Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist 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 that has been adopted by the Virginia General Assembly. I encourage 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 and the regulations therefore are a serious threat to public safety.

Thank you for considering my comments. 
  
Sincerely, 
HyunKyu Choi. L.Ac