July 28, 2026 · PROFESSIONAL LICENSURE · 12,772 words · 12 speakers · 112 segments
Good morning. I'd like to call this informational meeting of the House Professional Licensure Committee to order. The purpose of today's meeting will be to examine direct access to PT services in the past 30 days, as well as allowing PTs to perform dry needling. We'll hear from several stakeholders today during two separate panels, the first focusing on direct access and the second on dry needling. I'd ask members to hold their questions until each panel has concluded their remarks. Before we get our first panel, I'd like to thank Drexel University for hosting us today. They've been more than gracious. And I've noticed we've been joined by a large student population that I believe are PT students and advocates here today as well. The work we are doing here today is incredibly important because this meeting is being live-streamed and recorded, and we will be able to look back at today's testimony and devise legislation that could affect the future of our state and how PTs operate within Pennsylvania. So it's extremely important that we get this right, and that's why we have a panel of experts here today. I'd like to invite members to introduce themselves.
Representative. Good morning. I'm Representative John Schlegel. I represent the 101st Legislative District in the heart of Lebanon County.
I'm Chairman of the Committee, Representative Frank Burns. I'm from Cambria County. I've been the chairman for approximately four years now.
Now we have people joining us virtually, if they could introduce themselves. Representative Rivera, if you'd like to start.
House district in Lancaster. It was cut off.
Could you introduce yourself again?
Sorry, can you hear me now?
Yes. Okay.
State representative.
Seems like we might have a little technical difficulty, so we are joined by Representative Venkett, Representative Mirsky from Erie and Representative Rivera who is a sponsor of legislation for dry needling. So now I'd like to, we have our first panel here. If you would like to introduce yourself and let us know your credentials.
My name is Dr. Mark Belitsky representing Pennsylvania Chiropractic Association. I'm a licensed chiropractor and I'm board certified in chiropractic rehabilitation.
I'm Dr. Jay Grandio. I am a faculty member at Drexel University in the physical therapy program. I'm a board certified orthopedic certified specialist and a fellow of the American Academy of Orthopedic Manual Physical Therapists.
And good morning my name is Stephen Karp I am on the faculty at DeSales University in Center Valley Pennsylvania I am a physical therapist and I have a PhD in motor control And I'm a board-certified geriatric specialist.
And we have an additional panel member joining us virtually. If you could introduce yourself. Are you able to hear us? He's not moving. So we'll get started here. I ask that you keep your comments to five minutes, and then we'll have questions and answer after that, and we'll go. So if you would care to start.
Good morning, Chairman, Minority Chairman, and distinguished members of the committee. Thank you for the opportunity to speak with you today. My name is Stephen Karp, and I'm here on behalf of the American Physical Therapy Association of Pennsylvania. We appreciate your time and your willingness to consider legislation that modernizes the Pennsylvania Physical Therapy Practice Act. Our request is straightforward. We are asking you to support legislation that extends Pennsylvania's direct access treatment period from 30 to 60 days and eliminates the outdated certificate of authorization requirement. This intuitive and common sense legislation will improve patient access to care, reduce unnecessary health care costs, and bring Pennsylvania in line with nearly every other state in the nation while maintaining all existing patient safety standards. the legislation will also bring pennsylvania in line with the practice acts in our military and the va system those practice acts have permitted direct access for over 30 years at military and va hospitals and clinics in the commonwealth of pennsylvania next slide
Okay.
Because of time constraints, I urge you to watch the video. The video is a first person account of a person from Montgomery County who was harmed physically and financially due to a time lag in obtaining a referral for physical therapy. of the constraints he spent over $300 out of pocket to get the referral and he had to wait almost eight weeks next slide to understand why this legislation is important it helps to understand how we arrived here for many years patients in Pennsylvania could not receive physical therapy without obtaining a physician referral in the early 2000s recognizing advancement of our entry-level degree from bachelor's to master's, direct access came into play. This was an important step forward. However, the law at that time had three significant restrictions. First treatment without a referral is limited to 30 days Second physical therapists must obtain a separate certificate of authorization essentially another license beyond their professional license before they could provide direct access care and there were specific diagnoses that could not be seen by physical therapists. At that time those requirements seem reasonable based upon the master's entry-level degree but healthcare and our profession have evolved dramatically. Back then physical therapists had master's degrees. Now physical therapists are now doctorally trained and almost every other state has modernized its laws to meet this advancement accordingly. Pennsylvania has not. Next slide. Today Pennsylvania has become somewhat of an outlier. 48 of the 50 states and the US military and VA systems either have never required or have eliminated the certificate of authorization. Only Pennsylvania and Virginia continue to require this additional credential. This credential does not represent a different profession. It does not require a different physical examination. It does not create a higher standard of care. Instead it duplicates qualifications that licensed physical therapists have already demonstrated. Next slide. Our proposal consists of three simple changes. First, extend the direct access treatment window from 30 to 60 days. Second, eliminate the certificate of authorization. And third, and this is most important, preserve the physical therapist's responsibility to refer patients whenever the condition falls outside our scope of practice or requires additional medical evaluation. This legislation does not increase the scope of care of our practice. It does not authorize physical therapists to treat diagnoses outside of our scope of care, and it does not remove physician involvement when it is medically necessary. Next slide. Why does this matter? This change benefits both patients and our health care system. Nearly 95% of outpatient physical therapy episodes are completed within 40 days. For those unaware, typically physical therapists see patients one, two, or three times a week. That's where the 60-day extension for the direct access comes into play, because 95% of patients would be discharged before that period of time is up. Next slide. Patient safety remains our highest priority. Today's physical therapists are educated very differently than they were in Pennsylvania first in active direct access. Every new physical therapist graduates with a Doctor of Physical Therapy degree. This education includes extensive coursework in differential diagnoses, medical screening, imaging principles, pharmacology, and clinical decision making. Students also complete more than 1,000 hours of supervised clinical education before graduation. About half of these hours are in the outpatient arena and about half of these hours take place in the inpatient arena such as critical care. Following graduation, they must pass the national licensure examination and complete continuing education throughout their careers. Knowing when not to treat and when to refer is a core component of our education. Our code of ethics requires us to make referrals when appropriate. Additionally the nation largest professional liability insurer for physical therapists does not consider direct access to increased professional liability risk Physical therapists have one of the lowest malpractice premiums of all healthcare professions There are no increases in yearly premiums if a PT works in a state with direct access or a state that limits direct access like Pennsylvania. Finally, none of this legislation changes insurance requirements. For instance, if workers' compensation requires referral prior to the physical therapist seeing the patient, the patient must go to a physician first. Next slide. This slide summarizes several recent systematic reviews and meta-analysis evaluating direct access physical therapy. And in fact, Harry, I will give you an annotated bibliography afterwards, which consists of 10 recent peer-reviewed journal articles dictating the safety, efficacy, and customer service of direct access. I tasked my doctor of physical therapy students at DeSales to find one peer-reviewed publication in 10 years which recommended against direct access, and they could not find one. In closing, members of the committee, this legislation is not a dramatic change. It's a careful modernization of the Pennsylvania law that has not kept pace with today's health care environment nationally, in our military, in the VA system, and all the states bordering Pennsylvania. It preserves every important safeguard. It respects collaborative relationship between physical therapists and physicians. Pennsylvania has been a long leader in health care. On this issue, however, we have fallen slightly behind. Joining the other 48 states and the military in modernizing direct access is a practical evidence-based step that benefits patients, providers, and our health care system. On behalf of APTA Pennsylvania, I respectfully ask for your support of this legislation. Thank you for your time, and my colleagues and I from APTA Pennsylvania would be very happy to answer questions later in these proceedings.
Thank you.
Good morning, Majority Chair and members of the committee. Thank you for the opportunity to address you today. When we talk about direct access to physical therapy, one of the primary questions often is, are physical therapists educated and equipped to serve as safe, first-line care providers without compromising patient safety? As an educator preparing the next generation of physical therapists, I can answer that with an emphatic yes. Modern physical therapist education is not a technical trade. It is a rigorous three-year post-baccalaureate doctoral program. Before our students ever step into a clinic, they complete hundreds of hours in foundational sciences, including advanced gross anatomy, neuroanatomy, exercise physiology, pharmacology, and pathology. A cornerstone of entry-level DPT curriculum is differential diagnosis and screening for medical red flags. We do not teach students simply how to treat neuromusculoskeletal conditions. We teach them how to identify when a patient's primary complaint is not musculoskeletal. DPT students are extensively trained to recognize non-neuromusculoskeletal pathology, whether cardiac, visceral, oncological, or systemic. and to immediately refer those patients to the appropriate medical provider. The changes to direct access did not remove the physician from the care continuum. Rather, it facilitates early, efficient access to conservative care while creating a seamless referral network. Evidence across multiple states and federal health systems, including the U.S. military and the VA, demonstrates that direct access to physical therapy leads to lower imaging costs, reduced opioid prescriptions, faster recovery times, and above all, an exemplary safety record. Pennsylvania's current two-year waiting period to apply for direct access authorization creates an unnecessary barrier to timely, cost-effective patient care. Our entry-level graduates are tested, nationally licensed, and explicitly trained upon day one of graduation to safely evaluate, triage, and manage these patients. Removing arbitrary hurdles allows us to better serve Pennsylvanians while upholding the absolute highest standard of public safety. As detailed in my written submission, over 94% of DPT graduates report strong curricular grounding in clinical reasoning. And national licensure exams test for the differential diagnosis and red flag screening they are taught. Thank you, and I look forward to your questions.
Thank you.
thank you for the opportunity to participate today as i spoke earlier my name is dr mark blitzky i'm a chiropractor i'm board certified in chiropractic rehabilitation i'm the owner of an integrated health care practice that employs physical therapists i'm speaking today on behalf of the pennsylvania chiropractic association i work alongside physical therapists and firsthand hand, I see the value that physical therapy brings to our patients. This is not an argument against the profession or against modernization. We are not here to oppose another profession's advancement. We are here to ensure that every expansion of clinical authority is evaluated under the same evidence-based framework and supported by training, demonstrated by competency, and patient protections commensurate with the responsibility being granted. Pennsylvania currently allows physical therapists to evaluate and treat patients without a referral up to 30 days, as you know. This provides meaningful access. It also allows care to begin, gives physical therapists a time to monitor the patient's response, and establishes a defined period for treatment without referral. The proposal under discussion would extend that period from 30 to 60 days while also, this is important, removing existing requirements related to clinical experience and continuing education for direct access practice. Doubling the period of independent authority while removing the experience and continuing education requirements that currently support it should require a clear evidentiary justification. The committee should ask three straight questions. Why is the increase in 30 to 60 days necessary? What access or patient care problems exist under the current 30-day framework that the additional 30 days would solve? And what benefit does the patient receive from extending the statutory period before referral or involvement by another authorized provider is required? As a portal of entry provider working in musculoskeletal care, I understand the independent access involves more than just beginning treatment It includes determining whether care remains appropriate recognizing when clinical picture has changed and knowing when a broader evaluation consultation or referral is necessary Patients do not always arrive with a clear diagnosis. Symptoms may change. Pain may fail to improve. A condition that initially appears routine may ultimately require imaging, additional diagnostic evaluation, consultation, or referral. This is not a judgment about the ability of individual physical therapists. It's a question of whether the statutory framework maintains the appropriate relationship, access, preparation, independent authority, and patient protection. Before extending the current period, the committee should have a clear evidence that the change is necessary and that the education, competency, and safeguards supporting it are commensurate with the increase in the responsibility. Improved access is an important goal, but access should not be measured only by how quickly treatment begins. It should also be measured by whether the patient receives the right evaluation, reaches the right provider, and is referred at the right time. We are not asking the committee to reject modernization. We are asking the committee to apply one consistent standard. Expanded authority should be supported by evidence, proportional preparation, demonstrated competency, and meaningful patient protection. Thank you for your time and careful consideration.
Thank you. Dr. Kuprovich, can you hear us?
Yes, sir, I can.
All right, you're up.
William Kuprevich, testifying on behalf of the Pennsylvania Osteopathic Medical Association, thank you for the opportunity to present testimony on behalf of us. We appreciate the committee's willingness to hear from stakeholders on these important issues. Changes to health care policy deserve careful consideration because they have direct implications on patient safety, the quality of care, and access to appropriate treatment. As physicians, we believe it is our responsibility to share our perspective based on decades of clinical experience. Allow me to briefly introduce myself. Recently retired after 47 years as practicing as a board-certified osteopathic family physician in Bloomsburg, PA. I'm also board-certified in sports medicine and have served as a physician for high school, collegiate and Olympic athletes throughout my career. My experience culminated in serving as the Chief Medical Officer for Team USA at the 2007 Pan Am Games and the 2008 Summer Olympics in Beijing. Following these, I continued with medical coverage of USA women's basketball through World Cup competitions until 2021. Throughout its history, HOMA has consistently advocated for policies that prioritize patient safety while supporting thoughtful evidence-based improvements in healthcare delivery. It is in that spirit that we offer the following comments. Regarding direct access, we have concerns regarding the proposal to expand direct access to physical therapy from the 30 to the 60 days without physician involvement. 30 days provides a reasonable period of time to determine whether a patient is making measurable progress towards the treatment goals established during the initial evaluation If meaningful improvement has not occurred within that time frame it is appropriate to reassess the diagnosis and overall treatment plan. A re-evaluation by the patient's primary physician may confirm the current course of therapy remains appropriate or may identify that entirely different approach needs to be addressed. Additional medical evaluation can uncover conditions that fall outside the scope of musculoskeletal, excuse me, and may require prompt intervention. For example, while back pain is commonly caused by muscle strain or other muscle your skeletal conditions, it can also be the presenting symptom of serious underlying disease such as lung tumors or systemic illnesses. These diagnoses may not be readily apparent during a physical therapy evaluation alone. Waiting the full 60 days before additional medical assessment unnecessarily delay diagnosis and treatment and potentially have significant consequences for the patient. If a revised treatment plan is needed, initiating that plan after 30 days may improve patient comfort, reduce unnecessary delays, and lead to better clinical outcomes rather than continuing a therapy for an additional month. Houma believes that collaboration between physical therapists and physicians results in the highest quality patient care. We therefore do not support extending direct access from 30 to 60 days without greater physician involvement after the 30-day period. Closer monitoring promotes better outcomes and enhances patient safety. POMA's mission is to advocate for policies that place patient safety first. We trust healthcare professionals and policy makers to carefully evaluate any proposal that extends the scope of practice of professional. We respectfully urge the committee to proceed cautiously regarding both the proposed expansion of direct access and the authorization of dry needling by physical therapist until the sufficient evidence and safeguards are in place ensure these changes can be implemented without compromising patient safety. Thank you for the opportunity to present this testimony.
Thank you. We've been joined by Representative Gatos virtually as well. You know, we're going to open it up to questions and, you know, just for clarification, I know you said that you have to have a certificate of authorization for direct access for 30 days and then the average patient is in therapy for 48 days correct do we have an idea of how many physical therapists actually have the certificate of authorization
The estimates are around 75% of therapists have it. Obviously, many therapists work in the inpatient, like I do in the critical care arena, where we work by the team environment There no there no referral anything we just work together So that eliminates all the therapists who work primarily on the inpatient side of things thank you
representative Schlegel
Thank You mr. chairman I'm just curious in terms of the concerns that have been raised, both in the testimony and what we've heard today. Are those concerns based on a plethora of real-life experiences where it's had a negative effect on the care of the patient, or is this based on professional judgment of the prospects of what could be central areas of concern. Please.
Thank you for the question. Actually, it's more about parity, is that if you have an increased level of responsibility to the patient and the patient care and the patient safety, do you have the commensurate educational responsibilities? Are there markers in place? How much clinical experience? And right now, I don't believe that it is equal. So they're asking for more responsibility for the long-term patient care without having the educational level to match that.
So if I understand correctly, one of the issues you'd be advocating for if direct access would be signed into legislation would be that the amount of training and the type of training would be basically the same.
Correct.
and I was just wondering from a physical therapist standpoint what type of training currently do physical therapists go through to be able to to make those referrals over a 30-day period are you asking do they what type of education do they receive to make the determination if they need
to make that referral yes yeah so all physical therapy programs provide courses like differential diagnosis and medical red screening red flag screening courses so for instance when a patient comes in we get a past medical history of the patient we get a clear understanding of what their current signs and symptoms are as mentioned before there are certainly sometimes where musculoskeletal conditions are truly coming from organ referral or something else so we're teaching students how to screen for that how to kind of see that and then determine do I need to refer this patient out before I can treat them they're trained in cardiopulmonary courses so they can recognize any cardiopulmonary conditions that are outside of the scope of physical therapy care and so the first question that I tell all of our students to ask themselves an answer is should this patient be in my clinic today and if they shouldn't who should I then refer them to and is this an emergent referral or is it something that could be referred over the next couple days and
that if I may mr. chair one more question how much objection from the physical therapist perspective what would there be if the amount of education and the background that went into direct access was commensurate with those, with the medical profession, with those in the chiropractic field. I believe if you would ask physical therapists right now,
they would say that that education is commensurate. that we really feel that our DPT programs do an excellent job in teaching differential diagnoses and red flag science. Just to support that, I would say that all the states that went to unencumbered direct access, there was no increase in malpractice claims. Thank you.
Sir?
Representative Schlegel, just to respond to that, I would ask for actual evidence. Yes, there is training. We're not questioning the training. How much is that training? A lot of the questions on expansion here are vague. Oh, we do train. Oh, we do clinical. Oh, we do refer. How much education actually went into that is the question. So as you saw on the slide, they mentioned about 1,000 hours of clinical education. How does that compare to a chiropractic or medical education and clinical diagnosis? We're about 1,600 hours. So there's a significant difference face-to-face time with patients, relevance of referral, understanding the actual differential diagnosis and where it needs to go and why. That's why we're a portal of entry, and that's why the system has been set up to have that safety. So, yes, there's education. It's just not the same education. Thank you very much.
Thank you, Mr. Chairman.
Thank you. Are there any questions from members online? Seeing none. Carrie Orchard, the executive director of the committee has a few questions.
Good morning. Thank you all so much for being here. I was wondering, you had mentioned, Dr. Karp, that the certificate of authorization is almost
like a second license. Could you talk a little bit about what you have to do to obtain that, what all is tied into it, and whether or not any of that has been kind of achieved as the profession has moved from the masters to the doctoral level? Thank you, Carrie. So as I mentioned earlier, the certificate of authorization became law when physical therapists only had a master's level of education for entry. Since that time, we've advanced to a doctor of physical therapy, so it's a full doctoral program. Most programs are four years undergraduate, three years doctoral education, and that includes a thousand hours of clinical education. To obtain a direct access license, the physical therapist must wait a full two years after graduation before they can apply for it. There's a cost associated with it to the physical therapist. And then once it's granted, the physical therapist must take continuing education courses separate from the required continuing education courses from a typical license. So it nearly doubles the amount of continuing education required, which is another cost. When we submit for clinical education credits for people even not direct access, we have to let the attendees know how many hours are for direct access. So there is a burden there with record keeping also.
Hearing no more questions for the first panel, we'll take like a one minute or two minute break while the second panel joins us up front thank you Thank you Thank you. Thank you. Thank you Our panel two is going to be discussing dry needling I going to ask the presenters to introduce themselves We going to follow the same format Everyone will speak and then the members will ask questions So if you're ready to begin, we'll start with introductions.
My name is Dr. J.J. Thomas. I'm a physical therapist and a dry needling expert.
Morning, I'm Jay Grandio. I am a professor at Drexel University teaching in their physical therapy program. I've been performing dry needling since 2014. in my clinical practices when I was working in Virginia.
Dr. Mark Belitsky, chiropractor, representing Pennsylvania Chiropractic Association. I'm board-certified in chiropractic rehabilitation, and I employ physical therapists.
Good morning.
Suzanne Landis-Katzer. I am a licensed acupuncturist. Hold my doctorate. I've owned my own practice in Montgomery County for 14 years, and the president of the Association for Professional Acupuncture in Pennsylvania, representing today.
Good morning, everyone. My name is Janelle Farkas. I am a licensed and board-certified acupuncturist, and I am also here representing the Association for Professional Acupuncture in Pennsylvania.
And we have Dr. Kupovich virtually as well as part of the second panel.
Thank you, sir. Bill Kaprevich, representing the Pennsylvania Osteopathic Medical Association, board-certified family physician with a board certification in sports medicine.
Thank you. And we'll start with Dr. Thomas. And if you could start and tell us what dry-needling actually is for some of the viewers online. Oh, great.
I do have a prepared piece, too. Do you want me to start with that? Either way. Yeah. I'll start with answering your question. you so much and thank you for the opportunity just to be here dry needling performed by a physical therapist is essentially the use of a needle to reset muscles as this is how I initially describe it to patients so when a physical therapist performs dry needling we're addressing the neuromuscular skeletal system as it relates to movement and pain that is our scope of practice period whether I'm stretching someone or whether I'm giving them an exercise or whether that I am performing a different manual technique on them Our scope of practice is the normal scuscal system as it relates to movement and pain. Dry needling is another tool or intervention that we use to accomplish that goal.
Sure, okay, great. Thank you.
My name is Dr. Thomas. Thank you very much for having me here. I've been a physical therapist for 26 years, have been utilizing dry needling in my practice for over 17 years, and have been teaching dry needling for 15 years. Outside of my clinical practice, I've had the privilege of serving as a subject matter expert in dry needling on both a state and federal level and in different capacities, ranging from education and clinical practice standards to billing and coding related to dry needling. Some examples of the specific work I've done include assisting the American Physical Therapy Association in formalizing the addition of dry needling to the Delaware Practice Act, including working on the subcommittee to write the rules and regulations around that bill. In addition, I've served as an expert in the process of formalizing dry needling in multiple other states across the country. In 2015 and again in 2024, I served as an expert in the review of dry needling competencies conducted by the Healthcare Regulatory Research Institute. This was done in partnership with the Federation of State Boards of physical therapy and with the Human Resources Research Organization I have worked with the American Medical Association the American Physical Therapy Association and alongside the American Chiropractic Association and three acupuncture societies to approve the addition of two CPT billing codes for trigger point dry needling. I also served as the expert on dry needling at the RUC evaluation for establishing value assessment to dry needling coding for billing. As mentioned earlier, I've been teaching dry needling since 2011. In my own clinical practice, I've been able to help tens of thousands of patients with the integration of dry needling into my practice. These patients range in everyone from an 80-year-old who just wants to maintain independence to my professional and Olympic athletes who want to maintain their highest level of performance. Dry needling, needless to say, I have plenty of experience related to physical therapy and dry needling. And with my experience, I'm here to say that dry needling is not a new technique, and it is not something that needs to be established as within or not within our scope of practice. But I don't expect you to just take my word for it. Let me give you some of the evidence that shows us. All of the states, with the exception of California, New York, and Hawaii, currently allow dry needling either directly or implicitly, period. 41 of the states plus D.C. have laws and language that explicitly permit physical therapists to utilize dry needling in their practice currently. Many of the baseline doctoral programs include education around dry needling into their programs at varying degrees. For instance, I have been teaching an introductory lecture at Widener University's physical therapy program for the last five years. Let's talk about clinical practice guidelines. For reference, clinical practice guidelines are a systematically developed, evidence-based set of recommendations designed to help clinicians make decisions about appropriate care for a specific health condition. clinical practice guidelines specifically state dry needling as an appropriate intervention for multiple health health related conditions musculoskeletal conditions to name a few neck pain in the revision of 2017 included dry needling headaches in 2020 low back pain in 2021 lateral elbow pain and muscle function impairments in 2022 heel pain and plantar fasciitis in 2023 Temporomandibular Disorders 2023 and HIP in 2025. I printed off three of these so you can just see how it's written into the into the clinical practice guidelines for your reference if I can give them at the end. And lastly American Medical Association's approval of the process for dry needling CPT codes included a subcommittee which I was a part of and it was a collaborative effect with the American again the American Physical Therapy Association the American Chiropractic Association and three acupuncture societies when we wrote the details of the code we all work together to purposefully allow the code to be inclusive for all parties so the question for us today is not is dry needling within a physical therapist scope the question is since dry needling is a common practice in physical therapy woven into the education practice broadly in Pennsylvania and across the country and written into standards for clinical practice how do we effectively regulate the practice of dry needling amongst professionals. The answer to this question will be revealed through this bill. Thank you.
Good morning. Thank you for the opportunity to speak today. Um, I am speaking today to address the educational foundation and safety profile of trigger point dry needling performed by physical therapists to evaluate whether physical therapists should perform dry needling it is essential to understand the extensive educational prerequisite the physical therapy programs bring to postgraduate specialty training in entry-level programs students undergo exhaustive instruction and human gross anatomy including human cadaver dissection surface anatomy regional neuroanatomy and precision manual palpation by the time a physical therapist graduates they possess a deep understanding of tissue layers neuro vascular pathways and underlying anatomical structures this foundational knowledge is paramount to safety in any invasive or tissue level intervention however dry needling is not an entry level skill taught as a primary intervention in baseline programs nor do we present it as such we review dry needling as an advanced skill requiring targeted hands-on postgraduate continuing education and competency assessment when a licensed physical therapist pursues dry needling they are building upon thousands of hours of foundational education with specific intensive postgraduate training focused on anatomy needle safety clean needle technique infection control and specific high-risk anatomical zones dry needling performed by physical therapists and traditional acupuncture are distinct practices physical therapists do not evaluate or treat using traditional Chinese medicine concepts such as meridians, qi, or energy flow. Dry needling is grounded in Western neuroanatomy and myofascial trigger point physiology. It is a distinct clinical intervention designed to complement neuromuscular rehabilitation. Regulating dry needling with clear postgraduate education requirements, safety standards, and defined hours of continuing education ensures that Pennsylvania consumers have access to safe evidence-based care provided by properly trained practitioners entry-level education provides the ideal structural foundation for this training and clear legislative parameters will safeguard the public while expanding effective conservative care options thank you and I look forward to discussing how we can establish high educational standards for our clinicians
Chairman Burns, again, thank you, and thank you to the whole panel.
The PCA, Pennsylvania Chiropractic Association, approaches dry needling similar to how we did with the extension of the scope in a neutral framework. We are not arguing the physical therapist should never be permitted to perform the procedure. We are asking whether the education, hands-on training, demonstrated competency, and board oversight are commensurate with the authority being granted. The answer does not have to be no. The answer should be show us the standard and don't let it be vague. Be very specific. Dry needling involves inserting a needle through the skin and into the underlying tissue. Safe performance requires knowledge of the anatomy, needle depth and direction, norovascular structures, contraindication, infection control, patient selection, complications, recognizing these complications and the appropriate response when a complication occurs. The anatomy does not change based on the practitioner's license. The obligation to demonstrate proper preparation and competency should also not change either. The proposal requires the completion of a board approved program, but it does not clearly establish how many hours of the education are actually required. How much training must be supervised and how much is hands on How individual competency will actually be demonstrated Whether an examination or practical assessment will be required or how the board will verify that each practitioner is actually qualified These are not minor administrative details. They are the standards that connect clinical authority to patient protection. Program approval is not necessarily the same as an individual competency. A board may approve a course, but an individual practitioner treats the patient. The individual should complete defined preparation and demonstrate the ability to perform the procedure safely. The PCA applies the same principles to its own modernization proposals. We have supported defined education, hands-on preparation, demonstrated individual competency, and board accountability. We accept for ourselves the same evaluation framework we're asking the committee to apply here. The committee should ask, and I actually have a question, is that according to the committee, we're looking to expand into dry needling, but what I'm listening to today is that it's already being performed. And I would ask, how is that being done? What are the preparation and the commensurate with, what preparation is commensurate with this procedure? How much is supervised? Hands-on training is necessary. How will we, as practitioners, demonstrate competency? What safeguards ensure the complications are recognized and managed appropriately? We don't want vague. We want the commission and the committee to have very specific answers to these. We're not asking the committee to favor one profession over another. We're asking that every profession seeking the authority be evaluated through the same core patient safety questions and held to clearly define competency standards commensurate with the procedures. The anatomy is the same. The risks are the same. The obligation to demonstrate preparation and competency should also be consistent. Thank you.
Good morning. My name is Suzanne Lantus-Katzer. I hold a doctorate in acupuncture. I'm nationally certified and licensed by the State Board of Medicine. I've owned my own practice in Montgomery County, Pennsylvania for the last 14 years. As president of the Association for Professional Acupuncture in Pennsylvania, I'm proud to represent our 136 members and advocate for the nearly 800 licensed acupuncturists practicing across our Commonwealth. We appreciate the opportunity to speak with you today and hope to contribute to evidence-based policymaking. Feel free to look at our comments that were provided earlier and ask questions for clarification at any time. The APA exists to advance the practice of acupuncture, improve access for patients, educate the public, advise legislative policy, and most importantly, to promote safety standards and best practices in our medicine. This morning, we would like to share three main thoughts with you. First, why dry needling falls within the scope of acupuncture, why training standards matter, and finally, why transparency and accountability are essential when invasive needle procedures are performed. First, acupuncture is defined in Pennsylvania law as the insertion of needles to stimulate the body for therapeutic purposes, including pain relief. By both legal definition and clinical practice, dry needling falls within that scope. Dry needling is a modern term commonly used to describe a procedure that's been documented in medical literature as effective for more than 2000 years In acupuncture theory we have a number of names for this style of needling We call it trigger point acupuncture sports medicine acupuncture or orthopedic acupuncture The pistoning technique that's often referenced is a needle technique that we call setting the mountain on fire. There are many needle manipulation styles that are part of acupuncture training. The word dry in dry needling refers only to the absence of injectable substances. Dry needlers use acupuncture needles, which are classified as class 2 medical devices, and they're regulated by the FDA to be used only by qualified medical providers. No matter what name is used for the procedure being done, needle insertion creates a therapeutic response in the patient. The act of inserting an acupuncture needle creates a systemic physiological response in the body and the patient. regardless of whether the intent was to simply elicit a twitch response from a muscle or to create more systemic change this leads me to our second point training standards matter licensed acupuncturists complete a multi-year graduate level program of three to four years more than 660 hours of supervised clinical practice within that multiple national board examinations first national certification and clean needle technique certification before treating patients independently. Physicians pursuing acupuncture certification complete 200 hours of formal postgraduate training. Both groups are also required to complete continuing education to maintain their licensure. By contrast, Pennsylvania has no standardized requirements for non-acupuncturists performing dry needling. At present, there are no uniform minimum training hours. no consistent supervised clinical requirements, no standard competency examinations, and no statewide adverse event reporting requirements. While serious complications are uncommonly reported overall, the limited available evidence suggests that adverse event rates may be significantly higher when training is less standardized. That should concern us all. We have also seen recent public cases of pneumothorax, or collapsed lung, following dry needling performed in non-acupuncture settings. Those cases resulted in pain, trauma, medical intervention, and loss of work in normal activity. These events remind us that needle-based procedures are not minor interventions. Acupuncture during pregnancy is another example of why comprehensive training matters. As an acupuncture board, we continue to see advertisements for dry needling during pregnancy courses advertised. Acupuncturists learn not only where needles can be placed, but also when and why certain points may need to be avoided or used during specific times of the pregnancy. Without that depth of training, a practitioner may not recognize important safety considerations. Ultimately, our concern is not about terminology or professional titles. It's about consistent standards of education, safety, and accountability regarding therapeutic use of acupuncture needles. I'll turn it over now to my colleague Janelle Farkas, who will speak on the importance of transparency and accountability.
Good morning, everyone, and thank you again for this opportunity. Much of the case made to date widely as to why dry needling is separate from acupuncture is its separation from its originating culture and the use of a lifting thrusting technique, also referred to as pistoning with the needle being removed as soon as the motion ceases yet practitioners have already expanded well beyond this purported delineation Advertisements for both clinical practices and continuing education can now be found that include retained needles or needles left in the body for an extended period of time, electrical stimulation, and procedures such as facial rejuvenation. This expansion beyond even the original definition of dry needling further increases the risk to patients. Allowing this practice to go on unregulated creates a dangerous precedent. Various justifications for physical therapist's use of acupuncture needles have been provided in different forums, most of which center around their knowledge of human movement and function. Acupuncturists have an intimate knowledge of safely needling on all parts of the body for therapeutic use. Does that mean that if we rename tattooing and piercing therapeutic meridian modification, we would be allowed to offer it without consequence? What about other needle-based therapies like Botox injection and cosmetic fillers? Ultimately, you can see this discussion is not about terminology. Whether someone calls it acupuncture, dry needling, or another name that it's called, the patient experiences the same invasive needle procedure with real physiological effects and real risks. Pennsylvanians deserve confidence that anyone performing such a procedure has met clear, consistent standards for education, competency, and accountability. Thank you again for this opportunity and we look forward to your questions.
Dr. Kuprevich.
Dr. Kuprevich here. Dry needling. The second issue before this committee is the proposal to authorize physical therapists to perform dry needling. Understanding the nature of this procedure is essential and has already been addressed by numerous panelists. Dry needling involves inserting a thin, solid needle into muscle tissue to treat painful medical conditions that limit range of motion and function. Before the procedure is performed, an accurate diagnosis must first be established, followed by the determination that dry needling is most appropriate treatment among the several available therapeutic options. Unlike many medical procedures, dry needling is performed without direct visualization of the structures beneath the skin and beneath the muscle trigger point. As a result, significant complications can occur. For example, inserting a needle in muscles of the upper back, the neck, or the chest carries, as addressed already, the risk of puncturing a lung and causing a pneumothorax or collapsed lung. Also, the possibility of injuring the blood vessels that course under each rib or other vital structures create a true medical emergency. Within the sports medicine community that I'm part of, the dry needling is sometimes performed by orthopedic surgeons, sports medicine physicians, and in some countries, physical therapists working with elite medical teams. Importantly, these individuals have received extensive education and specialized training well beyond their entry-level professional training. And even among these highly trained practitioners treating the elite, the risks of dry needling are well recognized. Many limit the procedure to specific anatomic regions because for the increased risks associated with the torso and other sensitive areas. Furthermore, the medical literature continues to evolve and Additional research is still needed regarding the patient selection, long term effectiveness. Several important questions remain unanswered in this proposal. What level of education and clinical training be required before physical therapist may perform dry needling independently. Next, who will establish the educational standards and competency requirements. What qualifications must instructors possess to ensure consistent high quality training? Will there be standard certification requirements across Pennsylvania? Will practitioners be required to complete continuing education or periodic recertification to maintain competency? What physician collaboration will be available when symptoms suggest an underlying diagnosis beyond the musculoskeletal condition? What emergency protocols would be required should complications as pneumothorax, arterial vascular injury, or other adverse events occur, especially in rural communities where immediate hospital access is limited? These questions are not merely academic. They directly affect patient safety. POMA's position is that authorizing physical therapists to perform dry needling without first answering these questions and establishing appropriate safeguards presents an unnecessary risk to Pennsylvania patients. We remain concerned about three primary areas. areas. The adequacy and consistency of training, the diagnostic expertise necessary to determine when dry needling is appropriate and when other diagnosis or therapy should be considered, the ability to recognize and manage potential serious complications. Once the new scope of practice is granted, it becomes significantly more difficult to impose safeguards or restrictions after the fact. For that reason, it is essential that these issues be resolved before authorization is granted, not afterward. Accordingly, POMA cannot support expanding the scope of practice to include dry needling at this time. Should additional evidence, standardized training requirements, physician collaboration, and appropriate patient safety protections be developed we would be willing to reevaluate our position. At present however too many critical questions remain unanswered. As in my previous testimony POMA is concerned with both dry kneading and expanding direct access for the following reasons. Patient safety providing excellence in patient care. Thank you very much, Mr. Chairman.
Thank you, and thank you all for your testimony. We're going to open it up for questions. I guess my first question is for the physical therapist. How common is dry needling used on your patients, and how common is it that physical therapists are using dry needling in Pennsylvania?
I don have exact numbers on physical therapists in Pennsylvania practicing dry needling currently I can tell you I have been practicing dry needling in Pennsylvania since 2013 How common is it in my practice? I think it depends on how well trained you are. It's similar to other techniques in the sense that there are many tools we use within our practice. For me, it's dry needling. It's joint manual tools, joint mobilization, soft tissue mobilization. These are all pieces of what I integrate into an overall treatment plan, working towards getting a patient back to independence. And so these are initial courses that I would quickly move towards exercise-based rehabilitation to get them to independence. I can tell you I've polled some of my dry needling educator friends, friends that own companies that educate in dry needling, and I have the numbers. They estimate of 250,000 PTs in the country, around 45,000 potentially are dry needling. As I said, there are only six states where there's not formal language that includes it. I do think this is a fair part to say something that I didn't understand when I first started needling in 2009 and requesting, at the time I was in Delaware, and requesting the board's guidance on this process is that in a scope of practice, we don't enumerate all of the tools and techniques we use, right? For instance, cupping is not in our current practice act. So a physical therapist that uses cupping is doing so because it follows our scope of practice, which is in line with treating the neuromuscular skeletal system. There are other techniques, just scraping. Same, if you heard of instrument-assisted soft tissue mobilization, That's not clearly written in our practice act. The only reason these practice act issues have come up is because other professions have felt potentially that it's bleeding into, quote, their space. And with that, I would just say that there's always going to be crossover. So, for instance, my colleague, one of my colleagues from the acupuncture representation mentioned how, spoke of dry needling being specific to acupuncture. but that within acupuncture they use they treat the neuromusculoskeletal system so what i would like to point out is that yes i agree dry needling is pivotal to acupuncture acupuncturists it is within their scope that is part of what they do and they're trained in and they should continue to have that but in addition as physical therapists specializing in the neuromusculoskeletal system us say that them say an acupuncture is saying that we shouldn't have dry needling because dry needling is so pivotal to their career, then that would be similar to us saying that they shouldn't treat the neuromuscular skeletal system because that's so pivotal to our career. So my point being that scope of practice is not defined by how other professions utilize tools or techniques. Scope of practice is defined by our education and training. And I'll follow that up just with one other. So the committee, the task force that I worked on as an expert for the, it was the health Care Regulatory Research Institute, we looked at competency standards. I'll say I'm pleased with the panel here because I think we're actually all in agreement that the reason we're here is that we would all like to see great standards, you know, and I think that getting this bill done is part of where that comes from. So the competency standard project research opportunity that I was part of, what they found is that 88 of what we need to know so we compared national physical therapy examination criteria for doctoral physical therapy programs with knowledge knowledge skills and requirements for dry needling education and in 2025 the numbers were 88% of what we need to know we learn in our doctoral programs so there's only a 12% remaining and that covers clean needle technique and all the other components that were so aptly mentioned so so is dry needling taught as part of the curriculum to be a physical therapist
actually do teach foundational dry needling I don't I had no one in
particular I don't I didn't come with names of exact programs that teach but there are programs where students come out certified in dry needling a few but mostly it's a it's a continuing education just as often we use for spinal manipulation courses you know physical therapists we're hungry to learn we're constantly trying to increase our skill set most of my colleagues you know we have these standards of for for education requirements but we're all blowing that out of the water because we want to keep learning and so yes typically it's an additional amount of training and that varies based on the continuing as that pattern varies based on the continuing education course which again I don't think it's a bad idea to have standards around the courses and and what constitutes an appropriate course.
So you had mentioned in your training for the doctorate program, there's a 12% gap to meet the national standards.
That's what the research showed. Between task force, we had a task force of 10 experts. The experts were dry needling experts like myself, and some were previous board members or CAPTI, meaning national entrance examination experts on knowledge that is required for a doctoral program. And when we compared the data sets, 88% of what we needed to know we graduated with.
So do you believe the answer to solving this problem would be the educational requirements
for the physical therapist to, for the schools to be teaching dry needling as part of the curriculum? No, I actually don't. I mean, listen, I defer to the board on that and to you guys, but I think from my experience, it's typically a postgraduate course that someone would choose to do based on their interest and their patient population. It's not 100% of the PTs that graduate that are going to want to take this. So I think it's important for a physical therapist to have baseline understanding on what the tool is, when it's appropriately used, when it's not appropriate to use, surgical considerations, all of these things. Like in the lecture that I teach to Widener, it's a three-hour lecture, and we cover all of these things. Like, hey, you should know about this because you may or may not want to continue an education on that. So I think it's important to have conceptual idea of the technique, its capabilities, its limitations, and its risks. But I don't think it needs to be an additional requirement. And I also don't think that we'd be able to push that on a federal level personally.
Gotcha. And for the chiropractors, is any chiropractor using dry needling techniques?
Not that I'm aware of. And that was one of my questions is we're looking to license it and expand it into Pennsylvania. We are not against dry needling. Personally, I've even had it done to myself by a physician. And professionally, I see the value in it. I a little questioning on we talking here as though we been doing this for 17 years It not licensed or within the scope of practice How did we get to doing this and 17 years later we standing here now deciding whether or not it should be part of the practice That's a little backwards. As we were talking here, it's about standardization. Is every profession reaching the same standards? Some of these courses are very involved and take a lot of education and a lot of standardization. Some courses are weekend courses. What differentiates that? And should there be a differentiation? We think there should be that there is a high level of competency because, as you heard, they're piercing the skin.
There are much more complications and side effects. Is the education and the requirements and the standardization meeting that? And how is it being actually enforced so that any practitioner that's doing it, including a chiropractor, are we all reaching the same standards of education So it's quality of competency and patient safety. So it's my understanding these are thin needles, and I've never had it done, but it's not going very deep into the person's body and through the conversations I've had over the years. And so I viewed it as relatively harmless and safe until the incident with the Pittsburgh Steeler, T.J. Watt. And maybe the acupuncturist can explain what that is, what happened there.
So with the T.J. Watt injury, T.J. Watt was, as far as we understand, he was needled in the trapezius area, which is the apex of the lung that sits very close to the top of the trap. If you deep needle in that area, you have a pretty high risk of lung puncture. In a big football guy, your risk is less because they're bigger. There's a lot more space to needle. But an acupuncturist will know that appropriate depth according to who your patient is.
Just to your thought about is acupuncture generally very shallow needles?
in the course of acupuncture training you learn the gamut. We have what you call periosteal needling which is called bone tapping. So that's in the, you can do very superficial needling. There are many, many, many styles of acupuncture. There's a Japanese style that almost doesn't insert the needle in the skin. And then it goes all the way to periosteal needling which is the more orthopedic style of acupuncture. And there are many different cultures who have different informational things that kind of factor into how you needle a human or the patient who's in front of you. But it just kind of speaks to the width and breadth of what an acupuncturist does. And, again, we're not, you know, arguing scope of practice. we're really arguing training standards and making sure that people are competent and that they know exactly what they're doing and that they have established numbers, established timelines, established expectations and competency exams and proven measurements that they're moving through to prove competency.
If I may, the main consideration for me with any discussion of this is the real risk.
And risks that those who do not have a traditional education would not have. be aware of. It would be great if we could completely divorce the musculoskeletal system from the rest of the body. However, there are many studies now that show the systemic effects of the insertion of an acupuncture needle to various steps. I do have several needles that are a few inches long, so they're not all small. There are studies that show acupuncture or support acupuncture's effectiveness in things like labor induction for women who are pregnant. So that is why we are so concerned about safety, competency, and really understanding not only the effect on muscles, but also the effect that have been known traditionally for 2,000 years.
Thank you so much. So let's...
I was raised by an attorney, so I like to deal with fear in numbers, in data. So the high-level research that looks at incidence of severe injury associated with dry needling is 0.04, and the highest range is 1%. The percentage of GI bleeds or GI perforation from Advil, over-the-counter NSAIDs, is almost 2%. So there's a higher incidence of injury from something like taking over-the-counter NSAIDs than there are from dry needling. Another fact that I find helpful is HPSO, which is the largest professional liability carrier for physical therapists. They're underwritten by CNA Insurance Company. They do their own independent research to find risk assessment for whether or not they need to raise premium rates for physical therapists who are dry needling. They have done multiple research studies and they have never been concerned about injury, based on their assessment, injury risk to a point where they've raised our premiums. There's one more thing. The TJ Watt thing is, I don't think that's a great discussion for here because we have no hard data on it. No one has released confirmation on whether it was an acupuncturist, a physical therapist, an athletic trainer. We don't know what professional actually made the mistake. And there are conflicting stories because from what I heard, he had a chronic pec injury and it was actually a pec. So I think that is not a fair part for this discussion. Unfortunately, if we had more data, it would be great, but we just don't. And, you know, that's part of it, too. Is it an athletic trainer that did it, and should they be doing it? That's the question, and are they trained to do it?
And that's what we're trying to gather here is, like, and maybe this is a question for the acupuncturist.
is there any point where you're like, well, in a limited scope that the physical therapist would be able to do certain, I mean, I'm not an expert, so I'm just going to say certain size needles to a certain depth, and that's what they would be allowed to do compared to what you're doing.
So this is just a little bit more on what I had brought up.
initially when this conversation all started even prior to the Pittsburgh incident physical therapists were really standing on a definition of a technique the piston technique we call it setting the mountain on fire what-have-you which is just insertion of a needle manipulation to elicit a muscle twitch and then removal of the needle that was the foundation of why dry needling was separate from acupuncture if we accept that and say that that is okay that all they asking for In practice they have already gone way past their own definition of the technique to include electrostimulation where the needles are retained left in the skin connected to a machine similar to a TENS machine, and then stimulated for a period of time, whatever is appropriate for the patient on the table. We were also just made aware of a physical therapist that all they are offering is needle-based services, up to and including facial rejuvenation.
So the discussion of, you know, what would it take to allow dry needling, what would make us feel comfortable with another profession dry needling, becomes how do you restrict the scope to not become full-on acupuncture without an acupuncture education. Understood.
If I may reply. Sure. So the difficulty for me in having an acupuncturist or an acupuncture profession define what a physical therapist can do is that they don't know our scope of practice like we do. They don't know our education and training. This is why the FSBPT and the independent studies by the Human Resources Research Institute was so helpful because they analyzed the data to say our physical therapist, in fact, prepared educationally to be able to use the needle in this capacity. Furthermore, I think I should actually state the Federation of State Boards. You asked earlier for the definition. Here's the Federation of State Boards of Physical Therapy definition on dry needling. Dry needling is a skilled intervention performed by a physical therapist using needles to penetrate the skin and or underlying tissues to affect functional change in the anatomical structure and systems for the evaluation, management, and prevention of neuromusculoskeletal conditions, pain, movement impairments, and disability. These are all, that was my summation earlier. Basically, we're treating the neuromuscular skeletal system. Our definition does not include anything about the specific type of approach, pistoning, et cetera. So I think that's, again, misinformation, misunderstanding, just because an acupuncturist can't actually know everything they need to know to present our profession for what it is.
Okay, that's all the questions I had. Representative Schwabel, do you have a question?
I do, Mr. Chairman. Thank you. In fact, I have to admit that it is the dry kneeling issue that brought me here to Philadelphia today and Drexel University. I have a niece that is a practitioner, a physical therapist practitioner in the pediatrics area, and I have a cousin that just recently graduated and will be starting her professional career next month. And I, along with Representative Rivera, we have had the opportunity to talk to some acupuncturists, and that was certainly an education. So I have a question. I kind of want to go right down the line, and I'll try to keep it very brief for the sake of time. But I think I know the answer from our acupuncturist professionals, but I'm going to ask it anyway. is it your professional opinion that dry needling is a form of acupuncture?
We would say that, yeah, dry needling is a subcategory of acupuncture because it uses acupuncture needles to create a therapeutic response in the body That as simple as it gets I mean I would just add that you know while acupuncture looks like a simple adjunctive technique it a very complicated process and what you don know can cause injury. Thank you very much and from our the chiropractic
perspective I think a critical word that I heard today from your testimony sir was specificity including but not necessarily limited to specificity of standards hours of training and education and how do you measure competency in terms of that specificity and so I would say to ask our physical therapists professionals, is your profession prepared to address or do you think that you already have a blueprint in place for specificity and whether or not the training that physical therapists professionals who are certified in dry needling do they have or should they have more training similar to acupuncturist given the fact that and maybe you don't even agree with the assertion that that dry needling is a form of acupuncture so i'll come up for aaron let you respond
yes i would say there's already 39 states that allow dry needling by physical therapists they have standards they have continuing education requirements and I think there's already a blueprint out there that could be proposed I'm not going to propose that today I think it's something that would come down the down the line but I think we could follow a lot of the standards set by all of the states that surround Pennsylvania that are already providing that care yes I
agree with that especially you know as I said in my opening statement I served on a lot of the committee the subcommittees to help with these roles and
regulations and it's just a matter of sitting down with involved parties and getting it done really.
I will answer the is it the same as acupuncture. From a professional standpoint, of course I do disagree with that. In fact I refer to acupuncturists regularly within my own practice. And so because our scopes are different, I am not going to bleed outside of my scope. I'm going to treat the neuromuscular scelta system and when I see an opportunity that a patient could benefit from something outside of my scope, whether it's chiropractic, whether it's acupuncture, I do it. And that's how I teach my students when I'm teaching dry needling as well. Thank you very much.
Again, I appreciate everyone's testimony today. I thought it was excellent. I appreciate the information that you shared in the written form. And certainly, I think we had an example here of a robust discussion, but probably something that we probably need to take a little bit more further but thank you very much thank you mr chair now we have a question from representative
rivera good morning hopefully you can hear me i can see you on the presentation screen so if you can't hear me just give me a signal we hear you um okay wonderful uh i represent like mr in pennsylvania and i have a lot of chiro a lot of physical therapists as well who are in favor of this legislation and I do want to thank the professional licensure committee for organizing this today I want to thank Rep Schlegel for his personal experience with this legislation and I am happy to support this And I do believe that it was just mentioned that we have other states that we can look toward for answering some of the concerns raised today. And I'd love to know which states have the most comprehensive legislation that satisfies the concerns that were raised. If you were to finish this sentence, boy, I wish dry needling for physical therapists worked like the state of blank. Where is it done well?
I can answer this almost to completion. I will state what I can confidently and state what I know partially. What I know partially is that about four years ago we did already We have discussions with involved parties on potential hours, so with acupuncturists and I believe chiropractor representatives and physical therapists as well, we meaning the Pennsylvania Physical Therapy Association, and we came up with hours, recommended hours of training and a timeline for when we expected physical therapists to follow that. And so that has been initiated, and I think we could probably go back to a starting point of that. That's where I wasn't involved in those conversations at the time, so I don't have a whole picture of that. In terms of, this is one, my own recommendation on education standards is that the standards, in my opinion, should be directed around the approval process for courses that are teaching it personally. Because I think that's where the funnel comes from. And I think if the board can approve or certify or approve particular courses based on a set of standards, then that ensures that people are being trained, again, recognizing the difference between a physical therapist practicing dry needling versus an acupuncturist practicing dry needling, for example. That is something, as an educator myself, that I am very careful to make sure that my physical therapists and chiropractors that I've taught in the past are clear on this. Thank you.
May I ask a question? Are you still there?
Yeah, we're still here.
Okay. Thank you very much for your summary. I guess what I was looking for is to see where Pennsylvania could compare to another state's legislation that would be amenable to PTs, chiropractors, and acupuncturists. So if there's a hot spot in the country that is doing it well and you find out how well that's happening, I would love to have that state's name and information. Thank you.
I'll say I was on Delaware's subcommittee and it was well written. The pros and the cons to it being very inclusive is that if it's very inclusive and detailed then it's a little bit more of a laborious process. But in Delaware it was a very involved process. We used a subcommittee and we had 54 hours or 54 hours I believe it was and that the physical therapists had to do that over two years. Meaning that they couldn't start, most courses are two or three days and that they couldn't start the course and then not finish it in that two year time essentially. They needed a minimum of 54 hours in total in two years. Thank you very much.
I will definitely look more into that. Delaware. Thank you.
As a representative of Pennsylvania Chiropractic Association, we can offer those standards. We've already done the work, and I would presume that you should have done the work before you came to this committee to how to standardize this. If you're looking to pass legislation, you should have it ready to go instead of asking the board to try to figure out how to standardize it. We have the standards. We've set them pretty high bar so that we know that what we are requesting from all of us is that this high standard and safety will be performed and can be followed through. We're happy to share that. We are a proponent for dry needling. It's just the standardization to make sure that the safety and the education is there. And I would like to actually ask that question again to the committee. and I'm really curious if this is not within the scope right now, how is it being performed every day in this state? If we're asking, the physical therapists are asking, can we do this and can you make it part of our scope, I understand. But the testimony is in we're already doing this. How does that happen and how is that being adjudicated?
Doctor, if I may, we're not asking. It is within the scope implicitly. We're asking for them to write it so that it's clear and regulatory and we can regulate it. But as I said earlier with cupping and other tools, certain tools are not explicitly written just as they're not in chiropractic. And so we're not asking for it to be within our scope. We recognize it's within our scope. And we just want the regulatory agencies to put some clarification around it for our physical therapists.
I would just throw out the class 2 medical device is an acupuncture needle and the training that required in order to insert a needle into the body should be regulated And I would just reinforce the idea of safety regulation competency and proven competency The other thing that I did want to mention, you had mentioned 54 hours of training for dry needling. And we are licensed by the State Board of Medicine, and the doctors who are allowed to do acupuncture are required to do 200 hours of continuing education before they are licensed to insert an acupuncture needle. And they already have needle rights effectively. They have good practice. So I would just throw that out there.
Yeah, I should add, remember the competency standards is that, first of all, it's not apples to apples, education for physical therapy versus education for acupuncture. physical therapists actually already have in the Pennsylvania Practice Act, we are, it is formally written for us to do needle EMGs. So we're already actually covered under needle EMG. We've already had the established practice of using needles, inserting needles into the body for that purpose. Thank you.
Carrie Orchard. I was wondering if there's a certification exam or like what's the test? A lot of people talked about competency, so it seems like everyone wants to nail down what the training should look like, but I'm wondering then to the point of some of the presenters, what is the examination or the credential then that someone could get to sort of prove that?
That's a great question. and thank you so much. So I've taught, like I said, since 2011 and taught for multiple companies. And what I can tell you is that there are different processes for different companies partly because the way they teach the material is different So one company may teach upper trunk first and lower trunk second Another company might do whole body, but do break it up into more superficial or less risky muscles in the first level. So the levels are different, which is why each course has to have its own certification process. The companies that I taught for all had both a written and a practical certification component to their process. So as an instructor, we watched them do every single muscle that we taught them. We signed off on them or didn't sign off on them. And I will tell you, there were people I didn't pass. Quite frankly, they need to pass the competency standards. And that's it. But I agree. I think we all agree on that. I think it's helpful to have standards of education.
so would there be some kind of standard but generic terminology that could be written into legislation that would provide that there was ample training so is it something where you know in legislation we would be unlikely to list like specific organizations or specific training programs but we might list qualifications or or qualities that a program has to have like it has to have a written and a clinical component or something like that. What would be some considerations that we should look at for legislation?
Yeah, thank you. And we do have all these written out too. I just didn't want to take the board's time unnecessarily earlier, so I'm happy to pass on everything we have. We have every state's specific. I just didn't want to take too much time earlier. In Delaware, what we did was we put the language so that it basically says, I'm going to paraphrase, but it basically says, when a physical therapist has completed and certified in level one training they are approved to utilize their level one muscles that they already been certified in until the remainder of their training in that two year process to completion of 54 hours. So essentially just recognizing that physical therapists are going, they're learning a specific set of muscles and techniques and that they're expected to utilize those with which they've already been signed off on by an experienced expert educator.
Well, thank you all for your testimony. I gotta tell you, this is one of the best hearings we've had. Just the conversation from both sides and the back and forth, I can say, I see both sides of this issue. And when that happens, that means there is some form of compromise that can be had. We just got to figure out where that is. And that's what this testimony will be used for, is to see where we can find some agreements, where we can find compromise, not only among the groups, but also among the legislators as well. And there was a lot of talk about educational standards here today, and I think that's where the compromise may lie if there is to be one. but how do we get there is what we have to discuss over the next couple months to figure that out if we can get there. But thank you all for coming today, and like I said, this is one of the best hearings. Thank you.
We're adjourned. Thank you.