Dear Sir/Madam

As a licensed MD and Acupuncturist, I received 5 year in China to learn Traditional Chinese Medicine including acupuncture. I had my residency training in New York Medical College and I am board certified in Physical Medicine and Rehabilitation, I am the author of two acupuncture books, " Magic Needles" and " The Praeger Handbook of Acupuncture for Pain Management", I strongly oppose Dry Needling by PTs because of the following reasons, 

1. PTs are trying  to bypass acupuncture law.  By WHO definition, "Acupuncture literally means to puncture with a needle. However, the application of needles is often used in combination with moxibustion—the burning on or over the skin of selected herbs—and may also involve the application of other kinds of stimulation to certain points. In this publication the term “acupuncture” is used in its broad sense to include traditional body needling, moxibustion, electric acupuncture (electro-acupuncture), laser acupuncture (photoacupuncture), microsystem acupuncture such as ear (auricular), face, hand and scalp acupuncture, and acupressure (the application of pressure at selected sites).  "

http://apps.who.int/medicinedocs/pdf/s4926e/s4926e.pdf

2. PTs are violating FDA law.  Dry needling by its original meaning is hypodermic, sharp injection needles. Now PTs are using acupuncture needles to replace the hypodermic needles, which violated the FDA law.  

3. PTs are changing their scope of practice. In the history, generally speaking, PTs are not allowed to perform invasive procedures. However, they are trying to change their scope of practice.

4. The most important, it is a public safety issue. 60 hour post graduation course without any clinically supervised training in practice and examination, it is irresponsible to our patients' safety. Compared with MDs in US, we need 4 year medical school and at least 3 year residency training to receive license, then we also need at least 300 hours for acupuncture course and examination to receive our acupuncture certificate. 

Thank you very much for your understanding this issue. 

Best,

Jun Xu, MD