To:  Virginia Town Hall

Re: Oppose the dry needling practice by Physical Therapists in Virginia with so little training

I am a licensed acupuncturist and am writing to object to theproposed "dry needling" regulation in Virginia.  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. This would be the equivalent of me performing orthopedic adjustments on my patients. Yes, I could probably figure it out but I am not a qualified expert with enough training to responsibly care for patients in this way. The patients do not know the difference in training and it is up to the health department to protect them. As I know from my own practice and online resources, I have seen multiple patients with serious injuries from dry needlingby some physical therapists. I have yet to see any injury from a licensed acupuncturist. I have more than 3,000 hours and 4 years of training with needles/ acupuncture. I had to take clean needle techniques (CNT) and national board exams and needle competency testing before being able to practice. To allow physical therapists to use the exact same needles in the exact same points (please note many dry needling training seminars are actually teaching and using acupuncture points!) with ridiculously little training would be considered negligence by the board. 

I believe the proposed regulations are not good, because: 

20-30 (even 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. As you know, medical doctors need minimal 300 hours training in acupuncture/needling in order to practice acupuncture or use so-called dry needling. WHO suggests non-physicians should have minimal 1500 hours training in needling medicine to practice acupuncture/dry needling(WHO has clear definition that dry needling is acupuncture);

Dry needling constitutes the practice of acupuncture under Virginia and FDA 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; 

Dry needling is 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.  

Thank you for your time

Sincerely,

Zhisheng Sun