i am writing to oppose the use of dry needles by PT's or others who do not have a acupuncture licence. 

The foundation of dry needles is based on pain spot or tender points which in fact described in Traditional Chinese Medicine as Ashi points.  It then becomes part of the practice of TCM and acupuncture. But such dry needle practice is allowed to be performed by those who do not need the necessary acupuncture education and licence. 

This can confuse patients as they may perceive the treatment as acupuncture if acupressure.  

Without proper TCM and acupuncture training while performing the scope of acupuncture is endangering patient safety and healthcare integrity.  

Please decline such proposal.

Thank you  

Shirley Kan, LAc 10688