Action | Practice of dry needling |
Stage | NOIRA |
Comment Period | Ended on 12/30/2015 |
Dear Board of Physical Therapy,
I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. Many of my patients have been to physical therapy and received "dry needling". The strong majority have told me that not only was it ineffective, but it was extremely painful. Traditional Chinese medicine has understood the concept of needling in an area of musclar hypertension or pain for thousands of years. Of course this is not always comfortable, but the level of pain these patients have described, goes beyond what seems reasonable. It is very concerning to me when patients tell me that they have been told by their PT that dry needling is different and a different mechanism of action then acupuncture, when acupunture needles are being inserted into areas of muscular hypertension, pain, and/or known acupuncture point locations with acupuncture needles this by definition this constitutes acupuncture. The regulations present a serious threat to public health and would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy that has been adopted by the Virginia General Assembly.
I encourage you not to draft regulations because:
1. 54 hours of training is a completely inadequate level of training to qualify a physical therapist to safely insert acupuncture needles into patients and the regulations therefore are a serious threat to public safety;
2. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training required for acupuncturists and even medical doctors;
3. The dry needling rules are illegal, because they would allow physical therapists to engage in acts that are outside the legal scope of practice for physical therapy as defined by Virginia's General Assembly. There is nothing to support that the General Assembly ever intended to allow physical therapists to insert acupuncture needles into patients absent the same level of training required for licensed acupuncturists.
Thank you for considering my comments.
Sincerely,
Sarah Giardenelli, ND, MSOM, LAc
703.554.1100 x397
s1giard@yahoo.com