The Board of Allied Health Professionals
1000 Washington St., Suite 710
Boston, MA  02118

To the Board of Allied Health Professionals re: public comment to any changes made in the regulations regarding the practice of Physical Therapists in MA:

I am concerned about the prospect of Physical Therapists practicing acupuncture without being trained and licensed as acupuncturists.  The American Academy of Medical Acupuncture (AAMA) defines acupuncture as the insertion of fine needles through the skin at specific points to cure disease or relieve pain. The AAMA is committed to safeguarding public health and safety by ensuring that all persons practicing acupuncture be properly educated.  Poorly trained acupuncture practitioners are much more likely to cause substantial medical injury, including collapsed lung, nerve damage, blood vessel injury and infection.

There has been controversy in the US as to who is qualified to practice acupuncture. Recently physical therapists have been practicing acupuncture under the name of dry needling, or intramuscular manual therapy. They are even billing this invasive procedure under manual therapy codes. Although they claim that dry needling and acupuncture are completely different, one of their own course manuals, written by Dr. Yun-tao Ma, is entitled Biomedical Acupuncture. They erroneously claim that acupuncturists dont treat pain and dont needle myofascial trigger points, but this is untrue. There is a long history in acupuncture practice of needling points that are tender to palpation for the alleviation of musculoskeletal pain. Both the traditional name for these points, ahshi points, and the more familiar modern name, trigger points are regularly used by acupuncturists to describe this subset of acupuncture therapy.

It has recently come to the attention of acupuncturists who are following this issue, that weekend dry needling workshops for physical therapists are beginning to teach distal acupuncture points along with local trigger, or ahshi points in their workshops. They have renamed these distal points reflex points. This further undermines the claim that dry needling is somehow different from acupuncture.

Acupuncture is an invasive procedure that can result in potentially life threatening complications, and should be performed only by those practitioners with the specific body of knowledge afforded by successfully completing an accredited acupuncture program. Acupuncturists who complete these programs have been shown to have an extremely low rate of adverse effects (.2% in studies). Concern about patient safety around this issue led the state of Illinois to reverse their decision that had previously allowed physical therapists to perform dry needling. 

I, as an acupuncturist Licensed in the Commonwealth of Massachusetts, respectfully urge you to maintain current law and regulations for health care professionals, requiring anyone practicing Acupuncture or Dry Needling, one piece of the practice of acupuncture, to be a licensed acupuncturist.


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