I understand and am accepting of the fact that professions evolve over time, as a way to better serve the public. However, I am not in favor of dry needling - paritcularly as it is expressed in this regulation - for a variety of reasons. Most important: the proposal identifies no minimum training hours, standards of competency or regulations for testing competencies. 

Historically, physical therapy has been a medical profession that has not trained or engaged in invasive procedures, such as needling. Now that they are proposing for their scope-of-practice to include needling, there is a clear lack of absolutely necessary education, training and regulation for needling. As an acupuncturist, I have had over 3,000 hours of needling education, practice/training and supervision. I am required to follow stringent standards in regulations set forth by the VA Board of Medicine. In order to become a licensed acupuncturist, we must have a certain number of hours in education and training as well as take a series of three examinations in order to just apply for the license to practice. The proposal for PTs to needle does not include any explicit standards for education, training and licensing. There are no standards.

Why is this important? It puts the patients of dry needling by PTs at risk. Without explicit training requirements and standards that regulate who can needle (based on their education and training, and penalties for not meeting those regulations), there may be PTs who practice needling without true knowledge of the potential risks of needling. For example, this may lead to an increase in pneumothorax and other punctured organs (due to misunderstanding of needling depth and technique in certain areas of the body) and increase in bruising, hematomas and other adverse side effects. There may also be an increase in contamination/infection by use of more aggressive needling technqiues and using the same needle to puncture skin in various areas - if even on the same section of the body. 

If PTs are to engage in needling, then there needs to be a CLEAR process for education and training, certification, skill assessment and penaltites for those who do not follow the regulations. Even medical doctors and chiropractors who engage in 'acupuncture' are certified by a board and have a certain number of training hours absolutely required before they can become certified and/or licensed. And these are professions who have worked with invasive procedures on patients in the past. 

PTs in other states have also put forth proposed regulations allowing them to practice needling; however, as you can see in final reviews such as from Washington Department of Health, they denied adding needling to the scope-of-practice for PTs for the same reasons listed above (Information Summary & Recommendations: Physical Therapy Dry Needling Review, John Wiesman, DrPH, MPH, Decemeber 2016). In particular, the regulation for Washington stated 54 hours of training and even that number was deemed insufficient for "an invasive procedure with potential serious risks of patient injury," that no clinical supervised experience was required, and the level of education requried for dry needling has not been met by the majority of PTs. 

If this regulation was to move forward as it, it would be a true disservice to health professions and, especially, the public.