Dear Virginia Board of Physical Therapy:

Dry Needling is outside the physical therapy scope of practice. Dry needling is simply another name for acupuncture, which should be performed by trained and licensed acupuncturists, not physical therapists.  Licensed acupuncturists go through vigorous training for more than 3000 hours of study and clinical experience before they can perform acupuncture on patients.  Acupuncturists are regulated by state boards which require continuing education to maintain their professional status.  Physical therapists do not have adequate training in performing acupuncture, which is a medical invasive procedure. It would be very risky to patient safety if physical therapists are allowed to use "dry needling", especially because the draft regulations in fact provide NO MINIMUM TRAINING STANDARD WHATSOEVER. There have been a number of serious dry needling injuries across the country ranging from lung punctures to nerve damage.  Dry needling is a risky procedure if performed by any healthcare professionals who do not have enough training.  It would only hurt physical therapists' reputation when patients are injured and malpractice rate increased due to dry needling accidents.  Please consider public safety as a top priority and say no to dry needling. Thank you for your attention.