Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Physical Therapy
 
chapter
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
Action Practice of dry needling
Stage Proposed
Comment Period Ended on 2/24/2017
spacer
Previous Comment     Next Comment     Back to List of Comments
2/11/17  7:26 pm
Commenter: Joyce Wu, L.Ac.

Would you trust a paramedic to do your open heart surgery?
 

To Whom It May Concerns,

I’m writing to your office today because of the actions of groups that are trying get legislative permission to do acupuncture with less than 50 hours of training by giving the technique a new name.  They are focusing on Virgina at this time, and I am determined to fight this irresponsible misuse of public trust in any way I can. Physical Therapists have rebranded acupuncture.  Since they do not use hypodermic needles, they call it “Dry Needling” and are now trying to legislate their way into effectively practicing acupuncture without adequate training and licensing procedures.  This is dangerous.

California requires 3500 hours of graduate training in classrooms, supervised public clinics, and internship to even be eligible for the acupuncture licensing exam.  And we must be licensed to legally practice acupuncture (or Traditional Oriental Medicine/TOM) in California.  This I have done.  In addition to my graduate training, my 3500 hours of apprenticeship with a master practitioner allowed me to observe treatment of a range of serious diseases few acupuncture students get to see.  Some of my patients are referred to me by medical doctors, and I work in conjunction with their more standard care for outcomes that cannot be achieved by either tradition of medicine alone.  This kind of cooperation for what no one method can achieve alone is the greatest value TOM has to offer here.

Since acupuncture is legislated, licensed, and monitored in California, there are clear boundaries within which I must do my work.  If I violate the standards of my profession, I can be censured or even have my license and my livelihood permanently removed.  And just as medical doctors are, I am subject to malpractice laws and pay for malpractice insurance.  This is as it should be for the vulnerable to be protected.  As an acupuncturist and a health care provider, I have the obligation to protect quality and safety of patient care and to both support all legislation that demands quality and responsibility in the use of acupuncture and oppose all attempts to legislate misuse of the tools my profession has given to the world.

Virginia is one of the few states that haven’t yet established legal standards and procedures to oversee the practice of acupuncture and other forms TOM. This means two things: 1) legislators are not likely to be familiar with TOM, its value and the dangers in its misuse; and 2) anyone who wants a new edge can claim to be competent to use tools and techniques from TOM by giving them new names and people are not likely to notice.  Just as those who are not trained and licensed to practice medicine can be dangerous, those who practice acupuncture or “Dry Needling” without proper training can also be dangerous.  Establishing proper standards and licensing for all the tools and techniques of TOM under laws established by the State of Virgina is essential to protect the quality of health care received by citizens of Virgina.

I urge you to support all bills regarding any form of needling that protect the welfare of the citizens who depend on you to act wisely.  Please support the proper training and effective licensing of acupuncturists and reject any proposal that allows improperly trained people to practice acupuncture by calling it “Dry Needling”.  Please contact me again if you have questions about acupuncture, TOM, or the ways people are trying to get around essential safeguards by giving techniques and tools new names.

Sincerely yours,
Joyce Wu

CommentID: 56561