Corrine Gutierrez L.Ac., MSOM

                            Boulders Acupuncture & Natural

                                   Healthcare

                            7315 Boulders View Lane

                            Richmond, VA  23225

To the Virginia Board of Physical Therapy

As a licensed Acupuncturist practicing for the past 12 years, I oppose the proposed regulation that would authorize physical therapists to practice acupuncture in violation of Virginia law. 

Dry Needling is outside the physical therapy scope of practice as defined by the Virginia Legislature.  The Board of Physical Therapy lacks the legal authority to expand the physical therapy scope of practice to include dry needling and attempts to do so plainly violate state law.

One of the biggest risk to patients is Dry Needling is just not safe.  The draft regulations provide no minimum training standard whatsoever.  Dry needling involves the insertion of FDA-regulated Acupuncture needles as deep as 5” into patients by physical therapists that can have as little as a couple hours or weekend of training and no prior experience in the safe use of needles.  My sister is a physical therapist and in school had only a  2 hour training after which she along with other physical therapy students would have the “skills” to perform Dry Needling on patients.  Commendably, my sister had the courage and ethics to stand up and voice her opposition and refuse to treat patients in this method as she understands the years of education and clinical training required to practice Acupuncture which is exactly what Dry Needling is - the practice of Acupuncture.  Claims that Dry Needling was an invention distinct from Acupuncture because it is not based on meridians or energy flows reflects a gross misunderstanding of Acupuncture and are not factually credible.  Even medical doctors with extensive training in the use of invasive medical devices, such as acupuncture needles, need to have 300 hours of training in Acupuncture (including 100 hours of clinical training) to satisfy the minimal standards for certification from the American Board of Medical Acupuncture.

It is my sincere hope that the Board will oppose the proposed regulation that would authorize physical therapists to practice Acupuncture in violation of Virginia law, first and foremost for public safety and additionally my concerns set forth above.

Sincerely,

Corrine Gutierrez L.Ac., MSOM