I am a licensed acupuncturist and I am writing to object the dry needling regulations being set for physical therapists. I am not completely opposed to physical therapists from dry needling but I am stating that 54 hours is not enough hours to be knowledgable in the safety and proper techniques for dry needling. When there is a lack of proper education In acupuncture, there is a high risk of patient injury therefore leading patients to discredit acupuncture as a reliable form of patient care. These regulations put many patients at risk and may even prolong injuries and can even injure muscles that were not injured to begin with.

Any traditional specialty certification for a physical therapist requires a minimum of 300 hours or a whole year in a residency program. Universities with Doctor of Physical Therapy programs require students to do a minimum of 80 hours of SHADOWING which is STILL more than the necessary 54 hours for physical therapists to be qualified to dry needle. As a professional in this field, I strongly suggest increasing the hours required to be qualified in dry needling to 300 hours or more. By doing so, this will prevent putting patients at risk, prevent any discrediting acupuncture as a viable form of medical care, and insures that the physical therapist is highly knowledgeable about dry needling.

Both licensed professionals spent many countless hours studying to become professionals in their field and it would not be right if one professional could do the others job in 54 hours of studying compared to over 3000 hours they put in. If all it took was 54 hours to be qualified to dry needle, it would be considered a "easy" treatment option that required minimal efforts. What patient would feel safe receiving a treatment that their medical professional only studied 54 hours in? Would you send your loved ones to a professional with only 54 hours of schooling?

After all, I'm sure physical therapists would feel slightly offended just like us if licensed acupuncturists were only required to do 54 hours to be qualified to perform physical therapy on a patient.