The Tennessee Acupuncture Council (TAC) would like to submit comments in opposition to the proposed regulations regarding dry needling by physical therapists. 

The reasons for our opposition are straightforward: 

    Dry needling is not safe.

    Dry needling is acupuncture.

    The training required to perform dry needling is inadequate. 

Dry needling is not safe: In dry needling, as in acupuncture, FDA regulated acupuncture needles are inserted up to 5” into patients by physical therapists with as little as a weekend training course and no prior experience in the safe use of needles. It is our understanding that the draft regulations provide no minimum standard of training. This lack of training will increase the rate of injuries to your citizens. Injuries reported from dry needling include: pneumothorax, nerve damage, hematoma, etc. The American Medical Associations recently adopted a policy critical of dry needling: “Lax regulation and nonexistent standards surround this invasive practice … For patients’ safety, practitioners should meet standards required for acupuncturists and physicians.” The largest company insuring physical therapists recently called dry needling “an emerging area of risk” and documented numerous dry needling injuries. 

Dry Needling is Acupuncture: Dry needling is simply another name for acupuncture as it has been practiced for over 2,000 years.  Dry needling involves insertion of the same FDA-regulated acupuncture needles into the same “trigger points” that have been used in acupuncture for millenia for the same purpose of providing therapeutic relief.  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. 

Dry Needling training is totally inadequate: Most dry needling training programs involve only one or two weekends of training and does not include any of the supervised clinical training that has been critical to providing the real world experience that has been key to acupuncture’s strong reputation for safety and effectiveness.  In comparison, acupuncturists in Virginia are required to have at least 1,365 hours of acupuncture-specific training including 705 hours of acupuncture-specific didactic material and 660 hours of supervised clinical training. 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 (ABMA).  It is our opinion that there are extremely qualified practitioners of acupuncture that are able to safely treat any patient seeking relief through this means of treatment and they should be utilized. 

Additionally, it has come to our attention that dry needling is outside the scope of practice for physical therapists in Virginia. When the Virginia Legislature adopted the legal definition of physical therapy it had no intent to allow physical therapists to insert acupuncture needles and no authority for any similarly invasive procedures are allowed in statute.  The Board of Physical Therapy lacks the legal authority to expand the physical therapy scope of practice to include dry needling and any attempt to do so would plainly violate state law.

Thank you so much for your careful consideration of this harmful regulation. We trust that you will do what is necessary to protect your citizens and provide them safe and effective health care options. 

Sincerely, 

Sarah J. Prater, L.Ac. 

Vice President of Tennessee Acupuncture Council (TAC)

and the Board of TAC