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Dry Needling is one type of acupuncture and should be regulated by acupuncture laws

I am a licensed acupuncturist, with PhD of Anatomy and Neuroscience and am writing to object to the intent to draft "dry needling" regulations. I believe the regulations present a serious threat to public health and would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy as adopted by the Virginia General Assembly.

I strongly urge you not to draft regulations because:

*54 hours of training is a completely inadequate level of training to qualify a physical therapist to safely insert acupuncture needles into patients, let alone perform trigger point dry needling acupuncture effectively.  Trigger point acupuncture is sub-specialty involving one of the most invasive needling technique within our scope and the regulations therefore are a serious threat to public safety;

*Dry needling is a sub-specialty within the practice of acupuncture as defined under Virginia law and there is no basis for allowing physical therapists to practice acupuncture without commesurate educational and training requirements for acupuncturists and medical doctors;

*The dry needling rules are dangerous, because they would falsely imply to the public that physical therapists are adequately trained to safely and effectively treat trigger point related myfascial pain at the same level as medical doctors and licensed acupuncturists.  This is not only dangerous, but also deceitful as clearly the proposed lanaguage does not and can not match the leve of training in safety and efficacy of other licensed practioners of trigger point dry needling acupuncture. There is nothing to support 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 for considering my comments.

Heming Zhu, MD(China), PhD, CMD, LicAc

Professor of Integrative Health Sciences

Maryland university of Integrative Health