At this writing, there are no independent, agency accredited programs for “dry needling”, no standardized curriculum, no means of assessing competence of instructors in the field, and no independently administered competency exams.

Physical therapy entry level training does not include meaningful preparation for the practice of invasive procedures like dry needling that require additional training. The proposed regulation does not identify specific postgraduate training hours nor specific dry needling continuing education hours nor does it require independent testing to show competency as required by acupuncturists to obtain a license to use a metal needle for therapeutic purpose.

Dry needling is not safe when performed by under trained professionals who have not demonstrated competency and thus have the ability not to harm the public. Current training and lack of independent testing is inadequate to protect public safety and consumers. Medical doctors practicing acupuncture must have 300 hours of training to satisfy the minimal standards of training in acupuncture and pass an independent National exam to become members of AAMA, the American Academy of Medical Acupuncture.

The AMA, the American Medical Association passed a resolution in June of 2016 stating: “Our AMA recognizes dry needling as an invasive procedure and maintains that dry needling should only be performed by practitioners with standardized training and familiarity with the routine use of needles in their practice such as licensed medical physicians and licensed acupuncturists.”