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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7/22/19  12:05 pm
Commenter: Ash Goddard, Doctor of Acupuncture & Chinese Medicine

opposition to Dry Needling as proposed

I have been working with the State of Washington over the past several years on the issue of the procedure commonly referred to as "Dry Needling." The proposed language in Virginia brings up several concerns.

First, the definition of DN appears to come from "The Analysis of Competencies for Dry Needling by Physical Therapists." This definition appears to be very close to Virginia's definition of acupuncture. Hence, if two procedures are effectively the same, the training standards and licensing requirements should be thus as well. 

Second, during a formal scope expansion (Sunrise review in WA) the aforementioned report was found problematic. The WA Department of Health stated: "HumRRO and FSBPT convened a task force with experts in dry needling to consolidate information and construct a final list of competencies. However, the task force only included representation of physical therapists. It did not include representation from other health care providers like EAMPs [acupuncturists], medical doctors, or nurses, who could have offered their expertise in topics like needle technique, physiological responses, and contraindications to assist with development of minimum training to ensure safe needle technique." Adding an invasive procedure such as DN should, at a minimum, require a formal scope expansion process to ensure public safety, and consulting other professions with expert training in needle-handling is essential. 

The WA DOH also concluded, "HumRRO [the aforementioned report] acknowledges that there does not appear to be widespread agreement regarding the minimum number of practice hours necessary to perform dry needling, and that the acquisition of knowledge and skills is dependent on more than just the number of hours of deliberate practice." While the report outlined areas that need to be addressed in training, it did not define what that training might be. In fact, the very definition of DN is loosely defined and lacks standardization and consistency. As such, established training programs vary widely in content and instruction. No third-party competency exams exist. DN can be virtually anything and allows practitioners to go beyond their scope and utilize electro-acupuncture, acupuncture protocols, and so forth without the proper training to do so safely and effectively.

A clear definition of what DN is and is not should be to be clarified and training standards should be established and implemented prior to expanding the scope of a profession to perform this invasive procedure.

Thank you for your consideration on this very important matter.

CommentID: 73742