Ladies and gentlemen, Thank you for the opportunity to enter comments, Here are mine: - The term "dry needling" is a pseudonym for acupuncture. - The term "trigger points" is a pseudonym for acupuncture points. - The needles used for dry needling are acupuncture needles. They are FDA Class III medical devices, the sale of which is restricted to qualified acupuncturists. - The practice of dry needling by PTs is a subset of acupuncture practice. - Physical therapists practicing dry needling with insufficient education, training, and competency testing have caused serious injuries and represent a threat to public health. - Physical Therapists do not currently have the requisite education, training, and independent competency examinations to safely practice the subset of acupuncture called dry needling. I do not feel PTs should be disallowed from practicing dry needling. However to insure public safety and uniform standards of care there should be regulations that require PTs to receive education, training, and competency examinations similar to those required of acupuncturists and MDs who also practice acupuncture. Thank you and best regards. Sincerely and respectfully, Kevin McNeeley