As a matter of public record, I request that you provide your reasoning for determining that 54 hours is the proper amount of education for a physical therapist to be considered qualified to perform dry needling in Virginia.

In your answer, please include a detailed breakdown of the number of hours within all the different aspects and categories of learning required to attain competence in dry needling, and how you arrived at the conclusion that 54 hours was the right amount of education.

Adding an invasive and potentially dangerous procedure to the scope of practice for physical therapists is a matter of great importance to public safety. My assumption is that you studied this matter independently and in depth and decided that 54 hours was the right amount of education. I look forward to your clarification of this matter.