Distinguished Board members,

PTs have been providing dry needling in Virginia safely for many years. There is no evidence of a public safety risk in Virginia. The established process in the guidance document is sufficient to prevent harm to the public and is sufficient to be entered into Virginia regulations. The issue determining whether dry needling is within PT scope of practice has already been determined, and is why physical therapists can currently use this treatment technique to improve the mobility and function of patients. Medical doctors refer patients for dry needling because they are confident physical therapists have the skills require to perform this intervention. We require 54 hours of additional training hours because the coursework physical therapists are given in a graduate program (now mostly always a doctoral level degree) is extensive enough to cover 86% of the knowledge and skill to perform dry needling (report published by Federation of State Boards of Physical Therapy and completed by an external agency). 

I support The PT Board in establishing through rulemaking the same requirements that have been in place in Virginia through a guidance document for more than 5 years. And, again, PTs have been providing dry needling safely under these requirements during this time. There has been no evidence of public harm during that time.

Thank you for your service to the public,

Amber Devers, PT, DPT, NCS