I am opposed to “dry needling” being performed by PTs.  .  “Dry needling” IS acupuncture.  Regulations and licensure exist to protect the public health.  Using the term “dry needling” to circumvent the regulations and the licensure requirements to perform acupuncture in Virginia poses a risk to public safety.  Allowing PTs to perform “dry needling”/acupuncture with only 54 hours of training poses a risk to the public.  Even medical doctors are required to have 200 hours of training to perform acupuncture in Virginia.

Thank you for considering my comments. 

Sincerely, 

Lisa E. Ray, M.Ac., L.Ac.