CSOMA Lobbyist Defends Acupuncture Standards to PT Board

Below is a written response to the Physical Therapy Board of California reflecting our position on dry needling. Submitted by our lobbyist, who is funded in partnership with the California Acupuncture Coalition, Townsend Public Affairs, Inc.

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Dear Dr. Brandon and Members of the Board,

My name is Drew Fiske, and I am submitting this written response following my public comments delivered during the June 25–26, 2025 meeting of the Physical Therapy Board of California. I spoke on behalf of the California Acupuncture Coalition during Items 6, 12, and 22, and would like to formally reiterate and expand upon those remarks for the written record.

During the discussion of the March meeting minutes, I addressed a claim made by a presenter that California patients do not have access to dry needling unless they leave the state. This is factually incorrect. Dry needling is already provided by licensed acupuncturists in California as part of regulated and comprehensive care. This technique is accessible, legal, and practiced under strict licensure requirements. We respectfully request that the official record reflect this clarification to avoid any future misinterpretation.

I raised significant concerns about proposals to permit physical therapists to perform dry needling without being licensed acupuncturists. Dry needling is not a distinct or novel treatment—it is acupuncture by both legal and scientific standards. It involves the same needles, targets the same areas of the body, and produces similar physiological response.

In California, inserting needles for therapeutic effect is defined as the practice of acupuncture and is restricted to licensed acupuncturists and physicians. Acupuncturists are required to complete over 3,000 hours of education, including nearly 1,000 hours of supervised clinical training. In contrast, dry needling certification for PTs may require as little as 20 to 30 hours, with no uniform regulatory oversight.

Acupuncture needles are classified as Class II medical devices by the FDA and carry inherent risk. Using these devices without adequate training jeopardizes patient safety and undermines California’s regulatory framework.

In closing, I’d like to emphasize our concern with how dry needling continues to be framed as a separate and independent practice from acupuncture. This framing is misleading. The techniques overlap significantly—both in terms of clinical application and physiological effect—and dry needling clearly falls within the scope of acupuncture as defined by California law.

When individuals are allowed to perform invasive procedures like dry needling without meeting the rigorous training and licensure standards required of acupuncturists, it opens the door to confusion, inconsistent care, and increased risk to patients. The issue here is not just terminology—it’s about protecting the public and preserving the integrity of California’s regulatory system.

We respectfully urge the Board to remain vigilant in ensuring that any practice involving acupuncture needles is held to the same professional and safety standards already in place.

Thank you for the opportunity to participate in the meeting and to submit this written response. We appreciate the Board’s continued commitment to upholding high standards of safety and professionalism in healthcare practice across California.

Sincerely,

Drew Fiske
Townsend Public Affairs, Inc.