Dear Board of Physical Therapy,

I am a licensed acupuncturist and am writing on behalf of all of our Licensed Acupuncturists at our 4 clinic locations in Minnesota to object to the intent to draft "dry needling" regulations. We 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.

We 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;

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;

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.

Part of our training requires learning over 400 acupuncture points. We learn and are tested repeatedly in graduate school and on National Board Exams regarding point location, safe needling depth, safe needling angle, physical structures under the point, contraindications & risks, cautions such as "deep perpendicular or oblique insertion carries a substantial risk of causing a pneumothorax," several functions of the point, clinical applications, and combinations that can be used with other points. It takes years to learn how and where you can needle safely without risk of harming your patients and this is not something that can be learned in a weekend course. If Physical Therapists want to practice acupuncture, they need to be trained as acupuncturists from accredited graduate schools, pass the National Board Exams, and comply with other regulatory agencies all of which Licensed Acupuncturists must to do legally practice.  The bar for acupuncturists to practice is set extremely high for a reason. Don't allow under trained Physical Therapists to practice dry needling/acupuncture when there would be legal consequences for a non-licensed person who tried to practice acupuncture without training. 

Sincerely,

Licensed Acupuncturists at Chinese Acupuncture and Herb Center.