The regulation in discussion identifies dry needling as “an advanced procedure that requires additional training.” It does not recommend or require any specific post-graduate training hours. We already have "additional training" options available to anyone who wants to practice acupuncture safely and effectively ... it's called acupuncture school.  Any practitioner of acupuncture who comes through an approved acupuncture graduate program can sit for his/her state's licensing exam, pass it, and proceed to bring its benefits to his/her clients.  Anyone who thinks a few hours of weekend coursework in "dry needling" is an acceptable substitute for a thorough education and training in the art of acupuncture is fooling themselves as well as those who would be effected by their "dry needling."  I strongly encourage you to reject the efforts of PTs (or anyone else) to practice the medicine we strove for years to learn and to protect, without their having first obtained sufficient training (i.e., a Masters or Doctorate level degree in the field).  Anything less is negligence and a danger to your citizens and our profession.

Thank you for your time,

Don Gates, L.Ac.