Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Physical Therapy
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
Action Practice of dry needling
Stage Proposed
Comment Period Ends 7/26/2019
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7/17/19  11:07 am

Dry needling is not physical therapy professional practice scope

To whom it may concern:

There is no difference between dry needling and acupuncture except in terminology. It is what is called a distinction without a difference.

The Centers for Medicare and Medicaid define acupuncture as; “Acupuncture, in the strictest sense, refers to insertion of dry needles as specially chosen sites for the treatment or prevention of symptoms and conditions.” In their view, any insertion of a filiform needle into the skin is acupuncture, no matter what the terminology.

There are no physical therapy CPT codes that cover the use of filiform needles (dry needles). The only CPT codes that describe anything analogous to dry needling are acupuncture CPT codes.

Acupuncture needles are a Class II medical device that is regulated by the FDA. The “dry needles” used by physical therapists are unregulated and a health risk to the public.

Researchers have found that acupuncture points and trigger points, while discovered independently and labeled differently, represent the same phenomenon. The pattern of trigger points that are found in areas of pain, mirror the acupuncture channels or meridians.

I would also point out that physical therapists do not hold a plenary license and their scope of practice only includes external treatment modalities.

In contrast, NJ acupuncturists are required to have a minimum of 2,500 hours of training after earning a four-year Bachelor’s Degree along with passage of National Boards and a NJ State Licensing Exam.

I would respectfully ask that you oppose this legislation.

Sincerely yours,

Christina Rients

CommentID: 73588