Dear Board of Physical Therapy,

I am a licensed acupuncturist in the State of Washington and I 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. The State of Washington recently ruled against a Physical Therapy group teaching Dry Needling in the State of Washington, as they declared that the PTs lacked the legal authority to practice “dry needling.” "Under Washington law, the physical therapy scope of practice does not authorize the insertion of any type of needle, including acupuncture needles, for the purpose of “dry needling”, and their practice of “dry needling” constitutes the unlicensed practice of medicine"(http://forwardthinkingpt.com/2014/10/16/washington-counts-ban-physical-therapists-from-practicing-dry-needling/)

I encourage you to follow Washington State's lead and not to draft regulations because:

1. 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;

2. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training required for acupuncturists and even medical doctors;

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 for considering my comments.

Sincerely,

Stephen Semptimphelter L.Ac.