Hello, My name is Sarah Shupe Hung and I am a Virginia licensed acupuncturist with offices in Burke and Alexandria. I would like to express my concerns of the draft regulations.

One of my concerns is that the Board of Physical Therapy has recommended that informed consent include language that dry needling differs from acupuncture as “acupuncture focuses on energy flow and meridians.” This is a gross misrepresentation of the definition of acupuncture, especially as defined in our own scope of practice under Virginia law. Dry needling IS acupuncture. It is one form of many styles of acupuncture that acupuncturists learn in school and continuing education classes.  It does not focus on energy flow or meridians, but uses palpation of Ashi or more commonly known trigger points and often involves deep needling into muscles.

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.  Many claims by physical therapists state that “dry needling” is a recent invention distinct from acupuncture because it is not based on “meridians” or “energy flows”.  I feel that this reflects a gross misunderstanding of acupuncture and is not factual.  ? 

Another concern is public safety related to dry needling.  The draft regulations provide no minimum training standard or information on how they will make sure that only physical therapists with “additional training” will practice dry needling.? Recently the American Medical Association opposed the practice of dry needling. They adopted a policy that said physical therapists and other non-physicians practicing dry needling should – at a minimum – have standards that are similar to the ones for training, certification and continuing education that exist for acupuncture.

One of the board members commented that:

"Lax regulation and nonexistent standards surround this invasive practice. For patients' safety, practitioners should meet standards required for licensed acupuncturists and physicians," AMA Board Member Russell W. H. Kridel, M.D. https://www.ama-assn.org/ama-adopts-new-policies-final-day-annual-meeting

According to that recommendation Current dry needling training is inadequate to protect public safety and consumers.  Most dry needling courses involve only a one or two weekend training.  They also do not include supervised clinical training, which is critical to mastering needle techniques.  Supervised clinical training provides the real world experience that has been key to acupuncture’s strong reputation for safety and effectiveness. 

In comparison to one or two weekend training for PT dry needlers, 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).  

For these reasons I do not support the current draft of regulations and would ask the board not to approve them at this point.

Thanks for your time

Sarah Shupe Hung L.Ac.