Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Physical Therapy
 
chapter
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
Action Practice of dry needling
Stage NOIRA
Comment Period Ended on 12/30/2015
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12/30/15  7:37 pm
Commenter: Kellie Krasovec, L.Ac., MSOM

OPPOSE "Dry Needling" by PTs
 

Please prevent the use of "dry needling" by Physical Therapists.

I have been licensed and practicing as a Licensed Acupuncturist since 2005.  In the past few years, the number of PTs who have added acupuncture-like treatments, labeled as "dry needling" has multiplied exponentially.

I understand that PTs are providing this invasive technique after completing as little as 45-54 hours of training.  Additionally, they begin inserting and aggressively manipulating these acupuncture needles, after an hour or so of lecture.  In an acupuncture school, students are not permitted to insert needles until they have completed approximately 1-1.5 years of training on depth and angle of insertion.  Manipulation techniques are not permitted until they have successfully demonstrated knowledge of physical and depth location of vital organs, bones, tendons, arteries, veins, and nerves.  As should be the case with all healthcare providers, the first order is "Do no harm".  Dry needling seminars, and subsequent techniques, do not hold this standard of care.

I cannot count the number of patients who come to me telling me they have previously had acupuncture, by their Physical Therapist.  If the person receiving this treatment believes it is acupuncture, because dry needling IS acupuncture, then we have to consider that dry needling is acupuncture without sufficient training.

If the state requires thousands of hours of training before being able to be licensed to perform acupuncture, then all who choose to use this modality must be equally educated and trained.  Oregon and Washington have recognized this and acted morally and accordingly, for the best care of their citizens.

I encourage the board to consider the statements here from practitioners who hold both PT and L.Ac. licenses, who recognize the deficit and danger of allowing those with a PT license to perform these procedures with often no more than weekend long classes.

You do not want to be the person or board who opened the door to additional patient harm, including pneumothorax.  This has been documented by others commenting (see Lynn Almloff's comment), so does not need to be repeated.  Although I have heard of a few cases in Colorado of pneumothorax from dry needling by PTs or DCs, I have yet to hear of one due to a Licensed Acupuncturist.  It all comes down to proper education and training.  The reporting of adverse reactions via dry needling is also worrisome, and dangerous.

I encourage the board to take a long term view of what is in the best interests of their state, their community members and the safety of all.  I urge 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 well-written comments submitted on this forum by leaders in the field of acupuncture, which basically say the same thing:  “dry needling” is acupuncture with insufficient training, and is a danger to the public.

CommentID: 48744