Response to Dommerholt and Stanborough Re: “Evidence That Dry Needling Is the Intent to Bypass Regulation to Practice Acupuncture in the United States”

Dear Editor:

We appreciate Dommerholt and Stanborough's comments ¹ on our article, “Evidence That Dry Needling Is the Intent to Bypass Regulation to Practice Acupuncture in the United States.” ² We appreciate the opportunity to reply to their concerns.

First, in the paper they cite ³ to support their statement that “[t]he first postprofessional DN [dry needling] courses in the United States were taught in 1997 by a neurologist and physical therapist (PT),” we were unable to find that information. We did see that the paper spoke highly of the key contributions from Dr. Chan Gunn, Dr. Zhong-Hua Fu, Dr. Peter Baldry, and Dr. Chang-Zern Hong in DN development, all of whom were medical acupuncturists. ^{4 –6}

Second, they argue that “there is no more than an 18%–19% overlap between Ashi points and trigger points (TrPs).” This is a logical mistake. Ashi means the tender points, while TrPs are only part of tender points in muscle bellies; TrPs fall within the Ashi points category. ^7,8 In 2008, Dorsher ⁹ refuted this claim and reported a 95% overlap of TrPs with traditional acupuncture points.

Third, we agree that Travell's views about the two fields are complex. Yet as is clearly evident, Travell largely cited the work by Hong and another acupuncturist. She admitted that DN is also called acupuncture. ¹⁰

Fourth, while an argument might be made that “Dr. Ma is not the main representative of DN by PTs [physical therapists],” he is undeniably a major DN teacher.

We are curious about the statement that the U.S. Food and Drug Administration (FDA) has “down-classified” acupuncture [21 C.F.R. § 880.5580 (acupuncture) and 801.109 (labeling)]. ¹¹ We find no evidence of this. In addition, we were not able to find evidence of the uncited statement that “the [FDA] has approved specific 'dry needling needles' or 'physiotherapy needles' for DN.” The one reference we found was for a device called “the automatic intramuscular stimulator,” described as “acupuncture needle” on the FDA website. ¹²

The authors provide no reference to support their statement that “the vast majority of DN instructors are licensed PTs.” Their perception is in conflict with our own. In addition, PT liability insurance does not simply null safety concerns regarding PTs practicing DN.

Finally, we are confounded by the uncited statement that PT training requires 9800 hours. The current graduate level PT education is about 1888–2080 hours (118–130 credits). ^13,14 In addition, by 2015, none of the accredited PT schools had been offering DN courses. ¹⁵ As we noted—and were unchallenged regarding—DN courses are taught at only the 20- to 30-hour continuing education level for PTs. ¹⁶

The response from Dommerholt and Stanborough makes clear that they do not support our thesis that “DN is an intention to bypass regulation to practice acupuncture in the U.S.” We feel it appropriate to complete our response with reference to Gunn's proposition, in 1976, that “as a first step toward acceptance of acupuncture by the medical profession, it is suggested that a new system of acupuncture locus nomenclature be introduced.” ¹⁷ That strategy continues with this response.