Action | Practice of dry needling |
Stage | NOIRA |
Comment Period | Ended on 12/30/2015 |
Dear Board of Physical Therapy,
I am a licensed acupuncturist with 20 years of experience and am writing to object to the intent to draft "dry needling" regulations. I believe these regulations present a serious threat to public health and would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy that has been adopted by the Virginia General Assembly.
I encourage you not to draft regulations because:
1. 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. Nor is it enough training to learn the specific functions of each acupuncture point and how it effects the body when stimulated.
2. 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. Even cosmetologist & barbers must complete at least 1500 hours of training before legally being allowed to cut someone’s hair. Of course the only consequence of a lack in training in this case would result in a bad haircut, not a pneumothorax!
3. 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,
Jeanie Mossa-Kraft L.Ac