I am a licensed acupuncturist who opposes the proposed regulations that would allow the performance of acupuncture by physical therapists. I know the proponents of the regulations present it as allowing "dry needling" by physical therapists, but the term "dry needling" is a semantic sleight of hand to avoid regulations limiting the practice of acupuncture to those who have had adequate training.

Dry needling involves the insertion of an acupuncture needle into the body, just as acupuncure does. There are no distinct procedural differences between acupuncture and dry needling. Dry needling proponents claim that the technique is distinguishable from acupuncture because its effects can be described in Western terminology. Whether you call the technique acupuncture or dry needling, these effects are identical (and much medical literature now exists describing the physiological effects of acupuncture in Western medical terminology).

What does distinguish the two is the amount of training required to perform them. The proposal to allow physical therapists (or any profession, for that matter) to practice the insertion of acupuncture needles with just over 50 hours of training is truly alarming. The training and educational requirements for acupuncturists exist for a reason: public safety. Please do not sacrifice the safety of your citizens by enabling a brazen attempt to circumvent scope of practice laws. If someone requires acupuncture to regain his/her health, they already have access to properly trained acupuncturists thanks to the current laws and regulations.

I strongly urge you to oppose these proposed regulations. Thank you for your consideration of this important matter.