To Whom It May Concern:

The definition, process, and materials used in dry needling are, without a doubt, parallel with acupuncture practices. Dry needling is clearly a subset of acupuncture itself. Our state requires those practicing acupuncture to be strictly educated and fully licensed. Additionally, acupuncturists are required to perform continuing education in order to maintain their license. These standards are necessary to minimize the risk of injury and infection. So I do not understand how 50-something hours of training can be adequate in the eyes of any state board. Just like a licensed acupuncturist, people certified to perform dry needling will be inserting metal instruments (acupuncture needles, to be precise) into human bodies, and there is always a risk of injury to organs or introduction of infection. In the words of William Shakespeare, "What’s in a name? That which we call a rose / By any other name would smell as sweet." Dry needling IS acupuncture, no matter what you call it. Therefore, it should be held to the same standards of training, licensing, and practice.

Regards,

Ashley Pfeil