I write in opposition to the proposed expansion of scope of physical therapists to include dry needling.  DN is a form of acupuncture and is an invasive procedure which carries with it the substantial risk of harm to patients.  Physical therapists are not routinely trained in the use of needles in practice, nor in the use of other invasive procedures.   To allow this scope expansion via administrative rule is profoundly irresponsible, circumventing all training and safety statutes put into place for the practice of acupuncture.  This puts the public at risk of harm, and is nothing less than flagrant consumer health fraud. 

There are no independently verified training requirements/competencies for Dry Needling, no certification testing, no longitudinal training pathways, and national experience has already shown that when given this opening to practice, physical therapists frequently expand into overt acupuncture practice.  Physical therapists seek this modality because it is a short-course, back door entry into acupuncture practice, and such behavior lacks professional integrity and sullies the reputation of physical therapists everywhere.  A 54 hour training requirement is meaningless and arbitrary, and based on no reliable data.  While we appreciate the sentiment behind a signed statement that the patient is not receiving acupuncture, in all fact, this is a falsehood and the patient is indeed receiving poorly trained acupuncture. 

I encourage Virginia to promote responsible regulation and quality medical practice and reject the current rules proposition.