Dear Sir or Madam,
As a Licensed Acupuncturist, I oppose dry needling as performed by Physical Therapists without Acupuncture license.
 This is a kind of attempt to avoid the necessary training, degree and certifications required to perform this invasive and effective therapeutic intervention.  It further diminishes public perception of acupuncture (which is based on a medical classics over two thousands of years history) and dilutes its putative effect especially given the dearth of training and oversight in this procedure. 
 
Dry Needling is one type of Acupuncture (Medical Acupuncture. 2016, 28(4): 184-193).
 
First involves public safety and welfare, as even MDs must document over 300 hours of certified training to perform needling. 
The American Medical Association (AMA) released a statement in 2017 asking that only practitioners with experience with needles be licensed to use them http://www.asacu.org/wp-content/uploads/2017/06/AMA-Dry-Needling-Policy.pdf. The AAMA has specific and clear national standards requiring 300 hours of didactic training, supervised clinical hours, and the passing of a third party national psychometric exam.  
 
Actually most of the MD with Acupuncture license can’t perform the Acupuncture. They just hire the licensed Acupuncturist to do the Acupuncture treatment for them because the 300 hours training is obviously not enough.
 
The Current standards do not address even these basic concerns.
PTs practicing Dry Needling get to routinely perform this with less than 60 hours of training!!! This is unethical, wrong and actually embarrassing. 
 
The National Commission for Certification in Acupuncture and Oriental Medicine (NCCAOM for acupuncturists and the AAMA for medical doctors both have Certifications requiring specific numbers of didactic hours, clinically supervised hours and a third party national exam. https://www.nccaom.org/certification/board-examination-process/ http://www.dabma.org/
Usually people need about 3000 hours (3 years) study in USA and 6000 hours (5 to 6 years) study in China to qualify for taking the examination of NCCAOM.  
 
Secondly, it is a gross intersection into our scope of practice as needling is the core modality that defines acupuncturists as a profession.
 
Other oriental therapies such as cupping, Gua She have already been implemented in many PT offices and it is unsafe and unfair to allow PT's to "take over" all modalities of our medicine without the proper training, guidance, testing and detailed supervision.  
 
This is not good for the public because it further dilutes the clinically proven effectiveness of acupuncture which is why PTs want to copy us in the first place. It is a great medicine but they should have proper training to practice it.
Thirdly, the insurance industry grossly discriminates against acupuncturists in favor of PT's using dry needling for coverage and this further impacts our protected scope of practice and also endangers public safety. I have met many who equate dry needing with acupuncture and the public perception is not being helped by PTs using dry needling which is also unethical.
 
It should be about education, public safety, and public awareness, integrity of practice and knowledge.
 
Dry Needing is actually acupuncture and should be performed by licensed acupuncturists. Calling is a different name is simply a "wolf in sheep's clothing." Common sense goes a long way here as "Dry Needling" is relatively new on the PT horizon and they have been using our tools (acupuncture needles) and CPT codes (until this past year) and evidential research to promote acupuncture by another name.  
 
The only reason this has been allowed to go on is because of big PT lobby that drowns out the voices of smaller acupuncture lobby.
If money can over the law and public safty, in future it will have bad results.

Thank you for your consideration.