I am a licensed acupuncturist and feel strongly that the practice of dry needling by Physical Therapists should not be allowed without Acupuncture training equivalent to that required by Acupuncturists.  I believe the proposed regulations present a serious public health issue and are clearly outside the scope of practice for Physical Therapists.  

Key reasons why the proposed regulations should not be approved include:

1) the use of an Acupuncture needle is Acupuncture and there is no difference between an Acupuncture needle and a "dry needle".  Dry Needling is Acupuncture and should follow the same training as required by Acupuncturists.

2) the scope of practice for Physical Therapists does not and should not include the insertion of needles as therapy.  This is an invasive procedure and requires appropriate training far beyond the 56 hours proposed.  

3) once the door is opened for Physical Therapists to practice dry needling on trigger points, there is no way to prevent them from using it other places on the body which, without proper training presents a public safety hazard.  One simple search on the internet will show that PTs in other states are abusing the " trigger point only" regulations in their states and in fact training programs are beginning to teach Acupunture points to PTs.

I  encourage you not to draft these regulations.

Sincerely,

Rawls Whittlesey, L.Ac.