First, 54 hours of training for physical therapists vs 3000-4000hrs for acupuncturists is absurd to even call "Substantial Training" for physical therapists. Lack of theory and knowledge poses a serious threat to the patient and public safety!
Second, dry needling constitutes the practice of acupuncture under Virginia law no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training required for acupuncturists and even medical doctors; and
Illegal under VA Law. 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 no evidence that the General Assembly intended to allow physical therapists to insert acupuncture needles without the same level of training required for licensed acupuncturists.