I am a person with Multiple Sclerosis who has experienced dry needling by physical therapists on several occasions.  It has always given me immense relief from pain when so much else has failed, including near death from pain medication and acupuncture.  Dry needling has also improved my gait...amazing that relaxing taut muscles with dry needling can lead to such terrific outcomes and improved mobility.  Physical therapists are IMO quite qualified to perform dry needling and certainly need to retain the capacity to do so as outlined in the proposed regulations..

Acupuncture is quite different than dry needling and there is no comparison between the two.  Dry needling needs to remain in the purview of trained physical therapists.