Dear Legislative Committee:

I am writing to you to implore you to take a second look at this idea of "Dry Needling" as within the scope of Physical Therapy practice.  I would like you to consider my input as a Licensed Physical Therapist in Washington state since 1991, and a Licensed Acupuncturist since 2005.  I have also held Physical Therapy licenses in Massachusetts, South Carolina, and Georgia.  

Allowing a Physical Therapist to provide "Dry Needling", which in reality is a form of Acupuncture, within their scope of practice, is an expansion of scope that exceeds the Legislature's intent as expressed by Statutes regarding Physical Therapy.  This form of treatment is not included in the statutes in Washington state at all.  There is an argument that it could be considered under manual therapy or electromyography (RCW 18.74.160), but this is not accurate. Manual therapy does not include puncturing the skin with a needle or minimally invasive surgery, nor does electromyography, using a needle for purely diagnostic purposes to assess the health of muscles and nerves, nor does it include what Physical Therapists are now trying to do.

The term "Dry Needling" was first described 2000 years ago in China's earliest and most comprehensive medical treatise, "the Yellow Emperor's Inner Classic", where it discusses using painful trigger ports or motor points to treat pain and dysfunction, and manipulation of the needle at this point.  This was an ancient form of acupuncture point selection.  Acupuncture has progressed since then, and acupuncture points have been proven to be valid within meridians of energy in the body.   My contention is that Physical Therapists are using this term "Dry Needling" so they do not have to follow the guidelines that are set up for safe practice of Acupuncture,and disregarding the thousands of years of practice and theory that it entails.   PTs want to create  their own way of doing Acupuncture, in order to attempt to get the results that we as Acupuncturists get with patients who experience pain or muscular dysfunction, and have not resolved their condition with Physical Therapy alone.

The Washington State Legislature has made it very clear that invasive procedures or modalities involving skin penetration be written into the Statute.  Acupuncture is a profession that has been around for centuries, and there is a specific form of training which makes it safe for practitioners to practice this form of medicine.  I studied Acupuncture for 5 years and did 100 hours of observation and 200+ clinical hours in Acupuncture one-on-one supervised treatment, as well as sitting for a National Board Exam in order to be certified to practice Acupuncture. 

There have been people injured by non-Acupuncturists who are performing Acupuncture on them without a License.  In my own practice, I witnessed a patient who had been treated by her Osteopathic Doctor with needles in her back, to help her with back pain.  He did not have a License to practice Acupuncture, yet he felt he could help her with Acupuncture needles directly in her spinal area.  She unfortunately had increased pain and it took a month of Physical Therapy sessions to help her to resolve this pain. I was an Acupuncture student at the time, and was seeing this patient in my Physical Therapy practice.  

The FDA has classified Acupuncture needles as a Class II medical device subject to strict regulation under the federal Food, Drug, and Cosmetic Act (FDCA) and FDA's regulations.  Individuals who attempt to purchase Acupuncture needles without a license to practice Acupuncture are violating both civil and criminal provisions of the law intended to protect public safety.  (21 U.S.C. 331 (a)-(c).

Furthermore, Studies of "Dry Needling" have been inconclusive as to its medical efficacy, and therefore should not be considered as an expansion of scope of practice without conclusive evidence that this form of medicine is valid.  It is truly up to the Legislature to determine a profession's scope of Practice and significant changes must be decided by a Legislative body. 

As a Physical Therapist, I am dismayed that my colleagues would think they could do this without the proper licensing. I anticipate lawsuits happening when patients are injured in these procedures, and later find out that the Physical Therapist was not trained to do this adequately to protect the patient from harm.  As an Acupuncturist, I am outraged that another profession would consider that they could get enough training in a two weekend seminar to do what it took me 5 years to learn, not to mention passing a National Board examination and obtaining a license to safely practice Acupuncture. 

I would be happy to discuss this further with you at a time that is convenient for you if you have any questions.

Bridget Boylan, PT, EAMP Licensed Acupuncturist

bbptacup@yahoo.com

(425) 876-2255