Thank you for soliciting input on this issue. I am a licensed acupuncturist, although one who has long advocated that physical therapists and licensed acupuncturists should work together in an integrated fashion to improve patient outcomes. I believe the turf wars over dry needling are counterproductive and both sides should be communicating about how to integrate respective skills for the patient’s wellbeing. 

That being said, I believe the manner in which physical therapy boards in many U.S. states have voted to approve dry needling as being within the scope of practice of physical therapists in indefensible. Any honest evaluation of how these events have taken place makes clear such actions violate those boards’ responsibility to protect the public.

It is really very simple: more than 20 U.S. state physical therapy boards have voted to include dry needling into their state’s physical therapists’ scope without first undertaking a legitimate study regarding what additional training should be required to expand the scope in a safe and effective manner. The first attempt by the PT boards to do such a study was only just published this July (Analysis of Competencies for Dry Needling by Physical Therapists Final Report.  Prepared for:  Federation of State Boards of Physical Therapy July 10, 2015).

This report plainly states:  “Since 2010, jurisdictions have sought information from the Federation of State Boards of Physical Therapy (FSBPT) regarding the ability of physical therapists (PTs) to perform dry needling; however, no publically available studies have explicitly examined what PTs must know and be able to do to perform dry needling safely and effectively.” And: “The Task Force’s primary objective was to identify knowledge, skills, and abilities that are specifically needed for competency (in) dry needling.”

This is a classic case of “Ready-Fire-Aim”. For years the FSBPT remained silent as state PT boards expanded PT’s scope without bothering to study the issue. In doing so, they are holding needling therapy to a lower standard of oversight than the less invasive procedures of conventional physical therapy these boards are entrusted to regulate.       

The push to bring dry needling into PTs scope was primarily driven by those who profit from teaching weekend “certification” workshops to physical therapists not by that profession’s leadership seeing a need. Had that need been recognized, there would have been a study done first and consideration given to reaching-out to the acupuncture profession for input. That did not happen and the acupuncture community began to cry foul and now, after years of inaction by leadership while this scope grab took place, a study was finally done. What conclusions did this task force arrive at? It found:   

“(86%) of what PTs need to know to be competent in dry needling is acquired during the course of their entry-level education, including knowledge related to evaluation, assessment, diagnosis and plan of care development, documentation, safety, and professional responsibilities. Advanced or specialized training (e.g., dry needling course, residency program) is required for 16 of the knowledge areas needed for dry needling and these are almost solely related to the needling technique (e.g., selection, placement, and manipulation of needles; identification of contraindications).” 

And further:

“The Task Force defined specialized training as a full course on a particular topic or set of topics—short (e.g., half-day) workshops do not fulfill this requirement”—and recommended that “opportunities to practice actual needling should be incorporated into and provided immediately after the training to reinforce learning.”

Unfortunately, the task force did not make any recommendation regarding the number of hours of “additional, specialized” training that would be required. They punted on that important issue with the following political double-talk:

“Although additional training is needed for the development of psychomotor skills (as well as the 16 knowledge requirements noted previously), there does not appear to be widespread agreement regarding the minimum number of practice hours necessary (Kalichman & Vulfsons, 2010).”

While the report refused to address the topic of the number of hours this additional training requires it did state that 86% of the needed knowledge was already included in a PTs entry-level education so some simple math will give a ball-park figure. Although exact hours vary somewhat from state to state, most PT entry-level training will involve at least 3,000 hours so 14% above that would be an additional 420 hours. When you put all the findings in this report together you arrive at the following:

In order to teach physical therapists “what PTs need to know to be competent in dry needling” they need somewhere around 420 hours of “advanced or specialized training” including a “residency program” that is “almost solely related to the needling technique (e.g., selection, placement, and manipulation of needles; identification of contraindications)”. Furthermore, “short (e.g., half-day) workshops do not fulfill this requirement” and “opportunities to practice actual needling should be incorporated into and provided immediately after the training to reinforce learning.”

There is not a single training program for physical therapists in the U.S. that follows this one and only set of researched guidelines (including the training that lead to “certification” taken by those “experts” on this task force). Any physical therapy board that approves dry needling as being within the scope of the PT’s they regulate but does so without at a minimum following the above recommendations, is violating their mandate to protect the public.

Many PTs will no doubt claim that they need to be allowed to use dry needling as it is such an important therapy and their patients depend on it. While it is a positive development to see the physical therapy profession come to the realization that needling therapy is a truly important modality to ease pain and suffering it is perplexing that that same profession is not in the habit of working with licensed acupuncturists.

Considering there are no training programs that follow the recommendations in this task force report to insure “competence in dry needling” for physical therapists, why is it that physical therapists do not routinely seek to have their patients receive care from more fully trained acupuncturists? Do they seriously believe that a weekend course or two to learn dry needling as an “add-on” to their main, entry-level physical therapy training renders them superior needle therapist compared to those whose entry-level training specializes in such therapy? If PTs care about their patients receiving this valuable treatment, why do they not reach-out to the acupuncture community to work together? This should especially be happening when you consider that traditionally trained acupuncturists also have the training to treat conditions seen in the physical therapy setting that are not treatable by dry needling such as post-stroke or head injury neurologic recovery.  

I am not sure what the State of Virginia’s regulations may be regarding PTs’ obligations for making appropriate referrals. It may not be within your board’s purview to compel PTs to recognize and refer patients to acupuncturists when they could benefit from needling therapy or even to recommend that PTs reach-out to the acupuncture profession to work together for the well-being of their patients. I am sure, however, that it is your responsibility to protect the criticizes of Virginia from having needles stuck in them by physical therapists that do not at least meet the training standards detailed in the task force report commissioned by the U.S. Federation of State Boards of Physical Therapy.

The “dry needling certification” mills need to be shut down if there is to be any credibility given to training PTs in dry needling and the physical therapy boards need to be held accountable to their public protection mandates. This task force report was a good first step to bring some much needed integrity to this issue. I encourage anyone in a leadership role within the physical therapy community that wishes to engage in constructive dialog with the acupuncture community to contact the Acupuncture Now Foundation. Both professions owe it to our patients to work together.          

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