Public Comment to the Virginia Board of Physical Therapy

Opposing Proposed 18VAC112-20-121, Practice of Dry Needling.

Submitted by Michael Randolph, Citizen of Richmond, Virginia

February 22, 2017

I am writing this public comment to argue against the artificial distinction being made between acupuncture, practiced by physicians and traditional Chinese medicine practitioners (licensed acupuncturists), and so-called “dry needling,” practiced by physical therapists/athletic trainers, and any other profession seeking to do a weekend training program in order to perform acupuncture.

Whether a licensed acupuncturist, physician, or trainer/physical therapist is sticking needles into someone, it is an invasive procedure regardless of what the procedure is called, and that invasive procedure is acupuncture. 

Medical doctors and licensed acupuncturists receive a great deal of training and national certification in order to be qualified and licensed to perform acupuncture.  The notion that a trainer/physical therapist can perform acupuncture, or so-called “dry-needling,” without the extensive training and certification of medical practitioners as required in most states, is reckless on the part of the Commonwealth of Virginia.  “Dry needling” is the unlicensed practice of acupuncture in Virginia by physical therapists/trainers, and It is absurd that it has been allowed to get this far in the first place. Allowing trainers/physical therapists to do acupuncture without calling it acupuncture is akin to allowing trainers/physical therapists to dispense pharmaceuticals directly as long as they don’t refer to it as a drug. It is confusing to the public, and puts the public at risk

As a patient and citizen, it is my hope that the Commonwealth of Virginia will do two things: 1.) Eliminate the artificial and purely semantic distinction between “dry-needling” and acupuncture and state that sticking a non-hollow needle into someone for therapeutic purposes is acupuncture.  2.) Require that anyone practicing acupuncture, as defined in by Virginia law as: “The stimulation of certain points on or near the surface of the body by the insertion of needles to prevent or modify the perception of pain or to normalize physiological functions” have a level of training and national certification standards specific to acupuncture at a level commensurate to those for medical practitioners such as physicians and licensed acupuncturists.

As for me personally, the treatment modality of acupuncture, has been of great benefit to me over the years.  My first experience with acupuncture was to treat a rotator-cuff injury 20 years ago.  The practitioner was an MD specializing in Sports Medicine and was either a graduate of Harvard Medical School, or had completed his residency in one of their programs (I can’t remember which).  I was wary of acupuncture, but my physician explained it to me as a useful treatment modality that was poo-pooed by some for its use of historical/traditional terminology.   He assured me of his competency to practice acupuncture, having received many hours of professional and clinical training.  All my rotator-cuff problems were resolved with acupuncture and the specific exercises that he prescribed.  The experience left me impressed with the efficacy of acupuncture.

 Acupuncture again entered into my healthcare regimen to remedy episodically severe sciatica.  Having moved to Richmond, I used the services of a local licensed acupuncturist, who is nationally certified to practice acupuncture and Chinese herbal medicine. Previously I had sought relief from my sciatica through a physician and licensed physical therapist to no avail.  The combination of prescription muscle relaxants and PT exercises and ultrasound did not help (but I did receive an enormous bill).  Acupuncture solved the problem after three treatments.

I have continued to see the same practitioner for the past twelve years on an as-needed basis for two other problems. The first pertains to lower back pain resulting from a congenital defect in my spine.  The pain can at times be intense. My practitioner has developed an acupuncture treatment plan to address the muscle spasms and significant pain that is very effective.  After a short regimen of treatment I am pain-free for weeks to months.

The second health problem which has been helped, remarkably and to my great surprise, is gout.  During one visit to my licensed acupuncturist / TCM practitioner, for an unrelated problem (knee pain), I was in the middle stage of a gout-attack.  I have taken prescription medication for gout, but was at the time trying to manage my gout solely with diet.  My practitioner discussed my history with me, and the current symptoms, and worked out a treatment in addition to the knee pain treatment I had scheduled.  To my astonishment, the swelling and pain was greatly diminished by the time I left the office, and was nearly gone by the time I went to bed.  In light of previous flare-ups lasting more than a week, I found the results remarkable. 

It is my hope that the Commonwealth of Virginia will follow the lead of other states and require non-medical healthcare providers such as fitness instructors, athletic trainers, and physical therapists to undertake extensive training and undergo third party competency testing before they stick needles into someone so that no-harm is done, and the extensive benefits of acupuncture can continue to benefit the public.