I am writing to ask for your support to reject a proposal that is being put forth by the Virginia State Board of Physical Therapy on the grounds that it presents a public safety risk. 

The World Health Organization, the American Medical Association(AMA), and the American Academy of Physical Medicine and Rehabilitation(AAPMR) have recognized that dry needling is a subtype of acupuncture and is indistinguishable from acupuncture. The AMA and AAPMR have further stated that it should only be performed by practitioners with standard training and familiarity with routine use of needles in their practice, such as licensed acupuncturists or licensed medical physicians. Some states have even banned physical therapists from practicing dry needling due to public safety concerns.

Acupuncturists obtain a Masters degree which includes, in addition to biomedical training, at least 1365 hours of acupuncture-specific training, including 705 hours of acupuncture specific didactic material and 660 hours of supervised clinical training and in most states including Georgia are required to pass a national competency exam. Continuing education is also a requirement to continue practicing acupuncture. The American Academy of Medical Acupuncture has set the industry standard for a medical doctor to practice entry level acupuncture at 300 hours of postdoctoral training with passage of an examination by an independent testing board. This standard presumes extensive, pre-requisite training in invasive procedures. Contrast that with no standards for training required for physical therapists and no national standardized competency examinations, training standards, supervised practice requirements nor continuing education requirements for the safe practice of Dry Needling. 

The act of inserting an acupuncture needle through the skin into the body for diagnostic and/or therapeutic purposes constitutes the practice of medicine in general and acupuncture in particular. As “dry needling” is acupuncture, it presents the same inherent risks including but not limited to perforation of the lungs and other internal organs, nerve damage, and infection. Recent reports of serious and potentially life-threatening injuries associated with “dry needling,” include pneumothoraces and spinal cord injury. These and other injuries support the statement that “dry needling” presents a substantial threat to public safety when performed without adequate education, training, and independent competency examination. Adequate training and competency testing are essential to public safety.

I believe this proposed amendment puts the citizens of Virginia at risk and should be denied. It is imperative that courts and medical bodies maintain and preserve strict standards of education and training in the use of acupuncture needles before any person undertakes inserting a needle into a patient.

Thank you for your consideration of my comments.