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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7/26/19  11:50 pm
Commenter: Jessica

Efficacy concerns

There exists no verifiable research data attesting to the efficacy of Dry Needling as performed by Physical Therapists.
BlueCross BlueShield, when assessing the probability of relief of symptoms as demonstrated by a survey of available clinical research trials investigating the use of Dry Needling by Physical Therapists, concluded:
“Despite the fact that dry needling has been known for years, there have been few published studies measuring the effect on patient outcomes published in the peer reviewed literature. Those studies that are available have design flaws or comprise small study samples so that it is not possible to draw
conclusions regarding patient outcomes.”24
In a randomized, double blind, sham-controlled crossover trial comparing Dry Needling, Acupuncture and sham treatment of motion related neck pain, Irnich et al (2002) assessed relative quality of care: “Acupuncture is superior to Sham [treatment] in improving motion-related pain and ROM [range of motion] following a single session of treatment in chronic neck pain patients. Acupuncture at distant points improves ROM more than DN [Dry Needling]; DN was ineffective for motion-related pain.”25

Since Dry Needling is Acupuncture, no identifiable need exists to expand the scope of Physical Therapy in Virginia to
include Dry Needling. Acupuncturists are able, well-trained and amply experienced to fulfill all Acupuncture needs of Virginia residents.

The Federation of State Medical Boards lists guidelines for evaluating the merit/need of scope of practice expansion/change including:
? Existence of a verifiable need for the proposed scope of practice change;
? Existing scopes of practice and the effect of requested changes on public health and safety;
Physical Therapy Dry Needling Sunrise DRAFT
Page 331
? Formal education and training purported to support scope of practice changes and the existence of a formal process for accreditation;
? Existing or proposed regulatory mechanisms such as licensure, certification and registration;
? The advisability of allowing independent practice or requiring collaboration or supervision;
? The advisability of interaction and cooperation between affected regulatory boards in
evaluating issues that involve multiple practitioners, in investigating complaints, and in
recommending appropriate discipline;
? Requirements for full and accurate disclosure by all health care practitioners as to their
qualifications to provide health care services;
? Accountability and liability issues relating to scope of practice changes;
? Details, rationale, and ethics of any proposals to bypass licensing or regulatory
requirements in allowing scope of practice changes, the implications for other
practitioners, and the effect on patient safety; and 26
? Financial impact and incentives related to and affecting the scope of practice changes.
? None of these needs have been considered, reviewed or met.
The Federation of State Board of Physical Therapy in Changes in Healthcare Professions Scope of Practice: Legislative Considerations(2006)wrote: “The only factors relevant to scope of practice decision making are those designed to ensure that all licensed practitioners be capable of providing
competent care.”26


eb. 10 Apr. 2012. < 4c9350?OpenDocument>
Irmich D., Behrens, N., Gleditsch, J>M> et al (2002): Immediate effects of dry needling and acupuncture at distant points in chronic neck pain: results of a
randomized, double-blind, sham-controlled crossover trial. Pain 99, 83- 9.
Federation of State Medical Boards. (2005). Assessing scope of practice in health care delivery: Critical questions in assuring public access and safety. Dallas, TX
190. The Federation of State Boards of Physical Therapy. Changes in Healthcare Professions Scope of Practice: Legislative Considerations(2006)
Web. 29 Dec. 2011 <>.

CommentID: 74540