Important Points to Include in Comments:

1. The current regulation fails to define dry needling. The vague nature of the term dry needling may allow physical therapists to practice beyond the technique of trigger point release and incorporate into treatments acupuncture points, acupuncture protocols, electro-stimulation, retention of needles, etc.
   
   

2. The Board of Physical Therapy relied heavily on The Analysis of Competencies for Dry Needling by Physical Therapists to defend their position that dry needling is within the scope of practice for physical therapists. The Analysis defines dry needling as “using filiform needles to penetrate the skin and/or underlying tissues to affect change in body structure and function for the evaluation and management of neuromuscular conditions, pain, movement impairments, and disabilities.”
   
   The Commonwealth of Virginia defines the practice of acupuncture in Chapter 29 of Title 54.1, Section 2900 of the Code of Virginia as “stimulation of certain points on or near the surface of the body by the insertion of needles to prevent or modify the perception of pain or to normalize physiological functions, including pain control, for the treatment of certain ailments or conditions of the body…”
   
   These definitions are almost identical.
   
   

3. The current proposed regulation states that “dry needling is not an entry level skill but an advanced procedure that requires additional training.” However, 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.