As a licensed acupuncturist in Knoxville, Tennessee, I strongly oppose the proposed regulation that would allow physical therapists to perform dry needling. The reasons for my opposition are as follows:

1. Dry Needling is not different from Acupuncture. There is no factual credibility to the idea that acupuncture is based on only “meridians” and “energy flow.” This idea completely ignores a significant portion of the traditions that have been established over the last 5,000 years. Acupuncturists commonly utilize “trigger points” and other anatomical locations for needles to treat and prevent illness or pain. In fact, both dry needling and acupuncture involve the use of the same FDA-regulated needles. Any attempt to differentiate dry needling from acupuncture is not based on factual information.  

2. Dry Needling is Not Safe. Dry needling involves the insertion of needles up to 5” into patient’s bodies by physical therapists who have as little as a weekend of training with no supervised clinical time. This draft regulation provides no clear outline of what training will be required. Dry needling has serious risks such as pneumothorax and nerve damage. Even the American Medical Association warns against the danger of dry needling performed by under trained physical therapists: “Lax regulation and nonexistent standards surround this invasive practice...For patient’s safety, practitioners should meet standards required for acupuncturists and physicians.” The largest company insuring physical therapists recently called dry needling and “emerging area of sirk” and documented numerous dry needling injuries.

3. Dry Needling Training is Inadequate to Protect the Public: Most dry needling training programs involve little more than a weekend class. Compare that to the Virginia requirements for acupuncturists: 1365-hours of acupuncture specific training including: 705-hours of acupuncture specific didactic material and 660-hours of supervised clinical training. This high standard of training ensures that acupuncture is performed safely. Even training for medical doctors with extensive education on the use of various medical devices are required to complete 300-hours of training in acupuncture, including 100-hours of clinical training, to satisfy the requirements of the American Board of Medical Acupuncture. There is no reason training for a physical therapist should be any less than this.

4. Dry Needling is Outside the Scope of Practice for Physical Therapy: In the state of Virginia, the physical therapy practice act, as written, makes no mention of invasive procedures. The Physical Therapy Board lacks the authority to expand the scope of practice.

Dry needling is an invasive procedure that requires a strong minimum standard of training to perform safely. There are avenues in place to receive the proper training. The NCCAOM has set standards to ensure this training is met. Please oppose this dangerous regulation for the safety of your constituents.