Any practice outside the scope of statutory authority is "ultra vires" and illegal. Billing for dry needling under "trigger point therapy" is insurance/Medicare fraud without specific scope of authority AND specific coverage under the policy. If I insert an acupuncture (filiform) needle into your arm, your arm does not care whether I call it DN, Acupuncture, sticking, poking, etc. It has the same effect on the body regardless. Who would you rather have insert a needle? Someone with 4000 hours of training, or someone who learned in a hotel in a weekend. Most states require acupuncturists to have more trainig than that merely in their annual continuing education! Protect the patients should be your first concern!