"Traditionally, the modalities used in physical therapy have not involved the piercing of the skin, witness the treatments delineated in the definition above which do not involve invasive procedures." 

"Nor is it reasonable to conclude that the Board possesses the authority to so significantly expand the scope of practice to include dry needling through the regulatory process."

"Significantly (Acupuncture Regulations) does not include physical therapists among the practitioners authorized to engage in acupuncture -– a practice that explicitly involves the insertion of needles."

”treatment by means of manual therapy techniques and massage, electro- therapeutic modalities, the use of physical agents, mechanical modalities, hydrotherapy, therapeutic exercises with or without assistive devices, neurodevelopmental procedures, joint mobilization, "?