| Action | Practice of dry needling |
| Stage | Proposed |
| Comment Period | Ended on 2/24/2017 |
 |
Letter to Virginia Board of Health:
2/2/2017
I participated in a recent hearing regarding Dry Needling for Physical Therapists - Possible Expansion of Scope of Practice in WashingtonState. I am a licensed Physical Therapist for 28 plus years in Washington State, with licenses in three other states before moving here, and a Licensed Acupuncturist and East Asian Medicine Practitioner for 12 years in WashingtonState. I appreciate that licensing keeps the consumer safe with the knowledge that they are in well trained and qualified hands with a Medical Practitioner who is trained adequately to treat them safely and effectively within a specific medical practice. I spoke against this expansion of scope of practice for the following reasons:
1) Training PTs in a two weekend course to do “Dry Needling” which is Acupuncture without the proper license, is hazardous to the consumer, and eventually will lead to higher liability insurance for Physical Therapists and a lack of trust by the consumer of Physical Therapists as qualified to treat them effectively with any modality. Those who argue that dry needling is different than Acupuncture are stating this based on the idea that to understand anatomy so extensively gives one the ability to probe into the skin and make changes to the underlying tissue, with no regard for a system of medicine that has been doing just this for over 1500 years successfully and with minimal harm to patients. Acupuncture has ALWAYS been based on anatomy, pathology, physiology, etc., from the start of it. Anatomy, pathology, physiology, etc., are not recent “Western” innovations! As a Licensed Acupuncturist, I have to say that as soon as the needle goes through the skin and into living tissue, everything changes. No amount of cadaver work in a laboratory is going to prepare you for this.
2) There is an argument that there is a study in Ireland , the Brady Study, which shows that “Dry Needling” by Physical Therapists has been shown to be safe. This study asked over 170 Physiotherapists to reply about whether or not they had injured a patient with “Needling”, and less than 40 Physiotherapists replied to the study, and only 35 participated. Since it was voluntary, you can imagine that if a Physiotherapist had injured a patient, she/he might be less likely to respond to the survey. This is not sufficient to constitute proof of safely performing Dry Needling without proper Acupuncture training. Also, Physiotherapists have Needling in their Scope of Practice in Ireland, and therefore have taken educational coursework and training in Acupuncture, so it is like comparing apples to oranges.
3) Similarly in the UK, which was also used as a place where Physiotherapists do Dry Needling, the Physiotherapists are under the supervision of Medical Doctors, so that any Acupuncture they are doing has been approved and is being directed by a Medical Doctor. This is not the scenario we are talking about in Washington State.
4). When issues were addressed around the Classes that are being taught to Physical Therapists by other Physical Therapists in Arizona specifically, it was said by J. Dommerholt, a PT from Maryland, that the PT who was teaching the classes unsafely in Arizona was no longer teaching these classes. This Physical Therapist was providing very minimal supervision, was not using safe clean needling technique, and was encouraging PTs to begin working on their patients back at their clinics after just 18 hours of lecture and 9 hours of very minimally supervised Acupuncture needling, This Physical Therapist, Susan Falsone, PHD, PT has been teaching Athletic Trainers in Arizona how to do “Dry Needling”. Now this is very scary! Athletic Trainers are minimally trained in Anatomy and Physiology, and are not considered Medical Professionals in any way, shape, or form. This is an example of “you give and inch, and they take a mile.”
According to an Acupuncturist who attended one of these courses, Susan Falsone, PT, is teaching acupuncture points and calling them auriculo-stimulation points (anything not to mention the word acupuncture) , and she is teaching electro-acupuncture, cupping, and very definite acupuncture point usage for patients with musculoskeletal injuries. These are all within the scope of Acupuncture practice specifically, and not Physical Therapy. In this course there are 30 participants, and the modeling for needling would not be considered medically safe. She reinserted needles that are only supposed to be inserted once, a violation of OSHA standards. This is the “quality” of training that Physical Therapists are receiving on a daily basis in “dry needling” workshops and classes.
5). The needles that we use in this country as Acupuncturists, which are the same needles that the Physical Therapists are calling filiform needles, have a warning label on them, and I quote: “Caution: Federal law restricts this device to sale by or on the order of qualified practitioners of acupuncture as determined by the States.”
Since the Physical Therapists are adamant about the point that they are not doing acupuncture, they really should not be using acupuncture needles that are only for the use of Acupuncturists and Medical Doctors who are certified to do Medical Acupuncture. The AMA has put out a statement that Dry Needling is Acupuncture, and therefore should be governed by the laws of each State for Acupuncture.
NO “DRY NEEDLES” HAVE BEEN APPROVED BY THE FDA, new brands have been approved but ONLY as Acupuncture needles.
6) As far as Training to do Acupuncture as a Physical Therapist, as a dually licensed Practitioner of Acupuncture and Physical Therapy here is what I believe to be reasonable: Acupuncture practice does require a foundation in Bio Medicine, 450 hours of Basic Western Sciences, which could be waived for a Physical Therapist as allowed by the school Acupuncture/East Asian Medicine program. Clinical hours involve more than 600 supervised hours in an Acupuncture Clinic as well as 150 plus hours of observation of a Licensed Acupuncturist. Coursework includes at least 750 hours of Chinese Medicine Theory and Application. A clean Needling weekend course is also necessary to fulfill all requirements to practice Needling safely.
I don’t think there is much more to be said about this except that the studies are flawed touting the efficacy of Dry Needling. We should not compare Physiotherapists trained in other countries to what the training is in our country to determine whether they should perform acupuncture or not without a license, and we need to really look at what is safe and effective for patients to protect not only the patient but both of our professions.
Dual licensure is the only way to ensure health and safety for the consumer. Washington state has ruled that PTs
cannot do Dry Needling,with their concept of 52 hours of training by Physical Therapists to safely perform acupuncture without a license.
Sincerely,
Washington State
Sent from my iPhone
Sent from my iPhone