I am a licensed acupuncturist in the Commonwealth of Virginia since 1997.  I strongly oppose the incorporation of Guidance Document 112-9, regarding “Dry Needling “by Physical Therapists, into Regulation.

I have been involved in this “dry needling” conversation for years.  One reason that was repeatedly given for allowing the “dry needling” to continue was that “no one in Virginia has been harmed.” I objected that anyone would need to suffer harm before action was taken, but my comments always fell on deaf ears.  I know now of at least two documented cases in Virginia where someone was harmed by a physical therapist performing “dry needling.” The first case occurred on December 3, 2013 when a PT in Alexandria caused a pneumothorax by doing ”dry needling” on the upper back.  The patient was admitted to ICU and had a long recovery and much misery as a result of the “dry needling” incident.  The patient had a photo taken during her session with the needles in place, which I have seen.  Both the needle angle and depth are contraindicated in acupuncture treatment.  Based on my observation of the photo, the needles were deeply inserted all the way to the shaft with a perpendicular insertion angle in the region of the upper thoracic spine. A complaint was filed with DHP in February 2014, and there was no disciplinary action taken by the Board of Physical Therapy.  Since that time, I became aware of another case, as has been reported by Jodi Knauer, L.Ac. on this public forum, that occurred this year, during which her patient was treated in the hospital for pneumothorax as the result of “dry needling” by a physical therapist.

For the Board of Physical therapy to allow physical therapists to continue doing “dry needling” with the current grossly insufficient training that seriously injured at least two citizens of Virginia, then the Board of Physical Therapy has failed in its primary duty to protect the public from harm.

If a licensed acupuncturist were to place needles in the same anatomical location, with the same perpendicular insertion and depth of insertion, and it resulted in patient injury, that licensed acupuncturist would be deemed negligent and would likely lose their license to practice. However, to my knowledge, there is no report of a licensed acupuncturist causing a pneumothorax in Virginia during the  21 years that acupuncturists have been licensed to practice in the Commonwealth.  That is because licensed acupuncturists undergo rigorous training and education with direct clinical supervision, and then are required to pass a clean needle technique exam as well as national board exams administered by the National Certification Commission of Acupuncture and Oriental Medicine (NCCAOM).  Additionally, Virginia requires maintenance of NCCAOM certification status to renew an acupuncture license every two years.  Requirements to renew NCCAOM diplomate certification include continuing education units with ethics and safety at each renewal period.

This is not a case of turf war between professions, but a matter of public safety.  Again, in 21 years there has not been a documented case of pneumothorax from a LAc, but in just a third of this time, a PT has put at least two citizens in the ICU.  How many more citizens of Virginia will the Board of Physical Therapy allow to be injured by insisting that PTs are properly trained to do “dry needling”?

The bottom line is that “dry needling” is acupuncture.  Virginia Code: § 54.1-2900 defines acupuncture as:: "… the stimulation of certain points on or near the surface of the body by the insertion of needles to prevent or modify the perception of pain or to normalize physiological functions, including pain control, for the treatment of certain ailments or conditions of the body…”   “Dry needling” meets these criteria, and therefore according to Virginia law, “dry needling” is actually acupuncture.  Therefore it stands to reason that anyone practicing acupuncture must meet the education and examination requirements and be licensed to practice acupuncture.  I consider it highly narcisstic of the physical therapy profession to think that they can practice acupuncture with less training than a medical doctor.

In my own acupuncture practice, I have experienced an increased number of patients informing me of pain that has become worse following  “dry needling” treatment administered by a physical therapist. Many PTs are doing acupuncture beyond what the PT board has intended because the PT Board has no oversight over the practice of “dry needling”.  Patients have told me that their physical therapists have offered them “dry needling” for allergies, sinusitis, GI disorders, etc.  I have also questioned people as to needle placement and have too often heard that when having “dry needling” in the hip or back that needles were inserted into the foot.  Plain and simple, this is a distal acupuncture treatment strategy, and not one that is inherently found In trigger point “dry needling.”  I also ask if their insurance paid for “dry needling” and am usually told yes!  Since there is no insurance procedural code for “dry needling,” this can only mean that the PT is fraudulently billing insurance companies for a different procedure, likely that of manual therapy.  Again, no oversight by the PT Board, and one more way that Virginia citizens are harmed by PTs doing “dry needling”.  Insurance fraud results in higher insurance premiums for all.

I am proud to say that I do know two physical therapists of the highest integrity.  They went to acupuncture college, took the clean needle technique test, the board exam, and are licensed to practice acupuncture.  I fully support and respect these individuals, as well as those   physical therapists who get the proper education, clinical training, and licensure before treating their patients with acupuncture.

I call on the members of the Board of Physical Therapy to uphold the oath that they took when sworn into office, which is to protect the citizens of the Commonwealth of Virginia from harm.  There are many factual well-written comments submitted on this forum by leaders in the field of acupuncture, which all say the same thing:  “dry needling” is acupuncture with insufficient training, and is a danger to the public.  Please stop the illegal and unsafe practice of acupuncture by physical therapists in the Commonwealth of Virginia.

Respectfully submitted,

Lynn Almloff, DAOM, L.Ac.

Past President of Acupuncture Society of Virginia

Past Virginia representative to the Council of State Associations, now the American Society of Acupuncturists

Past Ethics Committee Member to the American Association of Acupuncture and Oriental Medicine.