The CMS CPT code committee of the AMA equated dry needling and trigger point acupuncture in the language creating its new CPT code.

It is imperative to include in the regulations a specific definition of dry needling the echoes TrP, trigger point acupuncture as the insertion of a needle, manipulation of the needle and removal of the needle. No needle retention and no electric stimulation.

it is vital to clarify that a third party exam be passed by all practitioners of dry needling, not an exam given by the instructors of dry needling courses. Both medical acupuncturists and licensed acupuncturists must pass third party exams. I urge you to include the language “third party national exam” in your language.

To meet best practices, I implore you to include a 500 hour requirement of dry needling specific training. Medical acupuncturists who are licensed medical doctors who have experience in needling must take 300 hours of AAMA, American Academy of Medical Acupuncture, approved courses and pass a third party exam. Licensed acupuncturists who practice many styles of acupuncture including dry needling, must have 1,305 acupuncture specific didactic hours and pass 4 national psychometric exams. To meet similar standards, asking for 500 didactic hours and 100 supervised clinical hours will only protect patients. 

Regulations must require an individual to attain and demonstrate the necessary knowledge, skills, and competence certified by an accrediting body not associated 
with the for-profit company providing the dry needling/trigger point 
acupuncture course. I am concerned that the general public is unaware of 
the vast difference in education and practice experience of persons 
performing such an invasive procedure. Often the person receiving care 
is in such discomfort that they don’t ask about the practitioner’s 
licensure, experience, or ability to perform needling/trigger point 
acupuncture in this manner. The individual trusts that their practitioner is competent and possesses the necessary training for the 
practice they deliver. It is up to our legislators, regulators and Governor to 
ensure that the Commonwealth remains a leader in progressive and safe 
medical care.

Please ensure that specific hours both for education and continuing education are specific and required by regulation and law.

Please ensure that a specific third party national exam be required both to demonstrate competency and the ability not to harm.

Please include language specifically stating that the practice of dry needling include the insertion of a needle, manipulation of a needle and removal of the needle.

When we expand scopes of practice, then we need to make sure they are within best medical practices to protect consumers of healthcare within the Commonwealth.

Respectfully,

Amy E. Mager DACM, Lic.Ac., FABORM

National Board Certified Acupuncturist

Vice Chair, American Society of Acupuncturists

Chair, Acupuncture Society of MA