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.