Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Physical Therapy
 
chapter
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
Action Practice of dry needling
Stage Proposed
Comment Period Ended on 2/24/2017
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2/13/17  2:23 pm
Commenter: Jodi L. Emery, L.Ac.

PT do not have proper training to perform dry needling
 

I am writing in regards to the practice of dry needling by physical therapists.  I am a licensed acupuncturist in the state of Virginia.

Acupuncture is the insertion of micro-fine needles into various areas of the body to illicit a physiological response.  Various practices of acupuncture are utilized by properly trained practitioners.  This can inlcude the use of points on meridians, but also the use of Ashi points.  These points do not lie on meridians or channels, instead are points where there may be pain.  This can include trigger points or motor points of various muscles. In this regard, dry needling is no different than acupuncture.  It is not a separate or new practice.  Physical therapists that practice dry needling are simply ignoring a substantial part of this medicine and doing so without proper training.

The Board of Physcial Therapy does not have the authority to expand the physical therapy scope of practice to include dry needling.  Physical Therapists can NOT practice acupuncture and should therefore be unable to practice dry needling.  Acupuncture needles are to be purchased and used solely by licensed acupuncturists.  The use and purchase of these needles by Physical Therapists is against federal law.

The training for dry needling that physical therapist receive is no where near the training that acupuncturist undergo to perform this practice, or what medical doctor's must undergo to practice acupuncture.  A lack of standard training requirements open this practice up for safety concerns for patients.  Pneumothorax, internal bleeding and nerve damage are potential risks for patients undergoing dry needling by under-trained physical therapists.  To this extent large insurance companies are stating that dry needling is "an area of emerging risk." The American Medical Association is weary of physical therapists performing this therapy "lax regulation and nonexistent standards surround this invasive practice......For patients' safety, practitioners should meet standards required for acupuncturists and physicians."  

Further allowing this practice to be performed by physical therapists sets an unfair advantage. In no other profession can you simply rename something and allow undertrained individuals to practice.  I believe, this opens the door for further explotation of this medicine.

A personal example of this recently happened to me in my clinic.  I work with a patient who also sees a physical therapist.  Upon telling the physical therapist that she has found great relief with acupuncture, the physical therapist claims that she can perform dry needling.  (In this example the physical therapist is denying the difference between the therapies).  This patient has had dry needling in the past (at the same physical therapy clinic), which she found to be painful and not effective for her.  During a consultation with this patient, myself and her NP-C it was decided she would not have dry needling done to her, instead continue with acupucnture and her also started physical therapy sessions.  This patient returned to her physical therapist and told her that dry needling would not be ordered.  The physical therapist responded with "I can perform passive dry needling".  Passive dry needling is not a term I have heard before.  My patient explained that passive dry needling occurs when the needles are placed and then left for a time.  This in my mind is 100% acupuncture.  My stretching the scope of practice for physical therapists you have opened the door to some scary business practices and an increased risk for patient's safety.

Dry needling is a method of acupuncture.  Physical therapists do not have the proper training.

Thank you for your time,

Jodi L. Emery, L.Ac.

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CommentID: 56765