Strongly Oppose Dry Needling for Athletic Trainers
I am a Doctor of Acupuncture and licensed by the state of Virginia as well as Nationally board-certified. I strongly oppose this dangerous amendment that would bypass measures integral to maintaining patient safety and proper oversight in the medical field.
Dry Needling is an Aggressive Acupuncture Technique
The opinion that dry needling is not acupuncture is incorrect. While the term “dry needling” is a western term, the technique is clearly described in many ancient acupuncture texts dating back thousands of years. It is a technique that is taught in every acupuncture school and routinely utilized when treating patients with musculoskeletal concerns.
That said, dry needling is a very aggressive acupuncture technique and is often not the best choice for a patient. Trained and licensed acupuncturists take a complete health history and after a lengthy intake and exam, decide on the modalities and techniques that are best for the patient.
Dry needling generally uses acupuncture needles that are much thicker than ones used in other acupuncture techniques. When dry needling, sometimes it is necessary to use very long needles (4”) and go through layers of muscles and navigate around vital organs. This is a very delicate procedure and carries a risk of side effects including local and systemic infection, organ puncture, excessive bruising and bleeding, fainting, dizziness, nausea, reduction in energy and the inability to participate in activities of daily living. A properly trained and licensed acupuncturist has the knowledge to avoid and reduce these risks.
Athletic trainers would only have this needling technique at their disposal (which they learn in an inadequately short course) and the likelihood of applying this invasive procedure to patients for whom it is contraindicated, is very high. Athletic trainers are educated on many other less invasive modalities that they can safely use to just as effectively treat their clients without the higher risks inherent in dry needling.
FDA Classification of Acupuncture Needles Used in Dry Needling
The Food and Drug Administration states that acupuncture needle sales must be restricted to qualified acupuncture practitioners. Dry needling uses the exact same acupuncture needles as those used in other acupuncture techniques. These needles are FDA-regulated Class II medical devices and according to the FDA, their sales “must be clearly restricted to qualified practitioners of acupuncture as determined by the States.”
https://www.govinfo.gov/content/pkg/FR-1996-12-06/pdf/96-31047.pdf
Inadequate Training & Oversight
Acupuncturists are required to undergo a minimum of over 2000 hours of training including almost 700 hours of clinical training directly involving needles. Acupuncturists are required to pass rigorous national (and in some cases state) board exams and have very strict oversight and continuing education requirements. Medical Doctors who perform dry needling and other acupuncture techniques have to undergo 300 hours of training in addition to their medical school education.
Allowing a short course in an invasive acupuncture technique to be deemed adequate training is dangerous and poses a grave risk to public safety
The American Medical Association’s Policy H-410.949: Dry Needling is an Invasive Procedure
The American Medical Association has a policy on dry needling and recognizes the invasive nature of this acupuncture technique.
“Our AMA recognizes dry needling as an invasive procedure and maintains that dry needling should only be performed by practitioners with standard training and familiarity with routine use of needles in their practice, such as licensed medical physicians and licensed acupuncturists.”
https://policysearch.ama-assn.org/policyfinder/detail/dry%20needling?uri=%2FAMADoc%2FHOD-410.949.xml
American Academy of Medical Acupuncture’s Policy on Dry Needling
Some excerpts from the AAMA’s policy on dry needling:
“The American Academy of Medical Acupuncture (AAMA) is the premier North American organization of physician acupuncturists. The AAMA is committed to insuring public health and safety by ensuring that all persons practicing any type of medicine, including acupuncture, are properly trained and educated. It is imperative that courts and medical bodies maintain and preserve strict standards of education and training in acupuncture before any person undertakes inserting a needle in to a patient. An ill-trained practitioner could, as a result of lack of education or ignorance, cause substantial medical injury.”
“Therefore, the AAMA strongly believes that, for the health and safety of the public, this procedure should be performed only by practitioners with extensive training and familiarity with routine use of needles in their practice and who are duly licensed to perform these procedures, such as licensed medical physicians or licensed acupuncturists.”
The current training and regulations in place for Athletic Trainers does not provide the proper education or oversight for this invasive treatment.
I ask the committee to hold the health and safety of the citizens of Virginia in mind and dismiss this hasty amendment that undermines medical safety, erodes public trust and endangers patient health while offering little in return.
I appreciate your time.
Sincerely,
Dr. Yasi Ayat, DACM, L.Ac.