Dry needling is acupuncture. To practice acupuncture takes specialized training and certificate, which doesn't fall in the scope of physical therapy.  If someone wants to practice any kind of needling work they should equip themselves with knowledge and license, this is to protect one's own practice as well as public health and safety. Rename acupuncture to dry needling, and lower the requirement for someone to practice it sounds a pretty lame and risky business to me.