I. Dry Needling Is Acupuncture – A Valid Acupuncture License Is Required

California law clearly defines acupuncture as the insertion of needles into specific points (acupoints) on or near the body surface to relieve pain and treat illness. Regardless of the theory or technique guiding needle insertion, any therapeutic skin penetration with a needle constitutes acupuncture. Therefore, dry needling is acupuncture, falls within the scope of practice of licensed acupuncturists, and requires a valid acupuncture license. Performing dry needling without such a license is illegal.

California Business and Professions Code § 4927(d): “Acupuncture” means the stimulation of a certain point or 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 diseases or dysfunctions of the body, and includes the techniques of electroacupuncture, cupping, and moxibustion.

II. Acupuncture Is the Profession Best Equipped to Deliver Safe, Effective Needle Therapy

In California, licensed acupuncturists must complete over 3,000 hours of academic and clinical training in acupuncture, plus 50 hours of continuing education every two years. They master both traditional Chinese acupuncture and modern specialized techniques, including auricular acupuncture, scalp acupuncture, Tung's acupuncture, floating acupuncture, and dry needling.

Acupuncturists treat diverse patients daily and accumulate extensive clinical experience. They tailor treatments to each patient using evidence-based modalities. Their clinical effectiveness is unmatched by physical therapists who receive only short-term training and use dry needling as an adjunctive procedure.

III. Acupuncture Is the Safest Form of Needle-Based Therapy

Acupuncturists receive the most extensive and standardized training in needle therapy, including more than 900 hours of hands-on clinical internship, supported by consistent daily practice. They are the most highly skilled professionals in selecting points, handling needles, controlling direction and depth, adjusting stimulation, and monitoring patient responses.

California has 13,000 licensed acupuncturists treating millions of residents each year, with an extremely low rate of adverse events. By contrast, injuries caused by PTs performing dry needling are well-documented. A prominent example is the severe pneumothorax suffered by NFL star T.J. Watt following dry needling administered by a physical therapist in December last year.

IV. PTs Performing Dry Needling Violates Critical Medical Professional Boundaries

After a century of development, the modern healthcare system maintains clear, science-based professional divisions to ensure patients receive the safest, most specialized, and most effective care. For example, medical doctors complete seven years of broad training yet still pursue strict specialty certification in cardiology, orthopedics, and other fields, requiring three or more additional years of focused education.

• • Those needing rehabilitative exercise should be treated by a physical therapist.
• • Those needing manual spinal adjustment should see a chiropractor.
• • Those needing acupuncture or dry needling must be treated by a licensed acupuncturist.

Allowing PTs to practice dry needling or acupuncture erodes these vital boundaries, compromising patient safety and diluting professional standards.

V. Physical Therapists Should Focus on Their Scope of Practice, Not Overstep Their Authority

We respect and value physical therapists as essential members of the healthcare team. However, PTs have no legitimate basis to adopt specialized skills from other professions after minimal training. Just as PTs may not practice medicine, prescribe drugs, or perform chiropractic adjustments, they must not perform acupuncture or dry needling. Permitting such an overlap creates public confusion and sets a dangerous precedent for “scope creep” across all licensed health professions.

In practice, acupuncturists regularly collaborate with and accept referrals from physicians and physical therapists, achieving excellent results. This interprofessional teamwork ensures patients receive the highest quality care.

VI. Acupuncture Must Not Be Split or Appropriated by Other Professions

Acupuncture originated in China thousands of years ago, with a complete theoretical and clinical system that has benefited global health. Introduced to mainstream America more than 50 years ago, acupuncture is safe, effective, affordable, and widely recognized by patients and medical professionals alike.

The struggle to legalize and legitimize acupuncture in California and across the U.S. was long and difficult; many practitioners faced arrest. Today, California maintains a rigorous system of education, examination, and regulation, with 13,000 licensed acupuncturists serving millions each year.

Assembly Bill 2497, supported by physical therapy organizations, seeks to separate dry needling from acupuncture and reclassify it as a PT procedure. This legislation endangers public safety, violates the rights of licensed acupuncturists, and deeply harms the cultural heritage of nearly seven million Asian American and Pacific Islander communities in California.

As Assemblymember Stephanie Nguyen stated in the B&P Committee hearing: “The Chinese medicine and acupuncture community has devoted countless years and efforts to this profession and will continue to do so. To hand over this professional privilege easily simply because some want it is a profound disrespect to the Chinese medicine and acupuncture community. I vote no!”