I support the development and enforcement of strict Regulations for the use of the advanced technique of Dry Needling.  Multiple reports of patient harm from this procedure indicate that the public is not sufficiently protected by the existing guidance documents. Specifically –

1. Photos of needles inserted to the handle and inserted to inappropriate depths given the location, along with reports of broken needles requiring surgery, pneumothorax, and nerve damage, show that the current 54 hour training and/or verification of that training is insufficient.  The Physical Therapy Board must determine whether the failure is with the total number of hours currently required, the caliber of the training, the number of clinical hours, or lack of verification of successful completion of the training. Any regulation must address the apparent shortcomings in the training of PT’s to use this advanced technique.
2. The burden of proof of proper training should fall on the Board, not the individual PT.
3. I appreciate the intent of the guidance document to educate patients as to the distinctions between dry needling and acupuncture.  However, photos and advertising of dry needling in Virginia and elsewhere show that Physical Therapists are not limiting themselves dry needling and are, in fact, doing acupuncture without training. Licensees are advertising “Cosmetic Dry Needling” and showing images of multiple needles in the face – an area unsuitable for the aggressive needle technique of dry needling. Physical Therapists are showing images of “dry needling” for headache with images of a needle in Large Intestine 4, a classic acupuncture point on the hand used for headache, far removed from muscular trigger points responsible for headache. Proper regulation of Dry Needling for Physical Therapists must include a clear definition of what Dry Needling is and language limiting its use to the release of trigger points directly related to the physician’s referral for Physical Therapy and recommendation for Dry Needling. This will be challenging given the broad overlap of the technique of dry needling with some specific techniques within acupuncture, however, every effort should be made. Additionally, the patient consent form should include the description of dry needling so that it is clear to patients when the Physical Therapist has stepped outside of the regulated procedure.
4. The distinctions between the field of Acupuncture and the modality of dry needling should not be defined in terms which encourage the description of acupuncture as unscientific.
5. Given the frequency with which patients express reluctance to file a complaint for harm they’ve experienced from Dry Needling, regulations should require licensees to self-report any known cases of harm that required medical attention or led to significant pain or symptoms lasting more than 5 days. In order to facilitate self-reporting these specific filings would not be used in disciplinary action but would be used by the Physical Therapy Board to determine whether the regulations are properly protecting the public.
6. The regulations should clearly state that Dry Needling is to be done only by the specific Physical Therapist who has completed the required training and that the PT must be in constant attendance while the needles are retained. No part of this technique is to be delegated to assistants or to other Physical Therapists.

I applaud the recognition that the advanced technique of Dry Needling requires rigorous regulation to protect the public. I support the efforts of this Board to adopt clear, careful, and enforceable regulation of their licensees regarding this technique.