment Unit. Acupuncture: Evidence
from systematic reviews and meta-analyses 2002 Mar.Used in glossary of "Acupuncture for Osteoarthritis." Centers
for Medicare & Medicaid Services. Web. 14 Jan. 2012. <http://www.cms.gov/medicare-coverage
database/details/technology-assessments-details.aspx?TAId=19>.
8 Acupuncture for Osteoarthritis. Rockville, MD: U.S. Dept. of Health and Human Services, Public Health Service,
Agency `for Healthcare Research and Quality, 2003. Print. This definition is also used in the glossary of
"Acupuncture for Osteoarthritis." Centers for Medicare & Medicaid Services. "Acupuncture for Osteoarthritis."
Centers for Medicare & Medicaid Services. Web. 14 Jan. 2012. <http://www.cms.gov/medicare-coveragedatabase/
details/technology-assessments-details.aspx?TAId=19>1
9 Seem M. A New American Acupuncture: Acupuncture Osteopathy, the Myofascial Release of the Bodymind.
Boulder, CO: Blue Poppy Press; 1993.
10 Callison M. Motor Point Index: An Acupuncturist's Guide to Locating and Treating Motor Points San Diego, CA:
AcuSport Seminar Series LLC; 2007.
11 Reaves W, Bong C. The Acupuncture Handbook of Sports Injuries & Pain. Boulder, CO: Hidden Needle Press;
2009.
12 Ma, Yun-tao. Biomedical Acupuncture for Sports and Trauma Rehabilitation Dry Needling Techniques. New
York: Elsevier; 2010.
13 Gunn, C. Chan. Acupuncture loci: A proposal for their classification according to their relationship to known
neural structures. American Journal of Chinese Medicine 4.No. 2 (1976): 183+. Print
14 Baldry, Peter. Acupuncture, Trigger Points and Musculoskeletal Pain: A Scientific Approach to Acupuncture for
Use by Doctors and Physiotherapists in the Diagnosis and Management of Myofascial Trigger Point Pain. 3rd ed.
Edinburgh: Elsevier/Churchill Livingstone, 2005. Print. ISBN 0 443 06644 2. Preface.
15 Commission on Accreditation in Physical Therapy Education (CAPTE) – Accreditation Handbook – November 2011
16 http://ope.ed.gov/accreditation/
17 http://www.acaom.org/about/
18 http://www.acaom.org/documents/accreditation-manual.pdf
19 http://www.nccaom.org/applicants/eligibility-requirements
20 Letter from Allied Professional Services [on file at AAAOM]
21 Letter from the Oregon Medical Board [http://www.oaaom.com/wp-ontent/uploads/2010/06/DryNeedling.pdf]

CommentID: 46643