Dear Board of Physical Therapy, 

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. "Dry needling" IS Acupuncture and the regulations present a serious threat to public health.  The regulations would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy that has been adopted by the Virginia General Assembly.

I implore you not to draft regulations for the following reasons: 

1. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training that is required for licensed acupuncturists to practice acupuncture in the state of Virginia. 

2. 54 hours of training is a completely inadequate level of training to qualify a physical therapist to safely insert acupuncture needles into patients and the regulations therefore are a serious threat to public safety;

3. 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 nothing to support that the General Assembly ever intended to allow physical therapists to insert acupuncture needles into patients without the same level of training required for licensed acupuncturists. 

Thank you in advance for your consideration and right action where this very serious threat to public health and safety is concerned!

Sincerely, 

Kristina Aschenbach, L.Ac.