I am writing to oppose the proposed rules to allow physical therapists to practice dry needling with 54 hours training. Physical therapists continue to make the argument that dry needling is not acupuncture. As an acupuncturist who has been needling trigger points for almost 30 years, I can assure you that I am practicing acupuncture. Trigger point needling is one of many techniques that acupuncturists use to treat musculoskeletal pain. I believe some physical therapists have misrepresented acupuncture in order to circumvent the acupuncture licensing requirement. 54 hours of training is completely inadequate, in fact it’s not even close to being sufficient.

I believe the physical therapy profession is better than this. I have been teaching acupuncture at the New England School of Acupuncture since 1988. Acupuncture colleges are similar to physical therapy colleges, they take the time to train their students properly so they can practice competently and safely. Let’s have mutual respect for our respective professions.