As both a licensed physical therapist and licensed acupuncturist, having taken a "dry needling course", I can attest that the didactic requirements for a physical therapy to take the physical therapy national examination, is insufficient for admission of solid filiform needle treatment which penetrates viable tissue. The term dry needling was used in Travell & Simons "myofascial pain & dysfunction the trigger point manual", which is intended to describe a hypodermic needle used to stimulate a trigger point, without injecting an aqueous substance. The insertion currently being performed by PT's is with a solid filiform needle and traditionally called an acupuncture needle. I can attest that the "dry needling" course I participated in is insufficient to provide the necessary skills in to practice tissue penetration. As well as, the instructors utilize the acupuncture point system to provide a "paint by number" treatment approach to musculoskeletal diagnosis, reducing the practitioner to the level of a "technician". "Skilled" intervention with solid filiform needles can only be applied when the practitioner has an understanding of the ORIENTAL Medical diagnosis process. Otherwise, use of solid filiform needles are a direct encroachment to the licensed practice of acupuncturists utilizing their assessment and diagnostic skilled, for which they are educated and licensed to preform. These standards are set to protect to public, so that the public knows the level of practitioner proficiency that is providing them care.