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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6/18/19  8:17 am
Commenter: Kim Nguyen

Opposition to dry needling by PTs

CommentID: 72585

6/18/19  6:01 pm
Commenter: Nada Acupuncture

Oppositon to PT perfom dry needling

PTs can performing dry needling only after they finish some shirt class. It is so unprofessional.

CommentID: 72601

6/19/19  9:14 am
Commenter: Doug Erickson

In support of physical therapists performing dry needling

I fully support physical therapists performing dry needling. I would also like to see state regulations changed to drop the requirement that patients get a prescription for dry needling from a doctor in order to receive the treatment from a physical therapist. There have been many times over the last several years when I would have liked to have dry needling done by my PT, but could not due to the extra time and expense involved in having to have a doctor's appointment first in order to get the prescription. I don't believe this type of deadweight loss (both to me physically for forgoing the treatment and to my PT in lost business) is adequately accounted for in the Economic Impact Analysis.

CommentID: 72602

6/21/19  4:41 pm
Commenter: Brittany A

For dry needling

Physical therapist are highly trained professionals that manage complex neuromusculoskeletal conditions. They are much more educated on anatomy, physiology, and medical screening than are acupuncturists and are thus more apt to dry needle safely and effectively. Much of the training is focused on safe and effective use of dry needling. Less continuing education is necessary for therapists because they are already so well educated in, and experts on, the musculoskeletal system. The actual technique of utilizing the needles is what is focused on and research presented during dry needling coursework. Therapists already have the expertise on anatomy unlike many other professions. 

CommentID: 72631

6/27/19  10:22 pm
Commenter: Dr. Beth Scott, PT, DPT

For PT's dry needling with sufficient training

The way the current regulations are written are still good guidance--PT's who wish to use dry needling should have multiple courses (many hours--I believe it is over 50 hours) of training and a similar number of hours of practice prior to being able to use the modality in clinic and bill for it. It is also my understanding that PT's who wish to needle must have a minimum of 2 yrs of experience. I believe this is still good guidance as well. Having practiced PT for over 32 years and needled for approximately 5 years, I feel I can comment on what are wise guidelines. I have heard of PT's needling who did not follow protocol and/or used poor technique and follow-up around needling (usually due to time constraints in the clinic or overbooking). This gives therapists and needling by therapists a bad reputation and reinforces the concerns of other providers who utilize needles in their profession (acupuncturists). Reducing the training required will only contribute to the negative side of this equation. Thank you.

CommentID: 72770

7/5/19  1:51 pm
Commenter: Katie Clifton

PT's Training for Dry Needling

I am against Physical Therapists performing dry needling. The current requirements for PT's is not sufficient to ensure safe needling practices and puts patients in danger of injury. There are other available options for dry needling without the risk. 

CommentID: 72922

7/6/19  11:10 am
Commenter: Alexandra Watkins

Concerns over dry needling for Physical Therapists

I do not think expanding the role of physical therapists to dry needling is in the best interest of the public. Their in-school training for invasive techniques is minimal, as is their licensing and oversight for anything that breaks the surface of the skin. Even with post-grad training, their education in needle technique & safety is a 10th of what is required for licensed acupuncturists which should be the bar. This lapse puts the public at risk of injury and infection, and is an inappropriate expansion of their scope of practice. 

CommentID: 72938

7/10/19  11:06 am
Commenter: Bruce Linnell

Support for new proposed training requirements for dry needling

As a patient who has received dry needling treatment for years, I am strongly in support for the new proposed training requirements for a PT to practice dry needling.  I have also had acupuncture, and the two are totally different things, with different methods and different goals. A well-trained dry needler can affect changes to the body that an acupuncturist never could.

CommentID: 73333

7/11/19  1:11 pm
Commenter: Bryan Esherick, DPT

In favor

Pt's should be required to take a course approved by the Board of PT. Courses offered cover more than enough in terms of needle safety, infection control (already part of graduate course work), palpation, and technique. The reason dry needling only requires one course, unlike accupuncture, is that the technique for dry needling is completely separate from accupuncture. PT's do not need to learn about energy flow, meridians etc., that is required with accupuncture. Having taken a course, I feel well prepared to use this technique for trigger point release and to improve muscle activation, which is the target of this therapy. Thanks!

CommentID: 73511

7/16/19  7:30 pm
Commenter: Evan Marcus

Oppose PT learning Dry Needling

Physical Therapists should not learn Dry Needing because they do not have the right experience or education material. As a licensed Acupuncturist in the state of Florida, I had to pass 4 board examinations to become licensed, earn over 1,000 clinical hours of acupuncture experience in order to become an Acupuncturist, learn the correct needing depth for each part of the human body. More importantly, when to use needling or not depending on the situation. 

CommentID: 73567

7/16/19  7:56 pm
Commenter: Rebecca Reynolds A-A-Acupuncture & Wellness

Opposed to Regulations for PT Dry Needling/Please Veto!!!!!

 PTs are wonderful & powerful professionals that are widely accepted in Western Medical. They have coined the term "Dry Needling"; which is placing acupuncture needles into acupuncture points.  In reality "Dry Needling" is trigger point acupuncture or orthopedic acupuncture. PTs are doing this very effective deep tissue needling with nearly no training 12-60 hours I think; as compared to the thousand of hours of training that an acupuncturist gets and 200 hours that MDs & Choripractors are required to have before doing Needling. This PT " Dry Needling" regulation is not safe for the citzens of Virginia.

The PTs chose to do the regulation route because they knew that these requirements would not be able to get through a legislative process. I was in fact sitting in the PT board meeting when this choice was made.

My husband is a democratic party precinct captain in Northern Virginia, I appeal to the governor to veto this PT "Dry Needling" regulation.


CommentID: 73568

7/16/19  9:30 pm
Commenter: Behnam Goudarzi, MD, FCCP, Pulmonologist

Dangerous dry needling

I have seen two pneumothoraces secondary to dry needling. just like other medical professions, the board should have higher standards in allowing invasive procedure to be done. Acupuncture is a rather invasive procedure that requires years of education and training not just a few days or weeks of courses. in the Right contest and in the hands of right people, acupuncture is very useful but dry needling usually is dangerous and usually has done by people who lack adequate training.

CommentID: 73569

7/16/19  9:32 pm
Commenter: Rozita Rouzbeh, DAc, Staywell Acupuncture

Oppose PTs to perform Dry Needling.

Type over this text and enter your comments here. You are

CommentID: 73570

7/16/19  9:53 pm
Commenter: Keith Loop, Dr. of Oriental Medicine; The Healing Loop

Opposition to Dry Needling done by PT

Dear Interested Parties,

As a prior lawyer and current Dr of Oriental Medicine and Licensed Acupuncturist, I oppose dry needling as performed by Physical Therapists.  This is a blatant attempt to avoid the necessary training, degree and certifications required to perform this invasive and effective therapeutic intervention.  It further diminishes public perception of acupuncture (which is based on a medical classics over thousands of years old) and dilutes its putative effect especially given the dearth of training and oversight in this procedure. 

The primary concern involves public safety and welfare, as even MDs and Chiropractors must document over 300 hours of certified training to perform needling. 

The American Medical Association (AMA) released a statement in 2017 asking that only practitioners with experience with needles be licensed to use them The AAMA has specific and clear national standards requiring 300 hours of didactic training, supervised clinical hours, and the passing of a third party national psychometric exam.  The Current standards do not address even these basic concerns.

The language “certification” was used regarding one particular provider of dry needling training.  It is imperative to understand the difference between a certificate program and true national certification.  The National Commission for Certification in Acupuncture and Oriental Medicine (NCCAOM for acupuncturists and the AAMA for medical doctors both have Certifications requiring specific numbers of didactic hours, clinically supervised hours and a third party national exam.

Secondly, it is a gross intersection into our scope of practice as needling is the core modality that defines acupuncturists as a profession. Other oriental therapies such as cupping, Gua She have already been implemented in many PT offices and it is unsafe and unfair to allow PT's to "take over" all modalities of our medicine without the proper training, guidance, testing and detailed supervision.  This is not good for the public because it further dilutes the clinically proven effectiveness of acupuncture which is why PTs want to copy us in the first place. It is a great medicine but they should have requisite training to practice it.

Thirdly, the insurance industry grossly discriminates against acupuncturists in favor of PT's using dry needling for coverage and this further impacts our protected scope of practice and also endangers public safety. I have met many who equate dry needing with acupuncture and the public perception is not being helped by PTs using dry needling which is also unethical. I hold a medical doctorate in Oriental Medicine and I posses educational hours rivaling the doctorates in Physical Therapy. I personally have over 5000 hours in an in-residency doctoral program. Yet I am not covered by the majority of plans in Virginia, and PTs practicing Dry Needling get to routinely perform this with less than 60 hours of training. This is unethical, wrong and actually embarrassing. 

It should be about education, public safety, and public awareness, integrity of practice and knowledge. Dry Needing is actually acupuncture and should be performed by acupuncturists. Calling is a different name is simply a "wolf in sheep's clothing." Common sense goes a long way here as "Dry Needling" is relatively new on the PT horizon and they have been using our tools (acupuncture needles) and CPT codes (until this past year) and evidential research to promote acupuncture by another name.  The only reason this has been allowed to go on is because of big PT lobby that drowns out the voices of smaller acupuncture lobby. Furthermore, acupuncturists are not know for making waves or trying to be aggressive etc.; however, this is overt and unethical attempt to avoid the appropriate training and infringes on our established profession and hurts public awareness in choices that could relieve pain.  

Thank you for your consideration. 

Keith M Loop, JD, DSOM, LAC, LMT, CYT




CommentID: 73572

7/17/19  12:27 am
Commenter: Bup Lee

Strong Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
Opposition to Dry Needling done by PT
To become an acupuncturist, we go to school for 3 or 4 years!!!!
Needling is our scope. This is so unfair to let pt do needling. Dry needling is one of our scope.
Please stop stop stop letting pt do dry needling
CommentID: 73574

7/17/19  7:17 am
Commenter: Victoria J Taylor, Lic Ac,

Please include educational standards for PT dry needling

While physical therapists may find benefit for their patients using dry needling techniques the current wording of the law does not clearly define dry needling, mandate educational hours or an independent body to oversee the education of such. 

There is no requirement for any specific training. There are no independent, agency-accredited vetted programs for “dry needling,” no standardized curriculum, no means of assessing competence of instructors in the field, and no independently administered competency exams.

Increased harm reduction, as well as patient expectations can be ensured by creating uniformity in the practice, as well as distinguishing it from the practice of traditional Oriental medicine.


CommentID: 73576

7/17/19  8:40 am
Commenter: Xiong Chang

Against dry needling done by PT

Dry needling is part of Acupuncture and should be done by a licensed Acupuncturist.

CommentID: 73578

7/17/19  9:21 am
Commenter: Yam zhang

We strongly against dry needling

CommentID: 73579

7/17/19  9:29 am
Commenter: libiao jiao

We against dry needling.

We against dry needling.

CommentID: 73580

7/17/19  9:37 am
Commenter: Keyvan Shahverdi

dry needling by PT

Strongly against dry needling done by PT.


CommentID: 73581

7/17/19  9:46 am
Commenter: Toni Rittenberg

Dry IS Acupuncture

dry needling is Acupuncture. Just because someone decide to give a new name doesn’t change the bottom line. The only reason they do that is because they new so little about what acupuncture is. 

CommentID: 73582

7/17/19  9:50 am
Commenter: Rong Wu, strongly against dry needling by PT

Needling must be performed by licensed Acupuncture

CommentID: 73583

7/17/19  9:56 am
Commenter: The Association of Traditional Chinese Medicine and Acupuncture

Dry needling should never be allowed to practice by phototherapist

Dry needling is clearly comes from Acupuncture treatment techniques. It is used mainly for treating certain pain related illness. Acupuncturist spend long time to learn broad acupuncture knowledges and techniques,dry needling treatment is a small piece of technique from the idea of  Ashi acupoint treatment. If let physiotherapist use so called dry needling treatment, it is totally unfair for acupuncturist.

CommentID: 73584

7/17/19  10:16 am
Commenter: Jianfeng Zheng

Dry needling is Acupuncture. PT need get training for Acupuncture if they want to do dry needling.

CommentID: 73586

7/17/19  10:34 am
Commenter: Jianqin He

Oppose of Dry Needling Practice by PT, Dry Needling is part of Acupuncture

I am against Dry Needling by PT. Acupuncture education is  at least 3 years, the regulation of PT training is not enough to practice needling treatment and puts patients in danger of injury. 

CommentID: 73587

7/17/19  11:07 am

Dry needling is not physical therapy professional practice scope

To whom it may concern:

There is no difference between dry needling and acupuncture except in terminology. It is what is called a distinction without a difference.

The Centers for Medicare and Medicaid define acupuncture as; “Acupuncture, in the strictest sense, refers to insertion of dry needles as specially chosen sites for the treatment or prevention of symptoms and conditions.” In their view, any insertion of a filiform needle into the skin is acupuncture, no matter what the terminology.

There are no physical therapy CPT codes that cover the use of filiform needles (dry needles). The only CPT codes that describe anything analogous to dry needling are acupuncture CPT codes.

Acupuncture needles are a Class II medical device that is regulated by the FDA. The “dry needles” used by physical therapists are unregulated and a health risk to the public.

Researchers have found that acupuncture points and trigger points, while discovered independently and labeled differently, represent the same phenomenon. The pattern of trigger points that are found in areas of pain, mirror the acupuncture channels or meridians.

I would also point out that physical therapists do not hold a plenary license and their scope of practice only includes external treatment modalities.

In contrast, NJ acupuncturists are required to have a minimum of 2,500 hours of training after earning a four-year Bachelor’s Degree along with passage of National Boards and a NJ State Licensing Exam.

I would respectfully ask that you oppose this legislation.

Sincerely yours,

Christina Rients

CommentID: 73588

7/17/19  11:15 am
Commenter: Yawye ltd

Must not delete the statement “clearly statement:dry needle is not acupuncture “

The whole difference between dry needling and acupuncture is safety issue. The acupuncture is systematically reducing risk of damages from needling. Dry needling is only used by certain situations such as emergency or there is no any other alternative safety treatment. For the above reason anyone practicing Dry needling should get clearly consent from the patient : dry needling is facing exposure of body damage and is not acupuncture which has much high level of body protection.

CommentID: 73589

7/17/19  11:20 am
Commenter: Lavena Chen

Dry needling can only be done by licensed acupuncturists.

Physical therapists are under qualified to practice needling on patients. The lack of proper training and knowledge of proper needling would jeopardize patients’ health. Let us all stand firm against all PTs who try to do dry needling without an acupuncture license. Let us educate the public that drying needling by PTs is unethical and dangerous.

CommentID: 73590

7/17/19  11:36 am
Commenter: Xue Li

Dry needles is Acupuncture

Acupuncture has 5000years history. In New York Acupuncture is three years master  degree . That mean they use three years to learn how to needles on human body, this is professional  career . How about dry needles? Is it save? Is it effective? I against dry needles.


CommentID: 73591

7/17/19  11:41 am
Commenter: Jiliang Xiao

Dangerous for dry needling

Please don’t put Patients into a dangerous position for who is not a licensed acupuncturist to practice on patients , dry needling is out of scope to practice for any physical therapist who is not licensed acupuncturist!

CommentID: 73592

7/17/19  11:50 am
Commenter: Kevin lu LAc CH

Stop PT use Acupuncture “dry needle”

CommentID: 73593

7/17/19  12:04 pm
Commenter: Yiming Lin, Lilburn Acupuncture Wellness Center

Stop PT to do Dry needling, one kind of Acupuncture

Not enough time training for PT to do Dry needling, one kind of Acupuncture.

CommentID: 73594

7/17/19  12:11 pm
Commenter: Joe, MacEwan University

Dry needling is a part of acupuncture

Dry needling is a part of acupuncture, it is dangerous for the public without acupuncture license. According to PT regulations, any technique passing the skin is out of PT’s scope of practice!    

CommentID: 73595

7/17/19  12:32 pm
Commenter: Gang Shi

If preform dry needle without studying acupuncture will cause some problems to the patient,

CommentID: 73597

7/17/19  12:41 pm
Commenter: Hwan chang

Object PT. Use dry needles

Dry needles is the one treatments of acupuncture, PT can not take over this treatment, this professional job is belong to acupuncturist, for career classification, we need respect acupuncturists, they are professional in all kind of acupuncture.

CommentID: 73598

7/17/19  12:44 pm
Commenter: Ruth Downey

Opposition to Dry Needling

 I oppose the introduction of dry needling to the practice of physical therapy because of the inadequate training required.

CommentID: 73599

7/17/19  12:47 pm
Commenter: Jean Haedrich

Strong against PT Dry needles

CommentID: 73600

7/17/19  12:52 pm
Commenter: Amy May Fua

I oppose the practice of performing dry needling, it should be performed by trained people

CommentID: 73601

7/17/19  12:53 pm
Commenter: Chin-Hwa Huang

Opposition to dry needling

CommentID: 73602

7/17/19  12:54 pm
Commenter: Ying Lin

No dry needling for PT

 I do not think expanding the role of physical therapists (PT) to dry needling is in the best interest of the public. First of all, dry needling is part of acupuncture, it should be done by well trained licensed acupuncturists who has been training for 3-4 years on that. Secondly, dry needling is an invasive technique and PT training for invasive techniques is very minimal.  Even with post-grad training, their education in needle technique & safety is less than 5% of what is required for licensed acupuncturists which should be the bar. This lapse puts the public at risk of injury and infection, and is an inappropriate expansion of their scope of practice. I strongly oppose PT to perform dry needling. 

CommentID: 73603

7/17/19  1:02 pm
Commenter: Binghui Guan

Against PT for dry needling practice

Dry needling with a short training period is dangerous. I oppose!

CommentID: 73604

7/17/19  1:19 pm
Commenter: Elaine Wolf Komarow

Appropriate training should be specified in the regulations

The PT Board itself says that Dry Needling is not an entry-level skill and that additional training is needed. However, the regulations don't specify the amount of training. So as to insure the safety of the public, I encourage the Board to specify the minimum amount of training that would be required before PT's could perform this advanced technique. I would also ask that the definition of Dry Needling be limited to local treatments. Treating distally is no longer considered dry needling. Yet many people who have seen PT's for this technique tell me that points were used that were far from the area of their pain.

CommentID: 73605

7/17/19  1:33 pm
Commenter: Zhendong Che.

Against dry needling for PT

CommentID: 73606

7/17/19  2:09 pm
Commenter: Zuobiao Yuan

Dry needling is acupuncture

Dry needling is from acupuncture. They only want steal the idea instead of having enough training.

CommentID: 73607

7/17/19  2:44 pm
Commenter: Dan Dommell

Dry needle

Dry needle is a dangerous practice. This only takes a couple weeks of training. You need better education to perform acupuncture.


CommentID: 73608

7/17/19  3:41 pm
Commenter: Lan Ma

Nay to dry needling by PT’s

Dry needling is very similar to acupuncture and to say it isn’t is very negligent. One should be properly trained as an acupuncturist so as to get the proper benefits that this technique can give.

CommentID: 73610

7/17/19  5:13 pm
Commenter: Jenna Betterson

Post dry needle

Without proper training it is dangerous to practice dry needling. I oppose to this law that is trying to be passed. The schooling is necessary for acupuncturist to have- 3-5 weeks is not enough training.

CommentID: 73612

7/17/19  5:38 pm
Commenter: Wan Qing Zhang

I oppose dry needling, with only few weekends of training to practice.

CommentID: 73613

7/17/19  5:58 pm
Commenter: Peter SU

Dry needling lack adequate training

Dry needling is from acupuncture. Acupuncture is a rather invasive procedure that requires years of education and training not just a few days or weeks of courses. Acupuncture is very useful but dry needling usually is dangerous and usually has done by people who lack adequate training.

CommentID: 73614

7/17/19  6:47 pm
Commenter: Bolin QIN

Safety issue is very important to professional health service ! No dry needling for PT!

Dry needling does not have formal training, certifications and state licensure. It's a bigger risk for the patients, who are treated by the people using dry needling.

CommentID: 73615