Attention: Virginia Board of Physical Therapy       

Re: Rule Making for "Dry Needling"

I am writing in opposition to the proposed rule making authorizing physical therapists in Virginia to perform "dry needling."  Dry Needling is acupuncture. Acupuncture is the practice of medicine. The term “dry needling” originates from the use of empty hypodermic needles, thus “dry”, used to pierce the skin in order to effect the underlying tissues therapeutically without an infiltrate such as lidocaine, procaine, or saline solution, for the sole purpose of reducing and alleviate pain associated with so called trigger points by a physician. 

One such physician, Dr. Janet Travell, M.D., developed a methodology to treat myofascial trigger points and resulting referred pain pattern. The methodology she developed and taught to physical therapists did not include so called "dry needling" instead she taught physical therapists her "spray and stretch" technique. 

The Medical establishment in the United States has a very long history of the use of acupuncture for treating pain exactly like the exquisitely painful points described in the literature published by Dr. Janet Travell, M.D. I encourage you to read Sir William Osler’s 1920 classic', "The Principles and Practice of Medicine." His chapter on Diseases of the Locomotor System (pg 1122) offers a very clear description of the use of acupuncture for lumbago.  

As a reminder:

1. § 54.1-2900.  of Virginia’s Medical Practice Act defines as acupuncture as:

"Practice of acupuncture" means the stimulation of certain points on or near the surface of the body by the insertion of needles to prevent or modify the perception of pain or to normalize physiological functions, including pain control, for the treatment of certain ailments or conditions of the body and includes the techniques of electroacupuncture, cupping and moxibustion."

The State of Virginia's Physical Therapy Practice Act does not provide as part of the scope of physical therapy practice to perform acupuncture or any invasive needling technique by alternate names. It further establishes a requirement to refer when a necessary when it states: "It shall be unlawful for any licensed physical therapist to fail to immediately refer any patient to a licensed doctor of medicine, osteopathy, chiropractic, podiatry, or dental surgery, or a licensed nurse practitioner practicing in accordance with his practice agreement when such patient's medical condition is determined, at the time of evaluation or treatment, to be beyond the physical therapist's scope of practice. Upon determining that the patient's medical condition is beyond the scope of practice of a physical therapist, a physical therapist shall immediately refer such patient to an appropriate practitioner.”