To the Physical Therapy Board:

Throughout my course of training to become an acupuncturist, I have undergone 3,000 hours of master level training and 720 hours in clinical internships with supervision. A professional acupuncture curriculum must consist of at least 705 hours in Oriental medical theory, diagnosis and treatment techniques in acupuncture and related studies, 660 hours in clinical training, 450 hours in biomedical clinical sciences, and 90 hours in counseling, communication, ethics, and practice management.

To become licensed in the state of Iowa, I graduated from a master’s level nationally accredited university, passed four National Board Exams, and became certified in Clean Needle Technique. To keep my license I must complete 30 hours of continuing education classes every 2 years and hold a current active status as a diplomate in the NCCAOM.

This is because the National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM) and the state realizes the danger with inserting needles into the body and also the knowledge that is needed behind the needle.

While physical therapists may know the anatomy of the body very well, they may not be aware of all that is happening when you insert a foreign object into the skin. They are very knowledgeable and great at their job. My question is: why do they want dry needling to be allowed? I would assume it’s because the use of needles is effective. Which is wonderful news! However, just because the modality works and physical therapists want to use it, doesn’t mean they are qualified or licensed to do so.

Throughout any licensed acupuncturists’ training, they will tell you it is a lot more than just inserting the needle. The location, depth, angle, direction and even the amount of time the needle is retained has a certain affect. 

It seems those in favor of physical therapists performing dry needling will say the biggest difference in acupuncture and dry needling is that acupuncture is based on traditional Asian medicine and dry needling is based on modern western medicine. However, by definition of dry needling, acupuncturists are performing dry needling because the needles we use are dry- nothing injected through them. They are dry opposed to wet. This is where it gets cloudy and confusing. In my personal experience, whenever dry needling comes up, the person I’m talking to always brings up acupuncture. This is because acupuncture and dry needling are the same.

I have seen pictures of physical therapists’ work in “dry needling” where they have multiple needles angles all different ways located directly over the lung. I’ve also heard about physical therapists manipulating the skin and tissue around the needle after the needle has been inserted. This could easily lead to a broken needle in the skin! I’ve also seen patients who have been needled directly through their clothing! This is definitely not in compliance with Clean Needle Technique to ensure a clean needling environment so infection may not occur. This is very frightening to me for the safety of that patient and all patients who may go to someone who is not licensed.

I trust the state will make the correct decision to ensure all communities are protected and will ensure people who are inserting dry needles into the human body are properly licensed to do so.

Thank you for your time,

Emily Hurm L.Ac.