Dear Interested Parties,

As a prior lawyer and current Dr of Oriental Medicine and Licensed Acupuncturist, I oppose dry needling as performed by Physical Therapists.  This is a blatant attempt to avoid the necessary training, degree and certifications required to perform this invasive and effective therapeutic intervention.  It further diminishes public perception of acupuncture (which is based on a medical classics over thousands of years old) and dilutes its putative effect especially given the dearth of training and oversight in this procedure. 

The primary concern involves public safety and welfare, as even MDs and Chiropractors must document over 300 hours of certified training to perform needling. 

The American Medical Association (AMA) released a statement in 2017 asking that only practitioners with experience with needles be licensed to use them http://www.asacu.org/wp-content/uploads/2017/06/AMA-Dry-Needling-Policy.pdf. The AAMA has specific and clear national standards requiring 300 hours of didactic training, supervised clinical hours, and the passing of a third party national psychometric exam.  The Current standards do not address even these basic concerns.

The language “certification” was used regarding one particular provider of dry needling training.  It is imperative to understand the difference between a certificate program and true national certification.  The National Commission for Certification in Acupuncture and Oriental Medicine (NCCAOM for acupuncturists and the AAMA for medical doctors both have Certifications requiring specific numbers of didactic hours, clinically supervised hours and a third party national exam.  https://www.nccaom.org/certification/board-examination-process/ http://www.dabma.org/

Secondly, it is a gross intersection into our scope of practice as needling is the core modality that defines acupuncturists as a profession. Other oriental therapies such as cupping, Gua She have already been implemented in many PT offices and it is unsafe and unfair to allow PT's to "take over" all modalities of our medicine without the proper training, guidance, testing and detailed supervision.  This is not good for the public because it further dilutes the clinically proven effectiveness of acupuncture which is why PTs want to copy us in the first place. It is a great medicine but they should have requisite training to practice it.

Thirdly, the insurance industry grossly discriminates against acupuncturists in favor of PT's using dry needling for coverage and this further impacts our protected scope of practice and also endangers public safety. I have met many who equate dry needing with acupuncture and the public perception is not being helped by PTs using dry needling which is also unethical. I hold a medical doctorate in Oriental Medicine and I posses educational hours rivaling the doctorates in Physical Therapy. I personally have over 5000 hours in an in-residency doctoral program. Yet I am not covered by the majority of plans in Virginia, and PTs practicing Dry Needling get to routinely perform this with less than 60 hours of training. This is unethical, wrong and actually embarrassing. 

It should be about education, public safety, and public awareness, integrity of practice and knowledge. Dry Needing is actually acupuncture and should be performed by acupuncturists. Calling is a different name is simply a "wolf in sheep's clothing." Common sense goes a long way here as "Dry Needling" is relatively new on the PT horizon and they have been using our tools (acupuncture needles) and CPT codes (until this past year) and evidential research to promote acupuncture by another name.  The only reason this has been allowed to go on is because of big PT lobby that drowns out the voices of smaller acupuncture lobby. Furthermore, acupuncturists are not know for making waves or trying to be aggressive etc.; however, this is overt and unethical attempt to avoid the appropriate training and infringes on our established profession and hurts public awareness in choices that could relieve pain.  

Thank you for your consideration. 

Keith M Loop, JD, DSOM, LAC, LMT, CYT