The American Society of Acupuncturists opposes the addition of “Dry Needling” to the practice of other professional groups on a number of grounds:

1. The practice is ill-defined, and there is no specific technique or curriculum which clarifies or directs this practice.  Courses around the country are not standardized and no curriculum is approved.  Many courses teach acupuncture points and techniques under the guise of “dry needling”, and practices are essentially practicing acupuncture and using this packaging to avoid proper training and state law. 
2. There is no independent, third party testing to assure minimal competency in practice.
3. The safety of acupuncture is known to be directly related to the training of the practitioner.  The more inadequate the training, the higher the risk of patient injury.  Training for “dry needling” is brief and non-standardized.  This puts the public at risk.  See:  4 Chan MWC, Wu XY, Wu JCY, Wong SYS, Chung VCH. Safety of acupuncture: overview of systematic reviews. Scientific Reports. 2017;7(1):3369. Published 2017 Jun 13. doi:10.1038/s41598-017-03272-0
4. Dry needling is clearly acupuncture.  Claims to the contrary come from individuals with inadequate knowledge of the field of acupuncture, and this claim is used again to by pass state laws that have been put into place to assure public safety.  Texts used in some “dry needling” classes include those such as “Biomedical Acupuncture” by Yun Tao Ma. 
5. Around the country, physical therapists are expanding practice to include “dry needling” for sinus congestion, menstrual dysphoria, and other internal medicine issues.  Oversight by physical therapy boards has been ineffective in managing the expansion of treatment into the domain of internal medicine, thereby putting the public at risk.  There is no reason to believe that the situation in Virginia will be different.  https://www.thephysiocompany.com/blog/physiotherapy-for-sinus-pain, https://www.kinetacore.com/about/news/clinical-pearl-desensitizing-the-migraine-functional-dry-needlingreg-approach/, https://waset.org/publications/10004906/dry-needling-treatment-in-38-cases-of-chronic-sleep-disturbance, https://integrativedryneedling.com/dry-needling-training/why-attend-integrative-dry-needling-courses/
6. The only other professional group that has added acupuncture to its scope is Medical Doctors.  The industry standard for this group, which is the most-highly trained of all medical professionals, is 300 hours.  It is indefensible to presume a professional group with lesser training should be competent at only 27-54 hours.  This puts the public at risk.