I am a physician in Georgia and am board certified by both the American Board of Anesthesiology and the American Board of Medical Acupuncture.  I have been practicing medical acupuncture full time for over 15 years.

The practice of dry needling is equivalent in its nature and its risk to acupuncture.  Typically dry needling involves local needling of muscles and tissues surrounding the muscles, whereas acupuncture in its more traditional form may involve distal points—points not in the region of pain.  Nevertheless, the instrument is the same—an acupuncture needle.

In contrast to physicians and acupuncturists, physical therapists’ training does not involve the safe practice of needles that penetrate body tissues, and in the case of dry needling in particular, deep penetration is often used.  To allow physical therapists to practice dry needling with minimal training (or without full training) poses an undue risk to the public.

I have no problem with physical therapists utilizing acupuncture or dry needling in their practice; it is a beautiful medicine.  For the safety of the public, however, the physical therapists should attend medical school and complete a 3 year residency, followed by a 300 hour course specific to acupuncture, or they should attend and graduate from an accredited acupuncture school and become certified though the NCCAOM in order to safely practice acupuncture or dry needling.

Anna Kelly, MD

Vice President, American Academy of Medical Acupuncture  

Modern Medical Acupuncture contains many sub-categories, such as reflex points, trigger points, ashi points, Japanese style, Korean style, Chinese style ... Their theories could be different but all of them have a common point, that is using a needle to pierce the skin on some points to acheieve certain goal.

Drying needling is one subcategory of Acupuncture. Per wikipedia  (https://en.wikipedia.org/wiki/Dry_needling) the term dry needling can refer quite specifically to what is now called Myofascial Acupuncture, Tendinomuscular Acupuncture, or some version of Sports Acupuncture.

The founder of Drying needling has an Acupuncture license as well, such as Dr. YunTao Ma. Dr. Chang-Zern Hong is the Acdemic editor for researches on Remote Effect of Lower Limb Acupuncture on Latent Myofascial Trigger Point of Upper Trapezius Muscle. (http://www.hindawi.com/journals/ecam/2013/287184/). Even the founder of drying needling is doing research on acupuncture on trigger points. So what is the difference between drying needling on trigger points and acupuncture on trigger points?

Practising dry needling without acupuncture license could not garantee the skill of the performer. It will jeopardize public health. 

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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;
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; 
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, 
 

Ji Kim

MS, L.Ac

Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist in Virginia and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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;
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 
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, 
  
Sarah Shupe Hung, L.Ac.

Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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;
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; 
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, 
David Zeoli, LAc

Sample comment: 
  
Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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. This would be the equivalent of me performing orthopedic adjustments on my patients. Yes I could probably figure it out but no I am not a qualified expert with enough training to responsibly care for patients in this way. The patients don't know the difference in training and it is up to the board to protect them. In my practice alone I have seen multiple patients come in with serious injuries from dry needling. I have yet to see any injury from a licensed acupuncturist. I have 3000 hours and 4 years of training with needles. I had to take national board exams and needle competency testing before being able to practice. To allow physical therapists to use the exact same needles in the exact same points (please note many dry needling training seminars are actually teaching and using acupuncture points!) with ridiculously little training would be considered negligence by the board. 

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;
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; 
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,  Ashley Will, Lac

Dear Board of Physical Therapy,

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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. This lack of safety is evidenced by many other states declaring it unsafe and prohibiting dry needling.

I encourage you not to draft regulations because:

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;
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; 
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,

Megan O'Connor

LAc, Dipl OM, MATCM

732-977-2027

megan.oconnorlac@gmail.com

Dear Board of Physical Therapy,

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:

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;
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; 
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,

Heather Sullivan

L.Ac, MSOM, BA-Nutrition

www.sullivanacupuncture.com

I understand why physical therapists would like to add "needling" into their scope of practice. It would enhance their practice and probably give better outcomes. However, they do not receive enough training for them to safely needle their patients and could cause harm to the public. For more thoughtful information on the subject, one should refer to http://www.liveoakacupuncture.com/dry-needling/

Physical therapist should build relationships with local acupuncturists and refer their patient to them for proper care. In the medical world, we are forced or refered to specialists for a reason, and in this instance it should be the same.

Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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;
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; 
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,

Julia Lee, L.Ac

The claim that Dry Needling is not acupuncture is ridiculous.  Acupuncturists undergo over 2000+ hours learning how to needle every point on the body safely, even 100 hours of Dry Needling education would be a far cry from what is appropriate.  Protect the public and keep the requirements for needling into a body as high as they should be.

Thank you,

Paul

To Who It May Concern,  Thank you for allowing comments on this issue.  I am a licensed acupuncturist in California state.  I studied this medicine in the standard 4 year master's level accredited program including 1000s of clinical hours..  I learned everything Eastern Medicine which is a complicated discipline.  I learned patient safety, acupuncture needles are not benign tools.  They can create healing and they can be dangerous when used frivolously.  I feel if a PT practitioner wants to practice needling, they have this opportunity by going to graduate school for Eastern medicine and take all the board tests required for this profession.  To not uphold the standards established, jeapordizes the integrity and safety we work so diligently to maintain.  We take 50 hours of CEUs to maintain our licenses, pay fees and insurances specifically to protect and support our patients. Google Dry needling and see what some PTs are doing.  It's dangerous and irresponsible and I hope you will protect the public and our profession from this half hazard behavior.

Thank you for your time.  

Best healing,

Sherra Cunningham, MATCM, L.Ac.

Per below, Dry needling is a part of acupuncture and should not be included in the scope of practice of other medical professionals. I do not expect to be able to practice physical therapy with a CEU course and am happy remaining in my scope of practice and refering patients to a PT when warranted. I expect that you will recognize that dry needling is acupuncture. It uses acupuncter needles and while the language is different obviously is recognizable in the chinese medical literature as acupuncture.

thank you

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:

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;
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;
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,

Evan Howlett

T

Dear Board of Physical Therapy,

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:

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;
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; 
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,

Sharon McGinty

Licensed Acupuncturist

ype over this text and enter your comments here. You are limited to approximately 3000 words.

How can anyone claim they are working for the patient's best interest if they are getting less than a 10th of the training a Licensed Acupuncturist is required to have in order to perform safe acupuncture? Professionals should be expected to refer out if they feel a patient will benefit from a modality, not experiment with inappropriate training for the sake of making money. Also, they should be prevented from abusing Insurance by billing under "manual therapy" which Acupuncturists cannot bill under. It seems fraudulent to allow a person with such little training to bill for something that would be seen unethical for an Acupuncturist. 

Dear Board of Physical Therapy, 
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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: 
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; 
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; 
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.

Sincerely,

Lisa Marie Price, L.Ac., Dipl.Ac.

Dear Board, 
  
I am a professional acupuncturist and am writing to object to your draft "dry needling" regulations.  These regulations present a threat to public health and would authorize physical therapists to engage in acts that are outside the scope of practice for physical therapy as adopted by the Virginia General Assembly, and as generally accepted throughout the U.S.. Allowing this would be the equivalent of me performing orthopedic adjustments on my patients with a weekend of training. Yes I could probably figure it out but no I am not a qualified expert with enough training to responsibly care for patients in this way. The patients don't know the difference in training and it is up to the board to protect them. There are numerous documented cases of serious injuries resulting from dry needling by Physical Therapists. Injuries from acupuncture performed by a licensed acupuncturist are extreemly rare. Licensed Acupuncturists have 3000 hours and 3-4 years of training with needles. There are national board exams and needle competency testing required before being able to practice. To allow physical therapists to use the exact same needles in the exact same points (dry needling training seminars are actually teaching and using acupuncture points!) with ridiculously little training would be dangerous. 

I encourage you to consider the following: 
 

1. 54 hours of training is a completely inadequate level of training to qualify anyone to safely insert acupuncture needles into patients.
2. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture. 
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. 
  
Sincerely,  John Barnett, L.Ac.

Dear Board of Physical Therapy,

I am a licensed acupuncturist and object to the intent to draft "dry needling" regulations.

Dry needling is an modern version of a "stone age" acupuncture invented at least 4,000 years ago. Dry needling is a local acupuncture, where needles are placed on or near the areas of injury. Acupuncture has evolved over time to do both local and distal needling. Just because Asian theoretical words such as qi, yin, yang, and meridians are removed by dry needlers does not become a different practice. My view of dry needling is like saying that Christopher Columbus or his cohorts had discovered the Americas although this is not true. Dry needling is an attempt to hijack acupuncture and calling it their own. It requires around 1,000 hours of acupuncture studies to be competent and safe for the public. Allowing dry needlers to study 57 hours is an invite to a whole field of acupuncture without getting a proper introduction. This is a spit in the face to the whole medical profession. Who is going to regulate physical therapists from practicing distal needling also? Even MDs require 300 hours of acupuncture study. 

Sincerely,

David Lee

805-497-6200

Dear whom it may concern,

Dry needling is simply the renaming and rebranding of acupuncture and an illegal attempt around acupuncuture statutes and standards. Dry needling is a technique coined by physical therapists, but, it is a rudimentary acupuncture technique. There is no way they can ever be seperate scientifically speaking. Anyone wanting to perfrom acupuncture and other invasive needling techniques, including MDs, DCs, PTs, etc., should follow state acupuncture statutes regarding training and education.

Sincerely,

Dr. Brian Grosam

Dear Board of Physical Therapy,

"Dry needling" is acupuncture and should not be included in the scope of practice of other medical professionals. It uses acupuncture needles. Throwing away 3,000+ years of clinical experience by a multitute of practiioners and renaming it "dry needling" doesn't change that simple fact. There is a 71% correlation between the location of traditional acupuncture points and trigger points. These studies have been around a long time. Saying you needle only trigger points and not traditional acupuncture points is completely inaccurate - and impossible. I do not expect to be able to practice physical therapy with a CEU course and am happy practicing within my scope of practice and having great referral relationships with PTs in my area. I expect that you will recognize that dry needling is acupuncture. Show some professional respect please; create partnerships and coordinate care with your local acupuncturists - they are highly trained in what they do. If you want to needle patients, go get an acupuncture degree and really learn it, you will not be disappointed.

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:

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;

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;

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,

Alicia Rosselle

I have been a licensed acupuncturist since 1990.    The use of dry needling by physical therapists poses danger to both the patient and my profession.  The patients thatbI know who have received this therapy report it as painful and only minimally useful.  When I was an acupuncture student in the 1980's my teachers forbade the use of needles on real patients in until halfway through the second year of a full time program.  Before needling we were schooled in energetic anatomy, meridian theory, diagnostics, point energetics as well as chi cultivation.  Our work is sacred, not something that can be duplicated in a weekend workshop or as an add on to other therapies.  Patients as consumers do not understand the difference in training and delivery.  In order to protect them, and our profession I recommend not allowing physical therapists thee inclusion of dry needling in their practice act.  Thank you.

Dear Board of physical Therapy,

We all know that using the dry needles can help the patients to cure the disease but it could cause a serious

damage to the whole body system's function.   I do hope you should understand why WHO and American licensing authorities require 4,000 hours (5 years worth as a full time students) of education and training courses to complete and to pass national examinations "before using the dry needles".

In the past years in Asian countries, they attempted to give the licenses to the professionals including physical therapist, massage therapist, nurses, etc but now they all stopped that program due to many negative outputs

from using the dry neeles to the patients.

An attempt of wrong concept application might lead many innocent citizens to a serious risk.

Sincerely,

Helmsley J. Park, L.Ac

Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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;
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; 
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, 
  

Jinwook Kim, Ph.D, L.Ac

Program Director

South Baylo University, VA Branch

979-204-3949

I was first introduced to Dry Needling 2 years ago, when a patient of mine came to me complaining of serious chest and upper back pain. She had just come from her Physical Therapist, who had performed Dry Needling on her back that same afternoon. As it turned out, she had a pneumothorax and had to go the ER, where she was put in the ICU and remained in the hospital for the next 24 hours. She happened to have taken a photo of her DN treatment, which showed the most shocking placement of needles I had ever seen: 8 needles inserted deeply, perpendicularly, into what acupuncturists call 'Back Shu" points, along both sides of the spine, with no regard for the underlying organs. PTs claim that DN is the insertion of needles into trigger points (called "ah shi" points by acupuncturists). But in the two years since my patient's unfortunate experience, I have seen many more photos of Dry Needling showing the reckless placement of needles into the body -- sometimes randomly, and sometimes along clearly drawn lines that are clearly acupuncture meridians. I object strenuously to the lack of training by PTs to perform DN. But more importantly, I object to the renegade path that many PTs have taken beyond the insertion of needles into so-called "trigger points". 

Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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.  This amount of training is not adequate to perform the art of acupuncture needling.  The amount of hours of training received in acupuncture school is focused on the art of oriental medicine and cannot be duplicated by "Dry Needling techniques".

 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; 

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.  

4. Physical therapists need to learn how to referr to an acupuncturist who possess the techniques and best application of acupuncture needles to the human body.

5.  There is an art to acupuncture that is only completed when the 8 Limbs of Chinese Medicine are incorporated into the treatment plan. "Dry Needling" will not  be an affective treatment and could actually cause more harm to the general public, as your board already knows of reported cases of damage and harm which are pending litigation around the misuse of  "Dry Needling".

Thank you for considering my comments. 
  
Sincerely, 
Robert A. Hoffman N.C.C.A.O.M. Lic. Ap.

Dear Board of Physical Therapy,

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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: 

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;
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; 
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,

Martina Skenderova 206-713-1893

Dear Board of Physical Therapy,
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:

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;

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; 

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, Alyssa Dazet L.Ac. 310-663-5831

Dear Board of Physical Therapy,
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:
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;
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;
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,

Deena Drewes, LAc

Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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;
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; 
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.  

I have observed another concern about this whole process that has been presented by physical therapists in many different states.  In the beginning they were asking for approval for dry needling claiming it is definitely not acupuncture.  Then as the acceptance grows, one of the main teachers publishes a book calling it the definitive book on medical acupuncture.    

Thank you for considering my comments. 
  
Sincerely, 
  
Don Wetsel 

dewetsel@gmail.com

Dear Board of Physical Therapy,

I am a California state licensed acupuncturist with over 3,000 hours of gradiuate level training - at least 1,000 of those hours were spent on clinical use and training of acupuncture. I am writing to object to the intent to draft "dry needling" regulations. I believe the 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:

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; consider if acupuncturists or dentists could take 54 hours of training to manipulate spines like chiropractors. 

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; 

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,

Karen You, L.Ac.

Dear Board of Physical Therapy,

I am a licensed acupuncturist, with a sub-specialty in Trigger Point Acupuncture Dry Needling and am writing to object to the intent to draft "dry needling" regulations. I believe the 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 as adopted by the Virginia General Assembly.

I strongly urge you not to draft regulations because:

*54 hours of training is a completely inadequate level of training to qualify a physical therapist to safely insert acupuncture needles into patients, let alone perform trigger point dry needling acupuncture effectively.  Trigger point acupuncture is sub-specialty involving one of the most invasive needling technique within our scope and the regulations therefore are a serious threat to public safety;

*Dry needling is a sub-specialty within the practice of acupuncture as defined under Virginia law and there is no basis for allowing physical therapists to practice acupuncture without commesurate educational and training requirements for acupuncturists and medical doctors;

*The dry needling rules are dangerous, because they would falsely imply to the public that physical therapists are adequately trained to safely and effectively treat trigger point related myfascial pain at the same level as medical doctors and licensed acupuncturists.  This is not only dangerous, but also deceitful as clearly the proposed lanaguage does not and can not match the leve of training in safety and efficacy of other licensed practioners of trigger point dry needling acupuncture. There is nothing to support 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,

Edd Lee LMT LAc

Dear Board of Physical Therapy,
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:
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;
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; 
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, 

Mary Cooke, LAc

Dear Board of Physical Therapy,
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:
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;
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; 
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,
Amber Novak

Amber Dragon Acupuncture

206-227-0641

amber@amberdragonacu.com

Dear Board of Physical Therapy, 
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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: 

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; 

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. 

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,

Matthew Safarik, LAc

Dear Board of Physical Therapy,
 
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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;
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; 
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,
  Susan Sandage L.Ac.

Puncturing the skin with an acupuncture needle is acupuncture and as such should be considered out of scope of practice for physical therapists. Dry needle, also known as Acupuncture should only be done by a trained, licensed acupuncturist.

Dear Board of Physical Therapy, 
  
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations.  I believe the 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;
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; 
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, 
  

Renee S Kim L.Ac.

Please do not regulate dry needles.  My Accupuncturist knows a ton and is in  a better position to help me,

Thank you.  Kate Howell

As a long-time patient of several acupuncturists, I experienced temporary relief.   After seeing a recent L.Ac. graduate, the results are miraculous.  I would never assume a physical therapyist would provide the same results as an L.Ac. just as I wouldn't assume an acupuncturist would be able to provide physical therapy with miraculous results with only 54 hours of training.

Dear Board of Physical Therapy, 

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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: 

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;
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; 
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,

Anthony Guadamuz

Anthony@AcupunctureSoFla.com

Dear Board of Physical Therapy,

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:

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;
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;
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.

Whereas, most licensed acupuncturists in the US undergo a rigorous education and training (well over 2,500 hours) that include needle insertion safety: the precise location of where to needle acupuncture points in the body, the safe needling depths for each of those points, the orientation/directionality of each of those needle insertions, and the avoidance of organ puncture.

Thank you for considering my comments.

Jennifer Yeh, LAc., MSTCM, Dipl OM

As a graduate of an acupuncture school and one who has received it for over 30 years, I am very concerned about risks to those seeking help from a physical therapist using the dry needle technique.

PTs generally dry needle just local areas where there is pain in the muscules and they may exclude treating the root cause of that pain.  Acupuncture practitioners, trained over a 3-4 year period including hundreds of clinic hours, consider a more comprehensive approach to treat pain at the root and/or the branch levels. Their diagnosis may involve points that are distal, on different channels, at different resonating locations, using reducing or tonifying techniques at depths specific to the condition, etc.  Physical therapy training for dry needling does not involve a complete enough knowledge base of traditional oriental medicine to perform needling and to do it safely.  This dry needling practice poses an undue risk to the public.  Before any physical therapist takes needle in hand, they should go through a several hundred hour course of study and clinic at an accredited acupuncture school, graduate, complete exams, and become accredited through NCCAOM exams as do acupuncture students.  Without that knowledge base and school credentials, I would not trust them to safely practice dry needling acupuncture on anyone, including me.  

Respectfully, 

Kim Laney LMP CSP

Journal of Acupuncture in Medicine just published an article- "Dry Needling is Acupuncture".

Dry needling is not a scope of physical therapy, practicing dry needling should follow acupuncture law and get an acupuncture licence first.

Academically, we find 1 for the treatment of musculoskeletal disorders, dry needling is from acupuncture in its origin, techniques and theories, and dry needling is one subcategory of Western medical acupuncture, and is thus acupuncture. As current training and clinical practice of acupuncturists involve both Traditional Chinese Medicine (TCM) and Western medicine, at least in China, where acupuncture originated, we have the following comments.

The term ‘acupuncture’ is a translation of ??? (zhen ci shu in Chinese pin yin) or in short ? (zhen), and is literally equivalent to the term ‘needling’ or ‘needling technique’. Based on the traditional and official definition, the term acupuncture refers to the actual insertion of a needle (usually a solid needle) into the body2, which describes a family of procedures involving the stimulation of points on the body using a variety of techniques. The acupuncture technique that has been most often studied scientifically involves penetrating the skin with thin, solid, metallic needles that are usually manipulated by hand or by electrical stimulation. Practiced in China and other Asian countries for thousands of years, acupuncture is one of the key components of TCM (https://nccih.nih.gov/health/acupuncture). Currently, acupuncture is practiced internationally, and has attracted more and more interest in Western countries, especially in the United Kingdom3 and the United States. Dry needling literally is acupuncture, although the term is more commonly used instead of acupuncture by physiotherapists in Western countries. As stated in the article by Zhou et al.1, dry needling is a subcategory of Western medical acupuncture. Taken literally, the term acupuncture includes both Western medical and traditional acupuncture, and thus obviously covers dry needling.  

Historically, dry needling is acupuncture. In China, especially in the East, the term dry needling (??, gan zhen in Chinese pin yin) has been a folk name for acupuncture since Western medicine arrived in China in the late 1800s, when the term of dry needling was created in order to differentiate it from the needles used for injections by Western trained doctors. Many people in China still refer to acupuncture as dry needling, especially after acupoint injection therapy and aquapuncture therapy were developed in China in the early 1950s4. The term dry needling (gan zhen) has already become a synonym for acupuncture used by many Chinese practitioners. For example, when searching using the Chinese term ?? in the Amazon book department (http://www.amazon.cn) all results are acupuncture books. With their combined education in both Western and Chinese medicine, modern acupuncturists from China are well equipped with knowledge and skills not only in TCM but also conventional medicine. Because of heterogeneous understanding and emphasis in training at different academic schools or different styles of practice, various types of acupuncture have developed all over the world, including Fu's acupuncture, scalp acupuncture, wrist and ankle acupuncture, abdominal acupuncture and others, which undoubtedly include dry needling. Because of the rapid development of science and technology, and significant progress in modern research into acupuncture, the potential therapeutic mechanisms of acupuncture have been explored and include Pavlovian conditioned reflexes, nerve segment theory, gate theory, somato-autonomic nerve reflexes and others.5 All of these mechanistic concepts of acupuncture are based on modern biomedicine. Clearly, traditional acupuncture is being explained by modern science.

In conclusion, dry needling is not only a subcategory of Western medical acupuncture but also an integral part of acupuncture per se. Although not all Western medicine practitioners may agree, dry needling arguably is an important part of traditional acupuncture.

References

1. Zhou K, Ma Y, Brogan M. Dry needling versus acupuncture: the ongoing debate. Acupunct Med doi:10.1136/acupunctmed-010911 Published Online First: 6 November 2015.

2. Kaptchuk TJ. Acupuncture: Theory, efficacy, and practice. Ann Intern Med 2002;136: 374–383.

3. National Institutes of Health. Acupuncture. https://nccih.nih.gov/health/acupuncture.

3. Dascanio VC. Acupuncture in physiotherapy: a contemporary UK perspective. Acupunct Med doi:10.1136/acupmed-2015-010977  Published Online First: 6 November 2015.

4. Li P. Clinical acu-point injection therapy. Military medicine press, Beijing, 2003:15 (in Chinese).

5. Jin GY, Jin JJX. Contemporary Medical Acupuncture: A Systems Approach. Beijing: Higher education Press-Springer, 2007.

Dear Board of Physical Therapy,

I am a licensed acupuncturist in the state of VA and am writing to object to the intent to draft "dry needling" regulations. I believe the 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:

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;
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; 
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,

Brian P. Wah LAc.

Dry needling falls within the scope of practice for Acupuncture and Oriental Medicine practitioners. Although each state has their own state Acupuncture board and regulations concerning the practice of Acupuncture and Oriental Medicine, each state includes the use of acupuncture (needles) for the use of creating energetic shifts in a person as within the scope of Oriental Medicine. Therefore, dry needling falls within the scope of practice of Acupuncture and Oriental Medicine practitioners. As it falls under the scope of practice for an established profession, it would be illegal for those of another profession to practice dry needling. This would be like Oriental Medicine practitioners giving Western dietary or supplement recommendations. We are not allowed to because it does not fall under our scope of practice; it falls under another profession's scope of practice. How did I come to this conclusion? Let's break it down. Dry needling is but another name for acupuncture (when used as a verb). When doing acupuncture, filiform needles are used to puncture the skin of patients in order to create energetic shifts in the patient's body, mind and spirit. As the needles are filiform, they are solid; because of this, they do not carry or transfer liquids or fluids such as those used by Western medical pracitioners (such as in the delivery of a vaccine or the flu shot). Hence, we use "dry needles" when we perform acupuncture or engage in dry needling. So when you think about the tools we use in acupuncture and Oriental Medicine, it is that of "dry needles." Perhaps we should look to the orignal, Chinese name for acupuncture and see if "acupuncture" is not a poor translation? Also, if we are to look at the purposes of needling we can say that we sometimes use our tools to, in terms of Oriental medicine, break up stagnation or stasis and to create movement - just as a physical therapist or Western medical doctor might claim to use needles to break up muscle spasms in order to release pain. Our tradition has been doing what physical therapists, Western medical doctors and other non-Oriental medicine practitioners are claiming is theirs for thousands of years. Look at a professional using "dry needling" on someone's back to break up muscle tightness or a spasm and then have an acupuncturist sitting right next to them, using "acupuncture" to essentially create the same result. Do you think that they are really two different things? Also, perhaps we should mention the training that is required of acupuncturists and Oriental Medicine practitioners versus professionals who engage in dry needling. We spend years in school and in clinic, learning all of the ways in which we can engage with the needle and the person. We are safe, experienced and well-educated becase of our education and training (that is regulated by a professional and legal board). "Dry needling" as practiced outside of the scope of Oriental Medicine is not dictated by the same professional and legal regulations. One must wonder why, with the increased interest in wholistic health and alternative medicine, that "dry needling" is only now being practiced by those outside the field of Oriental Medicine - something that we have been doing all along. What I just wrote contains many different points for why dry needling is essentially acupuncture, and therefore belongs under the scope of practice for (and only for) practitioners of acupuncture and Oriental Medicine. The points can each be easily expanded upon, but this hopefully is a good starting point for thinking about why acupuncture and dry needling are essentially one and the same.