The Acupuncture Society of Virginia finds the regulations concerning the practice of Dry Needling by Physical Therapists insufficient in the following ways: Neither the code not the regulations clearly define the Dry Needling. Many LAcs have shared patient reports of treatments by Physical Therapists that are outside the parameters of Dry Needling. For the protection of Virginia's residents and Physical Therapists the regulations should include a clear definition of Dry Needling. Additionally, although we appreciate the acknowledgement that Dry Needling is not an entry-level skill and is an advanced procedure requiring post-graduate training, we believe a minimum training level should be specified.

I am concerned that the regulatory action does not adequately define Dry Needling or dictate adequate training requirements for those who may practice this technique. Dry Needling uses acupuncture needles, but Dry Needlers lack acupuncture training. Dry Needling uses similar points to acupuncture, the same tools, and aims to have the same outcomes. As an acupuncturist, I attended hundreds of hours of didactic, theoretical, and practical training, passing examinations which focused on my knowledge of clean needle technique, safe needling practices, and ways in which needling a client can result in adverse events, and how to avoid them. Further, I will continue to receive continuing education in these matters among other clinical strategies and safety concerns, to maintain my licensure and ensure that I can safely conduct the techniques which I am licensed to practice. I strongly believe that any individual who wishes to use the same tools, and similar techniques, as a licensed acupuncture receive the same or similar training to ensure the safety of the residents of Virginia who may seek treatment from such practitioners. I have heard examples from many patients, professors, and colleagues of instances of injury at the hands of an inexperienced and undertrained practitioner of Dry Needling, and even at the hands of a teacher of Dry Needling during a Dry Needling training seminar. I strongly urge those involved in the regulatory action to review the following articles and consider how to keep Virginians safe in regards to the practice of Dry Needling: DOI 10.1089/acu.2016.1187 ; DOI 10.1089/acu.2016.29032.zhu ; "CCAOM Clean Needle Technique Manual - Best practices for acupuncture needle safety and related procedures" with particular attention to the introduction, especially page xviii, and pages 1-23 regarding the types of adverse reactions to acupuncture and the best practices for their prevention and management.

I appreciate your attention to this matter of public health and safety. 

Dry Needling Opposition

I oppose the use of dry needling by non-acupuncturists and here’s why.

Is it unsafe for physical therapists to use dry needling?  Let me  say that there have been many states that have ruled that acupuncture should only be performed by licensed acupuncturists.  Safety is at the top of those concerns when this issue has been raised legally in the states that disallow dry needling.

I think of physical therapists practicing acupuncture without an acupuncture license because ‘dry needling’ is an acupuncture technique just given a different name.  We acupuncturists call this technique ‘lifting and thrusting of an ah shi point’ and we have specific indications and precautions when using this technique.

Another concern is that some physical therapists say they are practicing acupuncture to their patients per their patients.  Another client stated that the physical therapist inserted at least 70 needles into a small area of her back, each insertion being excruciating.  Is that even safe? She then said she was immobile with pain and totally out of commission for weeks to follow dry needling.  Many other clients have told me that the procedure of dry needling by the physical therapist was excruciating. 

Traditional Chinese Medicine/acupuncture is an intrinsically holistic health system.  We assess the entire body so if someone had muscle spasms chronically, we would treat their symptoms and the underlying issues creating tight muscles working towards reaching a healthy, sustainable system. 

In conclusion, I say lets allow only credentialed practitioners of acupuncture (Licensed Acupuncturists) to practice acupuncture in the manner in which it was created and to represent the broad scope of  healing  possibilities using this time honored medicine.

Susan Sandage,  Dipl. OM, L.Ac., RN