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:

As a patient who receives acupuncture from a licensed acupuncturist, I am concerned about the prospect of Physical Therapists practicing acupuncture without being trained and licensed as acupuncturists in the state of MA.  I know my acupuncturist has taken a rigorous course of both academic learning and spent over 600 hours in a supervised clinic before being able to sit for the national acupuncture exam.  I want all patients receiving acupuncture, using a filiform acupuncture needle to be able to know and trust that their practitioner is licensed.  Dry needling is acupuncture.  It is an acupuncture/filiform needle used in an acupuncture/ahshi/trigger point.  Changing the name does not change what it is.  Acupuncture has requirements for licensure.  Dry Needling is acupuncture, so please have anyone practicing Dry Needling be licensed to practice acupuncture.

It has recently come to the attention of acupuncturists who are following this issue and their patients, 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 a patient who receives acupuncture 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.  Patients need to know and trust that their practitioners are licensed.


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