I strongly support recommendations of the Acupuncture Society of Virginia.

18VAC85-110-100. General requirements.

I strongly disagree with the requirement for a written documentation of or a written recommendation to receive a diagnostic evaluation by physician. This is an unnecessary regulatory burden on both patients and licensed acupuncturists. It is not necessary for the protection of public health, safety, or welfare. 

Virginia residents often concurrently seek care with a licensed acupuncturist in addition to a licensed doctor of medicine and / or other healthcare professionals.  A patient receiving a form that notes that the state requires them to be notified of a recommendation to receive diagnostic examination by another health professional undermines the professional credibility of licensed acupuncturists, who are well aware of the limitations of the acupuncture and Oriental medicine scope of practice and their responsibility to refer patients, as necessary, to other providers. Most Insurance companies in Virginia do not currently cover acupuncture and acupuncture will not be included as an essential health benefit in Virginia. Acupuncture is an out of pocket expense for most individuals.  Therefore, this regulation should be repealed to be consistent with consumer behavior, insurance coverage, and the requirements of surrounding states.

Many patients residing in localities near Virginia borders, especially those in northern Virginia, may be getting acupuncture in other states or jurisdictions (i.e. Maryland, District of Columbia) where they work. This requirement would therefore not apply to those individuals and is therefore not being applied equally to all Virginians. There have been no reported incidents of the lack of a medical examination requirement causing harm or endangering the health, safety, or welfare of these individuals.

18VAC85-110-130. Maintenance of patient records.

This regulation is not contained within the regulations governing any other health profession regulated by the Board of Medicine and therefore should be repealed.

Dry needle issue

2. Based on the real practice of Physical Therapist(PT) who uses so called "Dry Needling Technique", acutually use acupuncture needles, and use one of acupuncture and chinese medicines own methods, the Ashi points acupuncture/needling, or motor point needling. PT's uses another "language" to replace the discription in acupuncture books, to legalizing their practice of Acupuncture(using the term of "Dry Needling Technique" and description it with other medical terms and adding their own history of development of such technique, but these techniques are not different or new). I strongly hope the board requires them to get enough training and education. Currently, our profession (Acupuncture and Oriental Medicine) needs 2000 hours (or more than that) training, MDs or DCs who practice acupuncture need at least 300 or more hours additional training. PT practicing so called Dry needleing technique with less than 300 hours training is not acceptable. There are more injuries due to this inexperience and new dry needling practice and because of that injures our own profession.

 Thank you for your consideration of these recommendations.