Dry needling in an invasive procedure, which physical therapists (PTs) do not historically have education, training or practice in. As such, needling has not been included in their scope-of-practice. This regulation, as is, would essentially allow a procedure that poses serious health risks to patients if performed without stringent training and certification to be performed by those without proper education, training, certification, and guidelines. In other words, many PTs would be practicing a procedure historically outside of their scope-of-practice. They would be doing so without the training hours needed to ensure proper practice on patients without heightened health risks and adverse side effects. This regulation has zero hours of training for PTs to adhere to and there are no guidelines in place for certification, skills assessment or monitoring. 

If the VA Board of Medicine has such stringent education, training and certification measurements for acupuncturists (as well as for medical doctors and chiropractors) due to the adverse health risks invasive procedures generally pose, why is there not the same for PTs who traditionally have not worked with invasive procedures? Education and training with physical therapy does not seamlessly lead to a knowledge of safe needling. Separate education and training hours must be explicitly implemented in PTs are to engage in needling, for the safety of the public. There needs to be a specific number that has been demonstrated to be adequate for needling by PTs and there needs to be a separate certification process and regulatory board that can keep track of proper training, certification applications and making sure that those who engage in the practice of needling have fulfilled the requirements to do so. 

Traditional, entry-level PT training and education does not encompass that of needling and so many of those who are certified PTs do not have the knowledge or training required to safely practice needling. The proposed regulation does not address how competency would be met either. In other words, many PTs are currently incompetent to perform dry needling from current training and education for their profession and the regulation does not address how much training/education would be required but it also does not address how PTs would be regulated and held to standards should standards actually be put in place. 

For further proof of the validity of this comment, one could look to other states, such as New Jersey and Washington, that have turned down proposed regulation concerning dry needling by PTs for the same reasons. Even the American Medical Association in June 2016 released a statement that dry needling is an invasive procedure that should only be practiced by those with standardized training and familiarity with needles, such as acupuncturists and licensed medical professionals.