We strongly oppose the recommendation to allow PT's to "practice acupuncture", that is, to use acupuncture needles to practice "dry needling". While we are not opposed to having PTs learn acupuncture, the minimum requirement for training is WOEFULLY inadequate.  If medical doctors, who want to use the same acupuncture needles, are LEGALLY REQUIRED to have OVER 200 hours of training (and they have undergone rigorous medical and surgical rotations), it is absurd to have less than that for physical therapists who have far less baseline training than medical doctors.

We also ask that any injury caused by PT's using acupuncture needles is classified as a PHYSICAL THERAPY incident, not acupuncture incident (as it has been done in previously reported incidents).  The injury is driven by the inadequate training of the PT and not by an acupuncturist with thousands of hours of clinical training and didactic education.  We are unwilling to take responsibility for injuries caused by unlicensed practitioners.  We have enough issues reassuring our patients who have had horrible and painful experiences by PT's, we do not want the added burden of having our almost 0% injury risk raised artificially because a non trained practitioner used our tools to injure a patient.

The public deserves to have confidence that a licensed practitioner is, in fact, adequately trained for the procedure they administer. 

In health,

Amy Lewis, L.Ac., M.Ac., Dipl. Ac., President

Acupuncture Society of DC