Dear Board of Physical Therapy,

I write to object to your plan to draft rules that will permit physical therapists to engage in “dry needling,” a form of acupuncture.

My concern stems primarily from my sense that the minimal level of training your rules propose would not adequately prepare a physical therapist to practice acupuncture safely. Thus, the “dry needling” the rules would authorize poses an unnecessary and unwarranted threat to patient health and safety.

I also believe the proposed rules authorize physical therapists to engage in acts that are outside the legal scope of practice for physical therapy as defined by Virginia’s General Assembly, and are therefore illegal.

Lastly, I believe your plan undermines professional acupuncturists who have studied for years to master an ancient art and science. Permitting physical therapists whose training—however excellent—is not focused on acupuncture to become de facto acupuncturists blurs important distinctions in the medical community. It serves neither the interests of the Physical Therapy community nor those of the well-established Acupuncture community.

Thank you for considering my concerns.