Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Physical Therapy
 
chapter
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
Action Practice of dry needling
Stage NOIRA
Comment Period Ended on 12/30/2015
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12/23/15  7:30 pm
Commenter: David Bibbey

Dry Needling is Acupuncture
 

Dry Needling is Acupucnture.  Virginia statutes that protect the public and define licensure requirements for practice of Acupuncture should be observed fully when considering the legal use of Dry Needling in the State.  A minority of practitioners practicing Physical Therapy have coopted Acupuncture devices and techniques under the guise of a new modality.  There is nothing new or unique about Dry Needling; it has been previously detailed and described  in both Traditional and Modern Chinese Medicine texts.  Dry Needling proponents continue to seek state-by-state scope of practice expansion through Board Rule  to include Dry Needling, which is an invasive skilled intervention while misrepresenting Dry Needling (Acupuncture) as a manual therapy. There are many genuine concerns that need to be considered starting with public safety.  The same statutory language that governs the practice of acupuncture should be applied to those seeking to practie Dry Needling.  These modalities are ONE in the SAME.  How would the Virginia legislature or Board of Medicine handle introducing a medical modality that sought perform tooth extractions by non-Dentists?  Really, what if PT's coined a technique called, Oral Ligament Release that simply "released" the ligament that hold a tooth in the head or jaw.  What if the PT's answer to questions about practicing Dentistry without a license was that tooth extraction by Oral Ligament Release had nothing to do with the underlying principles of Dentisty; it simply deals with elimiating tooth pain by tieing one end of a string around the affected tooth and the other end around a door-knob and slamming the door shut.  It's very effective at elimiating tooth pain, and has nothing to do with periodontal concerns or practicing Dentistry.  Of course, this would been seen as an unreasonable risk to public safety, and a breach of the scope of practice act that guarantees that Dentisty is practiced by Dentists and Surgeons.  Much in same way, what PT's are seeking is to practice acupuncture, or stated another way, provide patients with the benefits of acupuncture care without the inconvenience and investments of time and expense required to be a licensed Acupunturist in Virginia.  Please pause and understand that there are reasons why roofers don't do plumbing and plumbers don't do heart catherizations, and cardiologist's don't pour concrete footings.  Areas of specialized work require specialized training, examination, licensure and regulation to protect the public and to maintain professional standards.  A path to training and licensure already exists to practice Acupuncure in Virginia - it is open to anyone interested-in inserting acupuncture needles into the human body for improving or correcting a health concern.  Please be sure that anyone / any profession seeking to treat patients with acupuncture / dry needling follows the path already prescribed in Virginia Law.   Best in healh, David

CommentID: 46914