Dear Board of Physical Therapy, 
  
I am a student of acupuncture and am writing to object to the intent to draft "dry needling" regulations.  I believe the regulations present a serious threat to public health and would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy that has been adopted by the Virginia General Assembly. 
  
I encourage you not to draft regulations because: 
 

1.   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. I am not allowed to insert needles professionally until I meet the minimum of 1,905 hours of entry-level acupuncture education to include at least 1,155 didactic hours and 660 clinical hours as stated in the Regulations Governing the Practice of Licensed Acupuncturists by the Virginia Board of Medicine, pass the NCCAOM & get my license;

2.   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 even medical doctors. Last semester, I took a needle technique class where I learned acupuncture techniques from the Neijing/The Emperor’s Inner Canon, an ancient Chinese medical text that has been treated as the fundamental doctrinal source for Chinese medicine from the second century BCE. One needling technique is called “Fen Ci” which means muscular needling. The method means to insert the needle directly into the muscles. The clinical application of muscular needling/Fen Ci is to treat muscular pain, flaccidity or old wounds at acupuncture points, which could also be trigger points. Another needling technique is “Hui Ci” or rehabilitating needling. This method helps restore function to a muscular region. This is established by inserting the needle beside the joint and asking the patient to move the joint while repeatedly changing the direction of the needling to relieve spasm of the tendons. The clinical application is to treat cramps of musculature by needling around the affected area. These are just some acupuncture needling techniques that sound like the generalized definition of dry needling to me: the use of solid filiform needles (acupuncture needles) for therapy of muscle pain. Yet the 2000+ year old Neijing defines these as acupuncture needling techniques. This is what is being taught in acupuncture schools, tested on by NCCAOM & accepted for acupuncture licensure by Virginia under Virginia law. Dry needling = acupuncture.

3.   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 nothing to support that the General Assembly ever intended to allow physical therapists to insert acupuncture needles into patients absent the same level of training required for licensed acupuncturists.  See #1 & 2.

  
Thank you for considering my comments. 
  
Sincerely, 
  
April Enriquez

www.aprilenriquez.com