Dear Board of Physical Therapy, 
 
  
South Baylo University - VA Branch encourages you not to draft regulations because: 
 

1. Dry-needling regulation by physical therapists might discourage the student body of all acupuncture and oriental medicine schools from the view of current students and perspective students. Becaue all students attending to acupuncture and oriental medicine schools have been trying their best to learn acupuncture technique (including dry-needling) during academic and clinc internship programs for almost 3000 hrs in terms of technique, anatomy & physiology, and safty and they are very proud of themself about to be licensed acupuncturists in the near feature. Please do not discourage all acupucutre and oriental medicine major students, faculties, staffs and alumni.
2. 54 hours of training is a completely inadequate level of training to qualify a physical therapist to safely insert acupuncture needles into patients and the regulations therefore are a serious threat to public safety;
3. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training required for acupuncturists and even medical doctors; 
4. The dry needling rules are illegal, because they would allow physical therapists to engage in acts that are outside the legal scope of practice for physical therapy as defined by Virginia's General Assembly. There is nothing to support that the General Assembly ever intended to allow physical therapists to insert acupuncture needles into patients absent the same level of training required for licensed acupuncturists.

Thank you for considering my comments. 
  

Sincerely, 

South Baylo University - VA Branch

www.southbaylo.edu/va