I am a Licensed Acupuncturist in the state of Virginia. In the "Virginia Register of Regulations, Volume 32, Issue 7 November 30, 2015 the line "the disclosure to patients on the difference between acupuncture and dry needling." is impossible. Dry needling is acupuncture. The author of the proposed regulations probably has a limited understanding of acupuncture and it's many forms of practice which would be understandable unless written by an acupuncturist.   Acupuncture is an invasive therapy. Physical therapy is not. Acupuncturist train for 3 years to this end. Physical Therapists do not. The difference should not be minimualized.