I am in opposition of this regulation regarding dry needling or “trigger point dry needling” since it is not within the scope of practice of physical therapists and is indeed an acupuncture technique which involves additional training, both didactic and clinical, and licensing in the state of Virginia which physical therapists do not have or qualify for. The public has been and will be placed at risk as they are unformed about the lack training physical therapist are taking before practicing dry needling, that there is no standardized in training or accountability in place nationally or on a state level to prove to the public that those practice dry needling are competent in the needling process and that they are receiving acupuncture by unqualified practitioners to treat pain or any other condition.  

It should be noted that in multiple areas throughout the country the issue of physical therapist’s practicing dry needling is being examined indicating that this is more than a state issue.  The hundreds of comments already submitted during this 30 day open commenting period both for and against this regulation also demands notice that this is not the simple issue that was discussed by the Task Force that was formed in 2008 to create the Guidance Document referenced in this regulation.  I respect the time and effort that those on the Task Force gave, but there is no presented evidence as to where these recommendations came from or are based on.  There are no other states with Guidance documents in the practice of dry needling by physical therapist to even refer to.  There is also a lack of education with physicians and patients as to what is dry needling or “trigger point dry needling” so when asked they are unaware of the similarity to acupuncture and at time of treatment physical therapist are making their own recommendations  for this procedure without physician referral, once again placing the patient at risk.

I work with pain management patients who also receive care and are referred to PTs and I respect the work and education PTs have.  The “trigger point dry needling” methods are not taught to PT students alongside other manual therapy techniques because it is not a manual therapy nor should it be billed to insurance as manual therapy which is also currently being done.