I have personally benefited greatly from  dry needling by my highly trained Doctor of Physical Therapy and fully support continuity of this type of care within the scope of a physical therapist’s practice as an option for patients.  Regarding the proposed deleted language:  I am highly skeptical of the request by the acupuncturist on the RAP that the language disclosing that dry needling is not acupuncture be deleted from the patient disclosure.   It appears a big issue nationally is that acupuncturists think dry needling should be exclusively within their purview. Also that the public is at risk of being deceived into getting dry needling, which acupuncturists say  is acupuncture, from a non-acupuncturist, namely the PT.  Since VA is, from a reading of this rule, allowing PTs to do dry needling and therefore finding it is within the purview of a properly trained PT’s practice, why then should it not be disclosed to the patient that dry needling is not acupuncture, thereby avoiding confusion? The only reason might be that some action may be planned in VA, as in other states, by acupuncturists,  to attempt to limit dry needling to acupuncturists.  If this is eventually successful and disclosures don’t state the current position that dry needling is not acupuncture, the PT runs the risk of being charged with having performed an acupuncture procedure outside the PT’s practice area without disclosing this to the patient and therefore not having obtained informed consent. This is neither in the interest of the public nor of PTs.  The acupuncture community seems committed to having dry needling preserved as part of their practice area to the exclusion of PT’s, with the attendant economic benefit necessarily reserved for acupuncturists as the public becomes more aware of dry needling’s benefits.  I would therefore suggest that the distinction be made clear to the patient, thereby clarifying the current position that dry needling is a separate specialty within the practice of PT. This protects the public AND protects the PT.  Such a clear disclosure also ensures that this regulation is about protecting the public’s medical care and not the economic position of one field of practice.