Acupuncturists practice many different styles including orthopedic dry needling and all of them require acupuncturists who practice in VA to meet the standards required by the NCCAOM to sit for and pass the required NCCAOM exams to demonstrate competency.

there are no independent, agency accredited vetted  programs for "dry needling", no standardized curriculum, no means of assessing competence of instructors in the field, and no independently administered competency exams.

Physical therapy entry level training does not include meaningful preparation for the practice of invasive procedures like dry needling that require additional training.  The proposed regulation does not identify specific post graduate training hours nor specific dry needling continuation education hours nor does it require independent testing to show competency as required by acupuncturists to obtain a license to use a metal needle for therapeutic purpose.

Dry needling is not safe when performed by undertrained professionals who have not been vetted for competency and have the ability not to harm.  Current training and lack of independent testing in inadequate to protect public safety and consumers.  Medical doctors practicing acupuncture must have 300 hours of training to satisfy the minimal standards of training in acupuncture. to become members of AAMA, the American Academy of Medical  Acupuncture.  The AMA, the American Medical Association passed a resolution in June of 2016 stating: "Our AMA recognizes dry needling as an invasive procedure and maintains that dry needling should only be performed by practitioners with standardized training and familiarity with the routine use of needles in their practice such as licensed medical physicians and licensed acupuncturists."

This regulation puts an invasive procedure into a scope of practice  without  requiring standardized,advanced, specific training in the classroom, clinic and appropriate third party examination which does not exist.  I urge you to reject this proposed change and not allow dry needling in the physical therapy scope of practice.