To:  Virginia Town Hall
Re: Oppose the dry needling practice by Physical Therapists in Virginia with so little training

I am a licensed acupuncturist and am writing to object to the proposed "dry needling" regulation in Virginia.  

I believe the proposed regulations are not good, because:
 
20-30 (even 54) hours of training is a completely inadequate level of training to qualify a physical therapist to safely insert acupuncture needles into patients and the regulations therefore are a serious threat to public safety. As you know, medical doctors need minimal 300 hours training in acupuncture/needling in order to practice acupuncture or use so-called dry needling. WHO suggests non-physicians should have minimal 1500 hours training in needling medicine to practice acupuncture/dry needling(WHO has clear definition that dry needling is acupuncture);
 
Dry needling constitutes the practice of acupuncture under Virginia and FDA law and there is no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training required for acupuncturists and even medical doctors;
 
Dry needling is outside the legal scope of practice for physical therapy as defined by Virginia's 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  acupuncturists.
 
Best regards 

Helen  Wang