Dear Board, 
  
I am a professional acupuncturist and am writing to object to your draft "dry needling" regulations.  These regulations present a threat to public health and would authorize physical therapists to engage in acts that are outside the scope of practice for physical therapy as adopted by the Virginia General Assembly, and as generally accepted throughout the U.S.. Allowing this would be the equivalent of me performing orthopedic adjustments on my patients with a weekend of training. Yes I could probably figure it out but no I am not a qualified expert with enough training to responsibly care for patients in this way. The patients don't know the difference in training and it is up to the board to protect them. There are numerous documented cases of serious injuries resulting from dry needling by Physical Therapists. Injuries from acupuncture performed by a licensed acupuncturist are extreemly rare. Licensed Acupuncturists have 3000 hours and 3-4 years of training with needles. There are national board exams and needle competency testing required before being able to practice. To allow physical therapists to use the exact same needles in the exact same points (dry needling training seminars are actually teaching and using acupuncture points!) with ridiculously little training would be dangerous. 

I encourage you to consider the following: 
 

1. 54 hours of training is a completely inadequate level of training to qualify anyone to safely insert acupuncture needles into patients.
2. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture. 
3. The dry needling rules are illegal, because they would allow physical therapists to engage in acts that are outside the legal scope of practice for physical therapy as defined by Virginia's General Assembly. There is nothing to support that the General Assembly ever intended to allow physical therapists to insert acupuncture needles into patients absent the same level of training required for licensed acupuncturists.  

  
Thank you. 
  
Sincerely,  John Barnett, L.Ac.