Acupuncture is a procedure using a solid needle and several styles of insertion and manipulation techniques. Dry needling is one of the many styles that the Chinese refer to as "Ahshi" needling. Physical therapists do not receive adequate training to perform this procedure. Other states that have granted dry needling to physical therapists have had significantly increased reports of patient injury from physical therapists utilizing a tool - the acupuncture needle, as a treatment. The American Medical Association recognizes Acupuncture as a medical procedure and requires MD's to receive a minimum of 300 hours to utilize this in their practices. If an MD needs a minimum of 300 hours to use a solid acupuncture needle for acupuncture/dry needling techniques, physical therapists must be held to 300 hours or more, otherwise it would appear the state of Virginia recognizes a physical therapists training and knowledge is Superior to that of a Medical Doctor - MD.     Please require 300 hours minimum training and clinical training as the state of Utah did or prevent any use of needling by a physical therapist entirely.   Respectfully  Kris Justesen, OMD