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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2/23/17  1:16 pm
Commenter: Dr. Tracy L. Hackett, L.Ac., AP, DAOM; Eastern Holistic Arts PLLC

No to PTs to practice unlicensed acupuncture or "dry needling"
 

 

Physical Therapists are trained in "exercise sciences", not in invasive therapies like acupuncture. There are numerous documented cases of pneumothrorax, muscle, nerve damage, and immense pain during 'treatment' due to undertrained PTs inserting needles into patients too deeply or incorrectly. Simply because PTs claim "know where the muscles are" doesn't make them expert at applying class ll medical devices into those muscles and underlying structures. Acupuncturists undergo hundreds of hours of training on the techiniques and precautions of needling that have been develped over thousands of years that PTs blatantly disregard and are defiantly ignorant of (until it suits them to know where certain points are). They like to assert that the difference between dry needling and acupuncture is merely philosophical, which is a very thin argument of no substance, because the foundational physical fact remains that the needle pentrates the skin to have an intended effect is always - simply and unequivocally - acupuncture. I personally learned the so-called "dry needling" technique (translates into "lifting and thrusting" technique from Chinese) while studying in a Chinese hospital in 2005.

The actual definition of "dry needling" dates back to the 1940's when new, empty (hence, "dry") syringes were inserted into muscles spasms. It is a crude practice that caused significant pain and hematoma to the patient. PTs have appropriated the use of acupuncture needles illegally recently to be abe to market their otherwise brutish practice. Their use of acupuncture needles consitutes practicing acupuncture without a license. The FDA guidelines are very clear on this point. Not only should PTs not be allowed to practice acupuncture without the proper training, they should be censured for their illegal use of class ll medical devices that are specifically for the practice of acupuncture: 

"The classification regulation (21 CFR 880.5580) for solid, stainless steel, acupuncture needles requires that these class II devices must comply with special controls for single use labeling, prescription labeling, biocompatibility,

and sterility.
Currently, an acupuncture needle that is intended to pierce the skin in the practice of

acupuncture may be commercially distributed if it is the subject of a cleared premarket notification (510(k)), complies with the special controls, and meets all other applicable statutory and regulatory requirements." (https://www.fda.gov/OHRMS/DOCKETS/98fr/oc99318.pdf)

Physical therapists using acupuncture needles are techinically practicing acupuncture without a license as per the FDA's own definition of the needles PTs typically use for so-called dry needling procdures.  

Physical Therapists have also moved well outside of their scope on many occassions offering: "Cosmetic Dry Needling" "Dry Needling for Allergies" "Dry Needling for Migraines" in other states where compaints were filed to boards of health/medicine. Where will the scope creep end if they are allowed this practice in VA? PTs are not educated in invasive procedures nor are they educated in internal medicine, yet purport to treat it when they hold degrees for Exercise Sciences.

The "I love dry needling" comments should be ignored by the legislature. None of those commenters are experts on the subject nor can it be asssured or verified by the comments alone that those individuals have actually received the treatments. This is not a popularity contest, it is medicine and should be treated seriously to protect the public from grievous harm by PT profiteers. PTs are obviously trying to profit at the expense of the public with their low safety and training standards while accusing properly trained and licensed professionals working within their scope to bar the poor PTs solely on the basis of preventing them from earning a living. They only receive 12-20 hours of training and have a history of overreaching their scope frequently in several modalities across mutiple states, not just in the case of practicing acupuncture without a license. Such instances are well documented by several organizations.  If "exercise sciences" are not enough for them to make a living, then they should go to school (and spend the $100K+ to get the training) like the rest of us and procure the proper training and LEGAL licensing. 

CommentID: 57698