Dear legislators,

I'm writing to decalre my opposition to the practice of dry needling by physica therapists for the following resons:

1. Substandard Training. 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;
2. DN Constitutes Acupuncture Practice. 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; and
3. Illegal under VA Law. 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 no evidence that the General Assembly intended to allow physical therapists to insert acupuncture needles without the same level of training required for licensed acupuncturists.

I urge you not to pas the legislation for the public safety.

Kind regards,

Mike Zojaji, PhD