Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Physical Therapy
 
chapter
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
Action Practice of dry needling
Stage Proposed
Comment Period Ended on 2/24/2017
spacer
Previous Comment     Next Comment     Back to List of Comments
2/24/17  4:13 pm
Commenter: Daniel J. Young ND LAc

Dry needling by Physcial Therapists - Opposed
 

Please do not allow Physcial Therapists to infringe on the practice and profession of acupuncture and place the poplulation at risk by allowing them to insert dry needles without adequate training. Even MDs, DOs, NDs, who practice acupuncture are required to have additional adequate training before inserting acupuncture needles. The fact that a Physcial Therapist is able to take a weekend seminar and then perform dry needling without proper training or even access to a crash cart is absurd. Just because they have the numbers and political clout to usurp the practice of acupuncture does not make it right and does place the public at risk!

Dry Needling is outside the physical therapy scope of practice. When the Virginia Legislature adopted the legal definition of physical therapy it had no intent to allow physical therapists to insert acupuncture needles and no authority for any similarly invasive procedures are allowed in statute. The Board of Physical Therapy lacks the legal authority to expand the physical therapy scope of practice to include dry needling and any attempt to do so would plainly violate state law.

Dry Needling is not safe. Dry needling involves the insertion of FDA-regulated acupuncture needles as deep as 5” into patients by physical therapists that can have as little as a weekend of training and no prior experience in the safe use of needles. 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. Not surprisingly, the American Medical Association recently explained in adopting a policy critical of dry needling, “Lax regulation and nonexistent standards surround this invasive practice … For patients’ safety, practitioners should meet standards required for acupuncturists and physicians.” The largest company insuring physical therapists recently called dry needling “an emerging area of risk” and documented numerous dry needling injuries.

Dry needling is the practice of acupuncture. Dry needling is simply another name for acupuncture as it has been practiced for over 2,000 years. Dry needling involves insertion of the same FDA-regulated acupuncture needles into the same “trigger points” that have been used in acupuncture for millennia for the same purpose of providing therapeutic relief. Claims that “dry needling” was an invention distinct from acupuncture because it is not based on “meridians” or “energy flows” reflects a gross misunderstanding of acupuncture and are not factually credible.r this text and enter your comments here.
For a Physical Therapist to insert a needle into one’s skin, the provider must have the same level of training as that required of an MD who practices Medical Acupuncture. Additionally, in June 2016, the American Medical Association released their position on Dry Needling. The AMA states that PT’s are inadequately trained to do dry needling.

“The AMA adopted a policy that said physical therapists and other non-physicians practicing dry needling should – at a minimum – have standards that are similar to the ones for training, certification and continuing education that exist for acupuncture.

“Lax regulation and non-existent standards surround this invasive practice. For patients’ safety, practitioners should meet standards required for licensed acupuncturists and physicians,” AMA Board Member Russel W. H. Kridel, M.D.” https://www.ama-assn.org/ama-adopts-new-policies-final-day-annual-meeting

The American Association of Medical Acupuncturists holds a position statement on dry needling:

http://www.medicalacupuncture.org/Portals/2/PDFs/AAMADryNeedlingPolicyOct15.pdf

…To include dry needling into the scope of practice by physical therapists is unnecessarily exposing the public to serious and potentially hazardous risks. Because of this we feel a duty to inform legislators and regulating bodies about the inherent danger to the public of this practice. Therefore, the AAMA strongly believes that, for the health and safety of the public, this procedure should be performed only by practitioners with extensive training and familiarity with routine use of needles in their practice and who are duly licensed to perform these procedures, such as licensed medical physicians or licensed acupuncturists. In our experience and medical opinion, it is inadvisable legally to expand the scope of physical therapists to include dry needling as part of their practice.

The Council of Colleges of Acupuncture and Oriental Medicine holds a position statement on dry needling by Acupuncturists:
http://www.ccaom.org/downloads/CCAOM_Position_Paper__May_2011_Update.pdf

… It is the position of the Council of Colleges of Acupuncture and Oriental Medicine (CCAOM) that dry needling is an acupuncture technique.
…It is the position of the CCAOM that any intervention utilizing dry needling is the practice of acupuncture, regardless of the language utilized in describing the technique.

CommentID: 58110