OPPOSED to Dry Needling a.k.a. Acupuncture by Physical Therapists

May I have your listening?  I strongly oppose the recommendation to allow PT's to "practice acupuncture", that is, to use acupuncture needles to practice "dry needling".  Such a technique is known as "needling ah shi points" in acupuncture.  While PTs have extensive training in the assessment and treatment of muskulosketal conditions, they have inadequate understanding of the principles of Chinese Medicine, and the implications of inserting acupuncture needles.  While I am not opposed to having PTs learn acupuncture, the minimum requirement for training is grossly insufficient.  If medical doctors, who want to use the same acupuncture needles, are LEGALLY REQUIRED to have OVER 200 hours of training (and they have undergone rigorous medical and surgical rotations), it is absurd to have less than that for physical therapists who have far less baseline training than medical doctors.  

To reiterate:

1. 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;

2. 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 required for acupuncturists (thousands of hours) and even medical doctors; 

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 absent the same level of training required for licensed acupuncturists. 

I also ask that any injury caused by PT's using acupuncture needles is classified as a PHYSICAL THERAPY incident, not acupuncture incident (as it has been done in previously reported incidents).  The injury is driven by the inadequate training of the PT and not by an acupuncturist with thousands of hours of clinical training and didactic education.  I am unwilling to take responsibility for injuries caused by unlicensed practitioners.  I have enough issues reassuring my patients who have had painful experiences by PT's that have hindered and complicated the progress of their acupuncture treatment, and I do not want the added burden of having my almost 0% injury risk raised artificially because a non-trained practitioner used our tools to injure a patient.

The public deserves to have confidence that a licensed practitioner is, in fact, adequately trained for the procedure they administer.   

Thank you for your consideration.

Sincerely,

Nell Carr-Young, L. Ac., NCCAOM