I am writing on behalf of the Acupuncture Society of Virginia to express my opposition of the Virginia  Board of Physical Therapy “s would allow physical therapists in Virginia to Dry Needling. Below are 3 points which support my concerns:

1. Substandard Training. 54 hours of training is a completely inadequate level of training to qualify a physical therapist to safely insert acupuncture needles into patients and the regulations therefore are a serious threat to public safety. Typically, an acupuncture candidate undergoes 3200 hours of academic training which 1800 hours is dedicated to acupuncture 350 patients in an internship.
2. DN Constitutes Acupuncture Practice. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training required for acupuncturists and medical doctors.
3. Illegal under VA Law. The dry needling rules are illegal, because they would allow physical therapists to engage in acts that are outside the legal scope of practice for physical therapy as defined by Virginia's General Assembly. There is no evidence that the General Assembly intended to allow physical therapists to insert acupuncture needles without the same level of training required for licensed acupuncturists.