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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7/25/19  11:20 am
Commenter: Sarah Alemi

Support for IF Properly Regulated

I am a licensed acupuncturist and I am happy to see that other medical professionals also see the benefit of the use of acupuncture needles and want to incorporate needling into their patients' care. However, as needling is an invasive procedure, all those who perform any type of needling should have adequate training, education and regulation. I was required to have 3,000 hours in order to become licensed in Maryland as an acupuncturist and I needed additional testing to even apply for my acupuncture licensed in Virginia. We want to help patients, not leave them with increased pain or risk of adverse events, such as lung collapse. 

As it stands, the current regulation for physical therapists to perform dry needling does not contain ANY MINIMUM REQUIREMENTS. Said differently, any physical therapist, even without any training or practice in needling, can perform needling. That directly puts the therapists' patients at risk of adverse events. Even other healthcare providers who needle have minimum training hours spelled out in their regulations and practice laws, such as primary care physicians and chiropractors. 

Although the regulation does not state any specific minimum hours of training or practice, it also states that "dry needling is not an entry level skill but an advanced procedure that requires additional training." If it has been agreed upon, as other healthcare providers also agree with, that needling is an advanced procedure, then why not make sure to have specific requirements for what that additional training needs to be? As I have already mentioned, acupuncturists in Virginia and elsewhere are very tightly regulated and must meet certain criteria if we are to practice. Same with primary care physicians and other healthcare providers. Although a physical therapist may have plenty of education and additional training in their field, their focus has traditionally been on non-invasive therapies. 

As it stands, this regulation would allow physical therapists to add to their scope of practice an invasive procedure that would not require any minimum or additional training on the part of the practitioner (outside of what they find acceptable), leaving public safety at risk. It would also allow the physical therapists to then tell patients (as some already do), that they can also "do" acupuncture and treat conditions outside of their traditional scope - again, without any additional training. 

How can you expect to regulate a profession and the safety of the those receiving care if there are no guidelines to go by? 

CommentID: 74156