To the Board of Physical Therapy,

I am a licensed acupuncturist, MA Lic #349, and a Diplomate of Oriental Medicine (NCCAOM), 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 urge you to honor the current law and choose NOT to draft legislation for physical therapists to practice acuouncture.  Dry Needling IS acupuncture and 92% of all trigger points correspond to acupuncture points. Students are taught from a text entitled Biomedical Acupuncture, using acupuncture needles. Dry needling IS acupuncture despite the narrative being spun. Putting a dry/filiform/acupuncture needle in any piint on a human body for any purpose is acupuncture.

1. 54 hours of training is a completely inadequate level of training to qualify anyone to safely insert acupuncture needles into patients and the regulations therefore are a serious threat to public safety. There have been multiple 

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.  This is a public health issue.

Thank you for your help, time and consideration.  New York, Washington, California and Illinois are among the states choosing to require acupuncture licenses to practice dry needling or acupuncture.   Therapists are well trained to practice techniques on the body acupuncturists are trained to do things in the body .  One pneumothorax is one too many there have been many and many states that allow dry needling . 

Respectfully,  Amy Mager 413.222.8616 AmyMagerHealing@gmail.com 59 Fairfield St., Springfield MA 01108