Trigger point dry needling and acupuncture are completely different. As a PT who has practiced dry needling for 5 years and received acupuncture, the difference is abundantly clear. The accupuncturist performs a completely different assessment and utilizes an entirely different rationale for inserting an needle. The PT trained in dry needling in accordance with the proposed regulations uses the insertion of a needle in conjunction with other modalities and exercise to treat muscles and spinal segments to enhance the outcome of a physical therapy treatment and provide a better, faster, more effective outcome to our patients. I have many patients who have received both acupuncture and dry needling and they are acutely aware of the difference. In addition, 86% of the training needed to perform dry needling is obtained by entry level PT's. The remaining  training is safely acquired when the proposed regulations are followed. 

To not allow PT's to perform dry needling as part of a physical therapy treatment would result in less effective care and suboptimal outcomes for our patients. Thank you.