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
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2/24/17  9:54 am
Commenter: Michael Callaghan, Yellow Dragon Acupuncture, PLLC, New Braunfels, Texas

OPPOSE Allow PT ability to conduct "Dry Needling"
 

I would like to thank you for the opportunity to provide written testimony before Virginia Board of Physical Therapy.  For the record, I am Michael Callaghan, a Retired Marine Colonel and a graduate of an accredited program of Acupuncture and Oriental Medicine.

I researched the standards required to become an acupuncturist, the testing requirements and the need to maintain proficiency and competency required once I obtained licensure.  In the time that I was in school however I became familiar with the fact that other professions are encroaching on my ability to distinguish myself as a professional by claiming “Certification” versus licensed, using the term “Dry Needling” vs. acupuncture.  What I find truly alarming is that that high standard required for me to seek a basic license – 2625 minimum hours of didactic of which 450 is in Chinese Herbs, Clean Needle Technique Course and an Internship of a minimum of 870 hours of clinical training is just the basic requirement for me to be called a licensed acupuncturist, while other professions have no such requirement and more importantly, there are no courses offered that are accredited by any overarching National Board or Agency.  My education cost well over $70,000.00 over the past 3 years, with many of my colleagues spending close to $100,000 on their education, only to be entering a profession that is being eroded by the lack of enforcement by other professional regulating agencies on their members.

In addition to eroding the profession of Traditional Chinese Medicine, it also confuses the public and those Medical Treatment Facilities that are interested in bringing licensed acupuncturist into their facilities, I have seen advertisements for positions that equate our profession to the level of a technician, something that I am over-qualified for at this point.  If you look at the State of Hawaii as to who can practice acupuncture, you will see that only those who possess a Master Degree or higher in Acupuncture and Oriental Medicine are allowed, no doctors, chiropractors or physical therapist are allowed to practice, regardless of their training without a degree, passing the proper national level tests and being granted licensure as an acupuncturist.

When I look back at my former career, I was trained in 1982 to control tactical aircraft to bomb targets, today that requirement requires a certification as a Joint Tactical Air Controller and no matter what I may think I know, there are now standards that have been developed and all personnel are required to adhere to regardless of rank or service affiliation.  This type of standard needs to be applied today to protect the profession of Licensed Acupuncturist.


Again, thank you for your time and allowing me to speak today. 

 

Sincerely,

Michael W. Callaghan

 

CommentID: 58006