I believe the regulations present a serious threat to public health and would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy. 

Trained acupuncturists, have already the scope of trigger point acupuncture in the scope of practice. Why there is need to have PT to do the same thing? With only 40 hours or less training? There has been several incidence of serious injuries from dry needling by some physical therapists. Public does not need to have one more, especially under your board supervision! I have more than 3000 hours and 4 years of training with needles/ acupuncture. Acupuncturist had to take clean needle techniques (CNT) and national board exams and needle competency testing before being able to practice. To allow physical therapists to use the exact same needles in the exact same points (please note many dry needling training seminars are actually teaching and using acupuncture points!) with ridiculously little training would be considered negligence by the board. 

Dry needling is outside the legal scope of practice for physical therapy as defined by Virginia General Assembly. There is nothing to support that the General Assembly ever intended to allow physical therapists to insert acupuncture needles into patients absent the same level of training required for licensed acupuncturists.  

Thank you for considering my comments.