I am a Licensed Acupuncturist in Virginia, and as such speak as a constituent, and a voice to my patients.

1) Many of my patients have come to me with hesitation due to painful needling experienced with dry-needling that did NOT resolve their pain. Be it due to lack of technique or clinical training hours, it appears majority of my patient's have had negative (nay, unnecessarily painful) experiences with dry needling. It is my concern that due to the lack of hours and technique in training, lack of standardization and lack of accrediting agency for Dry-needling, a poor, if not risky service is being provided. Acupuncturists receive 3-4 years of training with a minimum of 680 hours or more vs. the 50 or less hours of PT's dry needling courses. The current proposed regulation states that “dry needling is not an entry level skill but an advanced procedure that requires additional training.” If so, where are the advanced training hours matching the description for "advanced procedure"? Where are the separate board exams? Where are the measures and means of assessing such competency? 

2) Similar definitions. The Analysis of Competencies for Dry needling by PT's, defines dry needling as “using filiform needles to penetrate the skin and/or underlying tissues to affect change in body structure and function for the evaluation and management of neuromuscular conditions, pain, movement impairments, and disabilities.”
The Commonwealth of Virginia defines the practice of acupuncture in Chapter 29 of Title 54.1, Section 2900 of the Code of Virginia as “stimulation of certain points on or near the surface of the body by the insertion of needles to prevent or modify the perception of pain or to normalize physiological functions, including pain control, for the treatment of certain ailments or conditions of the body…” These definitions are almost identical, yet Physical Therapists claim that Dry Needling is not acupuncture. A clearer definition making a distinction needs to be provided. 

Thank you.