Dear Board of Physical Therapy, 

I am a licensed acupuncturist and Vice President of the Virginia Association of Naturopathic Physicians. I am writing to object to the intent to draft "dry needling" regulations. Traditional Chinese medicine has understood the concept of needling in an area of musclar hypertension or pain for thousands of years. PTs are claiming that dry needling is different and a different mechanism of action then acupuncture, when acupunture needles are being inserted into areas of muscular hypertension, pain, and/or known acupuncture point locations with acupuncture needles this by definition this constitutes acupuncture. 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.

The lack of standardized training for PTs in dry needling and minimum amount of training received by PTs preforming this procedure, present a serious threat to public health. 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. Regulations would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy that has been adopted by the Virginia General Assembly.

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).

?Thank you for your consideration.

Sincerely,

Sarah Giardenelli, ND, LAc

Virginia Association of Naturopathic Physicians