To Whom It May Concern:

I am writing in opposition to the practice of dry needling, also known as “trigger point therapy”, “trigger point dry needling”, “manual trigger point therapy” (when using dry needling), “intramuscular dry needling” (when using dry needling), “intramuscular manual therapy” (when using dry needling), “intramuscular stimulation” (when using dry needling), by Physical Therapists without extensive training in the techniques of needling.  Dry needling is not specifically included in the entry-level education for physical therapists.”1  Of the three (3) years physical therapy students spend in a program, none of the student’s classroom or lab time is spent receiving instruction or training on dry needling technique.  While standards for the practice of acupuncture from an Accreditation Commission for Acupuncture and Oriental Medicine (ACAOM)- accredited college and passing the National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM) national board certification exams include in excess of 2,000 hours of clinical and didactic education and training, 1,365 hours are specifically in acupuncture with 660 hours as clinical hours.  Typically, a physical therapist who uses an acupuncture needle to perform dry needling in the treatment of muscle trigger points learns through continuing education weekend seminars providing only 27-50 contact hours in “dry needling.”  

The American Academy of Medical Acupuncture (AAMA) cites “an ill-trained practitioner could, as a result of lack of education or ignorance, cause substantial medical injury.  Acupuncture, like Western Medicine is a complex subject.  It cannot be mastered in a weekend or in a month.”2  The World Health Organization (WHO) is on record recommending 1500 hours of training in acupuncture for physicians to gain a “full course of training.”3  The Council of Colleges of Acupuncture and Oriental Medicine (CCAOM) states that “these treatment techniques are the de facto practice of acupuncture, not just the adoption of a technique of treatment.”4  Dry needling technique has been taught in acupuncture programs and performed by licensed acupuncturists since the profession’s inception over 2000 years ago.  Referred to as “Ashi” points in traditional Oriental medicine, the language interprets to describe the same understanding and therapeutic physiological effects in modern scientific terms that physical therapists are attempting to coin as new.  

The NCCAOM, the national certifying board for acupuncture, confirms from a 2003 job task analysis that “82% of acupuncturists surveyed used trigger point needling in patients presenting with pain...Dry needling represents a substantial daily practice among American acupuncturists...Any intervention utilizing dry needling is the practice of acupuncture, regardless of the language utilized in describing the technique.”5

I question the wisdom of expanding the scope of practice of physical therapists to include dry needling when the recognized educational standards of physical therapists do not include instruction and training in the technique.  Additionally, the current post-graduate trainings in dry needling are substandard and inadequate for proper clinical supervision, safety standards, and implementation.  The absence of dry 

needling instruction from the physical therapy curriculum suggests that dry needling was never intended to be performed by physical therapists and in fact has not traditionally been performed by members of the profession.  

Empowering physical therapists to perform an invasive procedure for which they are inadequately trained to practice poses serious risk to an unsuspecting public of very specific harms, which include pneumothorax (physical therapist puncture lung, photo available, Yater-Wallace, Nov 29, 2013 Basalt, CO); punctured nerve (by physical therapist, Kuykendall, Oct 4, 2012 Ellicott City, MD); injury to internal organs, bones; transmission of infectious agents (HIV, HBV, HCV, MRSA, and ‘flesh-eating bacteria.”6  Also, Seirin, the world’s leading manufacturer of acupuncture needles, warns:  “Use (of acupuncture needles) by individuals other than licensed physicians or acupuncturists may lead to serious injury.”7

The FDA strictly regulates acupuncture needles, also known as “thin filiform needles,” as Class II medical devices.8  Federal law restricts this device to sale by or on the order of qualified practitioners of acupuncture…”9  This “caution” is on any packaged acupuncture needle box label.  “Therefore, physical therapists who are not qualified practitioners of acupuncture as determined by the States are violating civil and criminal provisions of the FDCA intended to protect public health and safety when they purchase or possess acupuncture needles.”10  Thus, any persons who are not explicitly authorized to practice acupuncture would be in violation of federal law if using FDA-regulated acupuncture needles.  And any state regulatory or professional board that endorses the practice of such signals to potential patients that those persons are trained, qualified, and legally sanctioned to do so.  This will expose the Virginia Board of Physical Therapy to liability for endorsing a practice that involves the violation of FDA regulations and the unauthorized use of a Class II medical device.11

I encourage you to thoughtfully consider these points before proceeding with any action that would allow the practice of dry needling without proficient didactic and clinical competency standards specific to the strategy.

Respectfully,

Jill L. Kelly, LAc, MAc, DiplAc

Chair, Tennessee Advisory Committee for Acupuncture

6212 Dayton Boulevard, Suite B

Hixson, TN  37343

1 Physical Therapists & the Performance of Dry Needling 2 (Jan. 2012), available at http://www.apta.org/StateIssues/DryNeedling/

2 AAMA Policy on Dry Needling, Dec. 9, 2014.

3 WHO, http://whqlibdoc.who.int/hq/1999/WHO_EDM_TRM_99.1.pdf

4 CCAOM Position Paper on Dry Needling, May 2011.

5  CCAOM Position Paper on Dry Needling, May 2011.

6 National Center for Acupuncture Safety and Integrity (NCASI) The Illegal and Unsafe Practice of Medicine in General and Acupuncture in Particular Under the Term “Trigger-Point Dry Needling” 2015

7 NCASI The Illegal and Unsafe Practice of Medicine in General and Acupuncture in Particular Under the Term “Trigger-Point Dry Needling” 2015

8 Jonas: Mosby’s Dictionary of Complementary and Alternative Medicine. © 2005, Elsevier.

9  61 Fed. Reg. 64616 (Dec. 6, 1996)

10  See 21 U.S.C. 331 (a)-(c), (g)

11 Jerger, Smale.  Letter re Dry Needling.  Nov 13, 2013.