I attended the Kiiko Mastumoto acupuncture education training event in Columbia Md. in mid October. The president of the Maryland Acupuncturen Society gave a lunchtime presentation and made the case of untrained physcial therapists who are performing acupuncture services called "dry needling techniques" without proper training where patient injury has occurred in these events.  I would urge the board to stay abreast of the option for  physical therapists to perform acupuncture without proper training. 

In short make the established rules for acupuncture licensure training should apply to physical therapists.  I attended a school in Florida where the training and licensure requires 1800 hours of didactic hours along with 500 clinic hours.  Currently the state of Virginia also requires N.C.C.A.O.M. license requirements as well. Ensuring the proper application and use of acupuncture services for the safety of  the public is a reflection of the medical professsion as a whole.  Being proactive and protecting the public from harm the board should use it's regulatory power to enforce complete training for the application of acupuncture services within the physical therapy realm of it's jurisdiction.