In my experience, physical therapists barely understand physical therapy. To think they grasp the complexity of acupucture points and how they combine to produce the desired effects is ludicrous, and DANGEROUS. Dry needling IS acupuncture. It takes many years of study to become a certified: one should be allowed to skip all that training simply because they have friends with political pull. There are four main reasons they should not be allowed to practice acupucture without qualifications:

1. Dry Needling is far outside the physical therapy scope of practice.  When the Virginia Legislature adopted the legal definition of physical therapy it had no intent to allow physical therapists to insert acupuncture needles and no authority for any similarly invasive procedures are allowed in statute.  The Board of Physical Therapy lacks the legal authority to expand the physical therapy scope of practice to include dry needling and any attempt to do so would plainly violate state law.
    
2. Dry Needling is not safe.  Dry needling involves the insertion of FDA-regulated acupuncture needles as deep as 5” into patients by physical therapists that can have as little as a weekend of training and no prior experience in the safe use of needles. The draft regulations in fact provide no minimum training standard whatsover.  There have been a number of serious dry needling injuries across the country ranging from lung punctures to nerve damage. Not surprisingly, the American Medical Association recently explained in adopting a policy critical of dry needling, “Lax regulation and nonexistent standards surround this invasive practice … For patients’ safety, practitioners should meet standards required for acupuncturists and physicians.”  The largest company insuring physical therapists recently called dry needling “an emerging area of risk” and documented numerous dry needling injuries. 
    
3.  Dry needling is the practice of acupuncture.  Dry needling is simply another name for acupuncture as it has been practiced for over 2,000 years.  Dry needling involves insertion of the same FDA-regulated acupuncture needles into the same “trigger points” that have been used in acupuncture for millenia for the same purpose of providing therapeutic relief.  Claims that “dry needling” was an invention distinct from acupuncture because it is not based on “meridians” or “energy flows” reflects a gross misunderstanding of acupuncture and are not factually credible.  
    
4. Dry needling training is entirely inadequate to protect public safety and consumers.  Most dry needling courses involve only one or two weekends of training and does not include any of the supervised clinical training that has been critical to providing the real world experience that has been key to acupuncture’s strong reputation for safety and effectiveness.  In comparison, acupuncturists in Virginia are required to have at least 1,365 hours of acupuncture-specific training including 705 hours of acupuncture-specific didactic material and 660 hours of supervised clinical training. Even medical doctors with extensive training in the use of invasive medical devices, such as acupuncture needles, need to have 300 hours of training in acupuncture (including 100 hours of clinical training) to satisfy the minimal standards for certification from the American Board of Medical Acupuncture (ABMA).