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Does your Scope of Practice allow Dry Needling?

U.S. Dry Needling Scope of OT Practice Decisions

The Integrative Dry Needling Institute LLC is solely an educational resource to provide the knowledge and technical skills necessary to deliver safe and effective dry needling treatment. The Integrative Dry Needling Institute LLC does not make policy, claims, or interpretation on professional licensure or scope of practice. The Integrative Dry Needling Institute LLC encourages all participants to contact their licensing board for official positions and rulings related to the practice of dry needling.  It is your responsibility to know, understand and practice within the specific rules, regulations and guidelines of your state, jurisdiction and professional license.

Click on the below boxes to view the state information provided by individual state boards and  Mary Barnes MOT, CHT, CIDN after communication with each state board as of the date listed.

Alabama
Although it is not mentioned in the practice act, the Board has agreed that is it within the scope of occupational therapy as long as the person has been educated or trained to provide the service.
Ann Cosby
Executive Director
Alabama State Board of Occupational Therapy
770 Washington Avenue
Suite 420
Montgomery, AL 36130-4501
334-353-4466
334-353-4465 (fax)
Alaska

Based on the workgroup recommendations, with further review by the Board of Physical Therapy and Occupational Therapy, it has been determined that the current occupational therapy scope of practice description in statute 08.84.190 does not support dry needling by occupational therapists regardless of education and training. At this time, statutory change is required to perform dry needling. Learn more and read the official statements here.

 
Arizona
March 22′
The Board plans to add a statement regarding dry needling on its website (ot.az.gov) in the next few weeks.
Regards,
Karen Whiteford
Executive Director
Arizona Board of Occupational Therapy Examiners
Arkansas
March 22′
There is currently no reference to the allowance for dry needling in the Medical Practices Act found on the ASMB website (www.armedicalboard.org [armedicalboard.org]).  
 At the December 2017 meeting the Arkansas Occupational Therapy Examining Committee discussed dry needling.  The decision of the Committee was that a statutory change to the Occupational Therapy Practice Act would be required in order for dry needling to be included in the occupational therapy scope of practice in the state.
 I hope this provides the resolution you are seeking.  Thank you for contacting the Arkansas State Medical Board.  
 Heather Owen
Licensing Supervisor
Arkansas State Medical Board
Arkansas Department of Health
1401 West Capitol, Suite 340, Little Rock, AR  72201
Office: 501-296-1802 | Fax: 501-296-1972
California
Thursday, February 27, 2020 9:30 a.m. – Board Meeting
Board Staff Present
Heather Martin – Executive Officer Jeff Hanson – Enforcement Manager Jody Quesada – Analyst
Reza Pejuhesh – Attorney
JMr. Bookwalter summarized public comment #4, regarding dry needling, that he received as a voicemail message. The licensee requested the Board take a position on whether OTs/OTAs can perform dry needling.
Mr. Bookwalter said that it is his belief that OTs and OTAs do not have statutory authority to perform dry needling.
Ms. Pavlovich stated that this service is not in the scope of the occupational therapy practice.
Colorado
Please visit our website at dpo.colorado.gov
· Select the blue box “Healthcare Professions Programs” then the profession; from there you can review Statutes, Rule & Policy.
Customer Care Team
P: 303.894.7800 | F: 303.894.7693
1560 Broadway, Suite 1350, Denver, CO 80202
6/21/22: We are referring your email to the Board.  The Board is included on this email chain.  Please allow time for a response.
Stephanie Diaz
Connecticut
Good Afternoon,
I’ve attached the scope of practice for Occupational Therapists in Connecticut for your review:
Sincerely,
Practitioner Licensing & Investigations Section
(PT declarative ruling)
 
Delaware
Good afternoon,
After reviewing the laws and regulations, dry needling is only mentioned in Physical Therapy:
See section 15.4.
Division of Professional Regulation
861 Silver Lake Blvd., Suite 203
Dover, DE 19904
(302) 744-4500
ref:_00DC016khO._5008y3GsV5:ref
Florida
Thank you for contacting the Florida Board of Occupational Therapy.
 At this time the Board has not addressed Rule Development regarding dry needling.
 I trust this information is sufficient, however, if you need further assistance for Occupational Therapy contact us at: mqa.occupationaltherapy@flhealth.gov, or contact the Board’s Administrator, Mrs. Anna King, at: Anna.King@flhealth.gov.
 My Best Regards,
Deborah K. Boutwell
  Regulatory Specialist II
  Florida Board of Occupational Therapy
  4052 Bald Cypress Way, BIN #C05
Georgia
March 22′
The Georgia State Board of Occupational Therapy has not developed any guidance or statements relevant to dry needling by occupational therapists in the state of Georgia.
GEORGIA STATE BOARD OF OCCUPATIONAL THERAPY
Georgia Office of Secretary of State
Professional Licensing Boards Division
237 Coliseum Drive
Macon, Georgia 31217
Main:  (404) 424-9966
Fax:  1(866) 888-1308
Hawaii
March 22′
Please see Hawaii Revised Statutes (“HRS”) 457G-1.5(a)(3)(N):
457G-1.5 Practice of occupational therapy. (a) The practice of occupational therapy is the therapeutic use of everyday life activities with individuals or groups for the purpose of participation in roles and situations in home, school, workplace, community, and other settings. It includes:
(3)
Interventions and procedures to promote or enhance safety and performance in activities of daily living, instrumental activities of daily living, rest and sleep, education, work, play, leisure, and social participation, including:
(N)
Application of physical agent modalities and use of a range of specific therapeutic procedures, such as wound care management, interventions to enhance sensory-perceptual and cognitive processing, and manual therapy, to enhance performance skills;
Therefore, pursuant to the above, the application of physical agent modalities is allowed. However, while you stated that AOTA determined that dry needling is a physical agent modality, the Hawaii statutes are silent regarding the use of dry needling.
Lastly, please be advised that in accordance with HAR §16-201-90, the above interpretation is for informational and explanatory purposes only.  It is not an official opinion or decision, and therefore is not to be viewed as binding on the Occupational Therapy Program or the Department of Commerce and Consumer Affairs.
Thank you,
Risé Doi (she/her/hers)
Executive Officer
State of Hawaii Department of Commerce and Consumer Affairs
Professional & Vocational Licensing Division
 
Idaho
March 22′
The Board has not issued any guidance on Dry Needling.  We are aware of AOTA’s position.  Thanks.  
Best Regards,
Jan Arrasmith
Education & Practice Specialist
Health Professions
Idaho Division of Occupational and Professional Licenses
Work: 208.488.7529
Illinois
(225 ILCS 75/3.7)
    (Section scheduled to be repealed on January 1, 2029)Sec. 3.7. Use of dry needling.
    (a) For the purpose of this Act, "dry needling", also known as intramuscular therapy, means an advanced needling skill or technique limited to the treatment of myofascial pain, using a single use, single insertion, sterile filiform needle (without the use of heat, cold, or any other added modality or medication), that is inserted into the skin or underlying tissues to stimulate trigger points. Dry needling may apply theory based only upon Western medical concepts, requires an examination and diagnosis, and treats specific anatomic entities selected according to physical signs. "Dry needling" does not include the teaching or application of acupuncture described by the stimulation of auricular points, utilization of distal points or non-local points, needle retention, application of retained electric stimulation leads, or other acupuncture theory.
    (b) An occupational therapist or occupational therapy assistant licensed under this Act may only perform dry needling after completion of requirements, as determined by the Department by rule, that meet or exceed the following: (1) 50 hours of instructional courses that include, but are not limited to, studies in the musculoskeletal and neuromuscular system, the anatomical basis of pain mechanisms, chronic pain, and referred pain, myofascial trigger point theory, and universal precautions; (2) completion of at least 30 hours of didactic course work specific to dry needling; (3) successful completion of at least 54 practicum hours in dry needling course work; (4) completion of at least 200 supervised patient treatment sessions; and (5) successful completion of a competency examination. Dry needling shall only be performed by a licensed occupational therapist or licensed occupational therapy assistant upon referral.
(Source: P.A. 102-307, eff. 1-1-22.)
 
Indiana
March 22′
Indiana
Thank you for contacting the Indiana Professional Licensing Agency.  Please visit our website http://www.in.gov/pla/ot.htm , where you may access the Indiana Occupational Therapy Committee Licensure Laws and Regulations, application requirements, and general license information.  Please be advised that the Indiana Attorney General’s Office has advised the Professional Licensing Agency that the agency’s staff and the Indiana Occupational Therapy Committee are not in a position to give advisory opinions.  The statutes and rules are published and available on our website, http://www.in.gov/pla/2518.htm  for the public to reference regarding their particular situation.  It will be necessary for you to contact your own legal counsel for an interpretation of the statutes and/or rules regarding your particular situation if you are unable to determine compliance on your own.
Sincerely,
Indiana Professional Licensing Agency
Indiana Occupational Therapy Committee
402 West Washington Street, Room W072               
Indianapolis, Indiana 46204
Office: 317- 234-8800
Fax: 317-233-4236  
Iowa
March 22′
Here is the offical response on dry needling from the OT board executive. 
It is the current consensus of the Board that dry needling does not appear to be prohibited by the law or administrative rules. However, dry needling is an advanced skill that requires additional training beyond entry-level education and should only be performed by OTs who have completed additional education and demonstrated knowledge, skill, ability and competency in the performance of the procedure. If the Board determines that an OT Is performing dry needling outside their training or expertise it could result in the licensee being disciplined by the Board. The Board has not issued an official opinion or policy statement on the performance of dry needling by Iowa licensed OTs. The Board will continue to evaluate information regarding this issue as it becomes available.
From: IDPH, PLPublic <plpublic@idph.iowa.gov>
Date: Tue, Jan 25, 2022 at 3:01 PM
Subject: Fwd: Occupational Therapy Board
To: Gavin Nordberg <gavin.nordberg@idph.iowa.gov>o
Kansas
March 22′
Thank you for contacting the Kansas State Board of Healing Arts. This message is from the Office of the General Counsel who represents the Board. The Office of the General Counsel does not render legal advice or services to private individuals or entities. All statements are intended as general guidance and do not necessarily represent the position of the Board. No warranties or representations are made regarding the completeness or adequacy of the information provided. You should not construe this general guidance as legal advice or the establishment of an attorney-client relationship. It is necessary that you obtain independent legal counsel for an application of the law to your particular situation.
 The scope of practice for occupational therapy is outlined in K.S.A 65-5402. While the Board has not had an occasion to take an official position on whether dry needling is within an OT’s scope of practice, it is likely not within the scope of practice for an OT in Kansas as the law is currently written or interpreted.
 Other professional licensure scopes (i.e. PTs pursuant to K.S.A. 65-2923 and K.A.R. 100-29-18 and L.Ac (acupuncture) under K.S.A. 65-7602(i)) include dry needling specifically in their statutes . An OT practicing those procedures may be considered engaged in the unlicensed practice of these professions.
 Here is a link to the Kansas Occupational Therapy Practice Act, K.S.A. 65- 5401 et seq, and its regulations:
 It might be a good idea to reach out to the KOTA (www.kotaonline.org) to see where they are at with the matter, as it might be something that is already on their radar.
 Sincerely,
 The Office of the General Counsel
Kentucky
March 22′
The Board regrets to inform you that it is not authorized to issue advisory opinions. This means any answer volunteered by the Board would be neither authoritative nor binding on any court, licensee, or future board.  
We recommend you consult The Kentucky Occupational Therapy Practice Act, which can be found in Chapter 319A of the Kentucky Revised Statutes, and the Board’s administrative regulations, which can be found in Chapter 28 of Title 201 of the Kentucky Administrative Regulations. You might also consult an attorney.  
The Board is aware of a position paper about dry needling from the AOTA, but cannot provide an opinion. https://www.aota.org/Practice/Manage/Scope-of-Practice-QA/dry-needling.aspx
Thanks,
Chessica Nation
Administrative Section Supervisor
Department of Professional Licensing
P.O. Box 1360
Frankfort, KY 40602
Louisiana
March 22′
The Occupational Therapy Advisory Committee (OTAC) of the Louisiana State Board of Medical Examiners (LSBME) is currently reviewing our Rules for needed updated language and changes. The issue of dry needling, and other modalities with a high risk of potential harm, has been researched and discussed in partnership with the Louisiana Occupational Therapy Association. No specific language has been drafted yet. We have been following the AOTA’s recent decisions.
OTAC provided an Advisory Opinion on Dry Needling to the LSBME in 12/2020 in which we stated that dry needling is within the scope of occupational therapy, but is not an entry-level skill, and that it requires continuing education and certification in order to protect the public from harm.
 Sincerely,
Darbi Philibert, Chair, and
Ingrid Franc, Co-Chair
OT Advisory Committee of the Louisiana State Board of Medical Examiners

 

Maine
March 22′
Thank you for your message. The board has not issued any guidance on the use of dry needling. We will present your email to the board at the next meeting. Tentatively scheduled for March 18, 2022 at 9am.
Thank you,
Tammy Reed
Office Specialist I
Office of Professional & Occupational Regulation
35 State House Station
Augusta, ME  04333-0035
Ph (207) 624-8624
Fax (207) 624-8637
Hearing Impaired /TTY (888) 577-6690
Maryland
March 22′
Currently, OTs in Maryland still cannot perform dry needling, but the Board is planning to introduce regulations to make it a PAM later this year.
Lauren Murray
Executive Director, Maryland Board of Occupational Therapy Practice
410-402-8556
 
Massachusetts
June 22′
Dry needling has been under review by the MA Board. The information will be posted to the Board’s website when it becomes available.
Board of Allied Health
6/20/22– Hello,
The response is the same, nothing has changed.
 -Board of Allied Health
Michigan
June 22′
 
In a position statement, the ASHT was unable to reach a conclusion on the use of dry needling but acknowledged that dry needling is used by occupational therapists and physical therapists. This statement recognizes that dry needling is within the scope of occupational therapy, yet the state practice acts still dictate regulation for dry needling so if dry needling is not in the public health code the State of Michigan has not added this to OT/OTA scope of practice.
Document Type Description
Section 333.18301 Section Definitions; principles of construction.
Section 333.18303 Section Promulgation of rules; restricted use of words or titles; practice of occupational therapy or occupation therapy assistant; license required; exceptions.
Section 333.18305 Section Michigan board of occupational therapists; creation; membership; terms.
Section 333.18307 Section Licensure as occupational therapist; rules.
Section 333.18309 Section Licensure as occupational therapy assistant; rules.
Section 333.18311 Section Assistance.
Section 333.18313 Section Continuing education or competence requirements; rules.
Section 333.18315 Section Third party reimbursement or mandated worker’s compensation benefits not required
Respectfully,
Kaye T
#team10269
Minnesota

In my communications from AOTA today regarding motions 10 and 11 at the AOTA representative assembly, it is my understanding that the Commission on Practice was directed to revise position statements on Physical Agents and Mechanical Modalities and adjunctive/preparatory techniques.

These statements were to be developed and made available by the fall 2022 meeting.

In my understanding of them, this does not mean that the revised statements are currently available.

Ultimately, the board is unable to issue guidance statements specific to this as it is not written into Minnesota State statutes 148.6404 governing Scope of Practice (https://www.revisor.mn.gov/statutes/cite/

148.6404). I would encourage you to closely review the scope of practice and in particular the last item in scope of practice (c): (c) “Occupational therapy services must be based on nationally established standards of practice.”

Statute are silent on this particular named technique as it is on multiple techniques used by OT’s (e.g. myofascial release, craniosacral therapy, interactive metronome, etc), neither specifically allowing or disallowing them. Any practitioner using any particular technique must ensure they have the proper training and competence to deliver the technique safely and with first and foremost regard for client and public protection.

Regards, Chris Chris Bourland Executive Director

MN Board of OT Practice
335 Randolph Avenue Suite 240

St. Paul, MN 55102

Mississippi
March 22′
Dry needling was added to the statute and rules have been
promulgated (see 8.1.4 miss. Code.ann. 73-24-13)
2. An occupational therapist must meet the following requirements in order to be deemed competent to perform dry needling:
a. A minimum of 3 years clinical experience as a licensed occupational therapist
b. Documented successful completion of dry needling course(s) of study approved by the Department that includes:
(i) A minimum of 50 hours face-to-face instruction; an online study is not allowed. Advanced dry needling (i.e., craniofacial, spine, abdominal, etc..,) will require more advanced training than the minimum requirements. It is the responsibility of each occupational therapist to acquire specialty certification through additional training beyond the minimum requirements.
(ii) Each course shall specify which anatomical regions/structures are included in the certification and whether the instruction was introductory or advanced concepts in dry needling
(iii) Every course instructor must be a licensed healthcare provider and have a minimum of two years of experience performing dry needling
(iv) A practical examination and a written examination with a passing score
(v) Anatomicalreviewforsafetyandeffectiveness
(vi) Indications and contraindications for dry needling
(vii) Management of adverse effects
(vii) Evidence-based instructions on the theory of dry needling
(ix) Sterile needle procedures which shall include the standards of the U.S. centers for disease control or the U.S. occupational safety and health administration
Missouri

Missouri does not have any regulations regarding dry needling.

Montana
March 22′
Under Montana laws, dry needling is not included under the scope of practice of occupational therapists or assistants. AOTA is a professional association and not a state licensing body so its guidance and opinions do not necessarily match individual state regulations and scopes of practice for licensees. The Montana board has been discussing dry needling as a general topic with regard to where other states are going, but only the Legislature would have the authority to add it to the scope of licensure in Montana.
If you have questions on whether dry needling falls under the scope of an OT in other states I would recommend you contact those state licensing boards as well. If you are interested in being added to this board’s interested parties list to received notices of meeting agendas and proposed rulemaking let us know and we can add your e-mail.
Lucy Richards
Executive Officer
Board of Barbers and Cosmetologists | Board of Behavioral Health|
Board of Occupational Therapy Practice |
Board of Speech-Language Pathologists & Audiologists |
Montana Department of Labor & Industry
Business Standards Division
PHONE (406) 841-2394
Nebraska
March 22′
Thank you for your inquiry.  In 2016, the CEO of the Department of Health and Human Services requested an opinion from the Attorney General’s office regarding Dry Needling and the ability for Physical Therapists, Occupational Therapists, and Athletic Trainers to perform such a service.  That opinion can be found at https://ago.nebraska.gov/sites/ago.nebraska.gov/files/docs/opinions/AG%20Opinion%2016-009.pdf   At that time, it was the opinion of the Attorney General’s office that dry needling was not within the scope of practice, as defined in statute, of an occupational therapist.  There have been no statutory amendments to the scope of practice since 2016.
Regulations, in order to be promulgated, must be based on statutory authority.   As such, there are no regulations pertaining to dry needling at this time.  Should there be a change in statute, the regulations would need to be updated to reflect such changes.
Let me know if you have any questions.
Claire
Claire Covert-ByBee | DHHS Program Manager II   
PUBLIC HEALTH   
Nebraska Department of Health and Human Services   
OFFICE: 402-471-0547  |  FAX: 402-742-1152   
Nevada
1/26/2022:
Pursuant to state law, as stated in the Advisory Notice, Dry Needling is not within the scope of practice of OT’s in the State of Nevada.
The Board of Occupational Therapy will not be seeking legislation in the near future to authorize Dry Needling within the Scope of Practice for OT’s in Nevada.
If you have any further questions, please feel free to contact me.
Stay Safe, Stay Healthy!
Loretta L. Ponton, Executive Director
State of Nevada
Board of Occupational Therapy
6170 Mae Anne Ave., Suite 1
Reno, Nevada  89523
775-746-4101 P / 775-746-4105 Fax
New Hampshire
March 22′
Licensees should only perform services if the licensee has had training and has demonstrated competency with the skill and is in compliance with the professions scope of practice, rules, and code of ethics here:
Licensees should only perform services if the licensee has had training and has demonstrated competency with the skill and is in compliance with the professions scope of practice, rules, and code of ethics.  
Jessica M. Whelehan | Board Administrator
NH Office of Professional Licensure and Certification
7 Eagle Square, Concord, New Hampshire 03301
New Jersey
March 22′
The board does not have any guidance on the use of dry needling by Occupational Therapists. This is not covered under the modalities scope of practice.
New Mexico
March 22′
We fall in this description: Several state statutes are silent on this particular technique, as they are on multiple techniques used by OT’s (e.g. myofascial release, craniosacral therapy, blood flow restriction, etc), neither specifically allowing or disallowing them.
The primary modality of occupational therapy is occupation as means and ends. This would be an adjunctive preparatory modality, with the session expected to move into purposeful or occupation based activity.
Sincerely,
Carla Wilhite, Board Chair
Carla Wilhite
Board Chair of the NM Board of Examiners for Occupational Therapy
I understand you have done some research from other states and provided this information to the board and have been provided your data. However they have concluded that it is not a current scope of practice for Occupational Therapy. The board meets quarterly and is holding a virtual board meeting tomorrow morning at 9:00 am. You are welcome to join as an attendee and when the option is open for comment you may ask your questions.
6/22/22: The board did meet however, this item was not discussed or placed on the agenda for discussion. The board has the right to decide what they choose to review and discuss at their meeting and this was not a present issue for discussion. 
You may submit a request to the board via email to determine if this is an opted topic for the board to visit in their next meeting in September on the 15th at 9:00 am.
Thank you for your inquiry,
Bertha Valerio, Board Administrator  
Boards and Commissions Division 
2550 Cerrillos Road | Santa Fe, NM 87505 
Main Office (505) 476-4622
New York

Good morning,
OTs and OTAs may not perform dry needling in NYS
Thank you,
State Board for Occupational Therapy
New York State Education Department
89 Washington Avenue
Second Floor, West Wing
Albany, New York 12234
518-474-3817 ext. 100
518-473-0532 (fax)
www.op.nysed.gov/prof/ot

North Carolina
March 22′
Thank you for your inquiry regarding dry needling.  At its July 22, 2019 Board meeting, the Board agreed that dry needling is not within the scope of practice of occupational therapy, at this time.  The Board also discussed this topic at their meeting on May 18, 2020 and agreed to request guidance from AOTA on this issue.  
The Board has been made aware that the AOTA Representative Assembly (RA) has created a task force of 4-5 members to investigate the use of dry needling as a method used by OT practitioners that prepares a client for occupational performance, composed of at least one member from the Commission on Practice, one member from AOTA policy, and one OT practitioner with exposure to, and preferably training in, the use dry of needling.  Further, the task force shall be instructed to provide a report to the RA at some point in the future.  The report shall address the following:
* A summary of recent evidence since the COP 2017 practice response
* A recommendation as to whether to recognize dry needling as a preparatory method that falls within the scope of OT practice after receiving the necessary specialized training
* Where and how to provide an official statement on the use of dry needling in OT practice
* The implications of the use of dry needling in OT practice
The NCBOT is tabling this issue until more information is provided by AOTA.  If you have any further questions, feel free to contact me.
Elizabeth Kirk
Administrative Director
NC Board of Occupational Therapy
North Dakota
March 22′
The Board has the following stance on dry needling:
 Physical Agent Modalities (Dry Needling)
The Board does not regulate or require certification for OT’s performing specific modalities, including dry needling. It is the responsibility of the OT to be proficient in the specific modality he/she is practicing. Should a complaint or lawsuit arise involving an OT’s application of a specific modality, the OT would be responsible for proving his/her proficiency and appropriateness of application of the modality.
 This information can also be found at the Board’s website, https://www.ndotboard.com/practice.asp. Any updates can be found on that page.
 Thank you for your information on the other state’s requirements for PAMs and dry needling. AOTA is also looking at dry needling and may have changes to the requirements or a guidance later this year.
 Jacinda Simmons
Administrator
NDBOTP Office
Ohio
March 22′
Thank you for your question. In accordance with section 4755.04 (A)(3) of the Ohio Revised Code, it is the position of the Occupational Therapy Section that occupational therapy practitioners may use physical agent modalities, including dry needling, in the provision of occupational therapy services provided that the occupational therapy practitioner demonstrates and documents competency in the modality, in accordance with rule 4755-7-08 of the Administrative Code, and is practicing within the occupational therapy scope of practice. If the modality will be administered by an occupational therapy assistant both the supervising occupational therapist and occupational therapy assistant must document and demonstrate competency in the techniques or modality.
 Thank you,
 Ohio Occupational Therapy, Physical Therapy, & Athletic Trainers Board
77 S. High Street, 16th Floor
Columbus, OH 43215-6108
(P) 614-466-3774  (F) 614-995-0816
Oklahoma

March 22′

Unknown at this time.

Oregon
March 22′
 Here is where things stand currently with Dry Needling in Oregon:  
The OT board discussed dry needling in 2016.  And at that time AOTA did not take a position, so did not want to take a position in Oregon until AOTA did.  The board has not reviewed since.  
Currently acupuncturists are the only profession that can legally practice dry needling in Oregon. The PTs and Chiropractors have challenged the rule.
The Oregon Medical Board and its Acupuncture Advisory Committee regulates the practice of acupuncture in Oregon.  They have concluded that “dry needling” is acupuncture and can only be performed by a licensed acupuncturist.   Their rules state that no person may practice acupuncture without a license.
847-070-0007 Practice of Acupuncture
(1) No person may practice acupuncture without first obtaining a license to practice medicine and surgery or a license to practice acupuncture from the Oregon Medical Board.
Other professions have challenged the rule but have not been successful:
In 2017 the PT board asked received a (very costly) opinion by the Dept. of Justice General Counsel Division.  The opinion was No, it is not within the scope of a PT.
In 2011, the board of Chiropractic examiners adopted a rule authorizing chiropractors to practice dry needing however the Oregon Court of Appeals held that dry needling is not within the chiropractic scope of practice.
Regards, Nancy
Pennsylvania
March 22′
 Please note that neither the Board or Board Counsel is permitted to provide legal advice to anyone but the Board (which includes answering specific questions), and neither the Board nor Board Counsel may provide advisory opinions, including interpretations of the law or the Board’s regulations.  Therefore, you may wish to consult with a private attorney for legal advice.  
 The Occupational Therapy Practice Act and the Board’s regulations, which adopt the 2015 American Occupational Therapy Association (AOTA)’s Code of Ethics, may be found at https://www.dos.pa.gov/ProfessionalLicensing/BoardsCommissions/OccupationalTherapy/Pages/Board-Laws-and-Regulations.aspx. 
  The Board does not currently have regulations on dry needling.
 
Rhode Island
March 22′
We do not have any record of the Board issuing guidance on the use of dry needling.
 
South Carolina
March 22′
Waiting for a response
South Dakota
March 22′
 At this time we have not issued any guidance on the use of dry needling by occupational therapists in South Dakota as OTs are not allowed to use dry needling within our state.  I thank you for the research and the follow-up of what each state is doing.  It is greatly appreciated. 
 Best,
 Brooke Blaalid, MSW, MA
Management Analyst
SD Board of Medical & Osteopathic Examiners
101 N. Main Avenue, Suite 301
Sioux Falls, SD 57104
Tennessee
November 22′ Below rules will become effective in 90 days once they are filed with sec. of state.

RULE 1150-02-.21  DRY NEEDLING TO THE UPPER LIMB

  • In order to perform dry needling, an occupational therapist must obtain all of the educational instruction described in paragraphs (2)(a) and (2)(b) herein. All such educational instruction must be obtained in person and may not be obtained online or through video
  • Mandatory Training – Before performing dry needling, a practitioner must complete educational requirements in each of the following areas:
  • Fifty (50) hours of instruction, to include instruction in each of the four (4) areas listed herein, which are generally satisfied during the normal course of study in occupational therapy school:
  1. Musculoskeletal and Neuromuscular systems;
  2. Anatomical basis of pain mechanisms, chronic pain, and referred pain;
  3. Trigger Points;
  4. Universal Precautions; and
  • Twenty-four (24) hours of dry needling that includes specific instruction to the upper limb defined as hand, wrist, elbow and shoulder girdle.
  1. The twenty-four (24) hours must include instruction in each of the following six (6) areas:
  • Dry needling technique;
  • Dry needling indications and contraindications
  • Documentation of dry needling;
  • Management of adverse effects;
  • Practical psychomotor competency; and
  • Occupational Safety and Health Administration’s Bloodborne Pathogens Protocol.
  1. Each instructional course shall specify what anatomical regions are included in the instruction and describe whether the course offers introductory or advanced instruction in dry
  2. Each course must be pre-approved or approved by the Board or its consultant, or the Board may delegate the approval process to recognized health-related organizations or accredited occupational therapy educational

(3)    A newly-licensed occupation therapist shall not practice dry needling for at least one (1) year from the date of initial licensure, unless the practitioner can demonstrate compliance with paragraph (2) through his or her pre-licensure educational coursework.

  • Any occupational therapist who obtained the requisite twenty-four (24) hours of instruction as described in paragraph (2)(b) in another state or country must provide the same documentation to the Board, as described in paragraph (2)(b), that is required of a course provider. The Board or its consultant must approve the practitioner’s dry needling coursework before the therapist can practice dry needling in this
  • Dry needling may only be performed by a licensed occupational therapist and may not be delegated to an occupational therapy assistant or support
  • An occupational therapist practicing dry needling must supply written documentation, upon request by the Board, that substantiates appropriate training as required by this
  • All occupational therapy patients receiving dry needling to the upper limb shall be provided with information from the patient’s occupational therapist that includes a definition and description of the practice of dry needling and a description of the risks, benefits, and potential side effects of dry needling.
Texas
March 22′
Board doesn’t dictate specific competency requirements. It is the responsibility of the OT to demonstrate competency
Utah
March 22′
Per Utah Code (law) only Medical Doctors, Osteopathic Doctors, Naturopathic Doctors, Physical Therapists, Acupuncture, and Chiropractors are allowed to dry needle.
Thanks,
Jeff
DOPL 7
Website: www.dopl.utah.gov | Email: b7@utah.gov 
Division of Occupational & Professional Licensing
Phone: 801-530-6755 or 801-530-6628 
P.O. Box 146741 Salt Lake City, UT 84114
Vermont
March 22′
The Vermont Advisor Board has not rendered an opinion. 
Thank you
 Judith Roy
Office of Professional Regulation
 Licensing Board Specialist for:
Athletic Trainers
Auctioneers
Occupational Therapists
Physical Therapists
Property Inspectors
Radiologic Technology Board
Real Estate Appraiser Board
Real Estate Commission
 Address: 89 Main Street, 3rd Floor
                 Montpelier, VT 05620-3402
Phone:    802-828-3228
Fax:         802-828-2465
 
 
Virgina
March 22′
It (DN) has not; it may be addressed at the next OT advisory board meeting which is May 24th.
Jennie F. Wood
Case Manager, Discipline &  Compliance
804-367-4571
Virginia Board of Medicine
9960 Mayland Drive, Suite 300 Henrico, Virginia 23233
6/21/22: Ms. Barnes,
Your correspondence to Jennie Wood, Compliance Manager at the Virginia Board of Medicine was forwarded to me. In response to your inquiry, please be advised that dry needling was not an agenda item for discussion at the May 24th Occupational Therapy Advisory Board meeting. You may review the agenda and the minutes of that meeting on the Board’s website at https://www.dhp.virginia.gov/Boards/Medicine/AbouttheBoard/MeetingCalendar/ 
Also, as previously advised by Ms. Wood, attached is a link to the minutes of the June 7, 2016 meeting when the topic of dry needling was last discussed by the occupational therapy advisory board – 
I hope the above is helpful to you.
Thanks,
Michael O. Sobowale, LL.M.
Deputy Executive Director, Licensure
Virginia Board of Medicine
9960 Mayland Drive, Suite 300
Henrico, Virginia 23233
Office: (804) 367-4472
Facsimile: (804) 527-4426
Washington State
March 22′
I am the program manager for the OT program. There has not been a statutory change on dry needling for OTs. If there is guidance, it would be from years ago as I have been with the program for 8 years. I am currently unable to access any old files so I can’t look for older guidance.
This was a contentious issue when it was brought before the physical therapy board. I imagine it will be a big issue for OTs in the near future.
Kathy
KATHY WEED
Program Manager
Health Systems Quality Assurance
Washington State Department of Health
360-236-4883 | www.doh.wa.gov
Gender Pronouns: she/her
Wisconsin
March 22′
The Wisconsin Board has not promulgated rules on dry needling nor has it issued any guidance on dry needling.
 Please let me know if I can be of further assistance.
 Tom Ryan
DSPS
 
West Virginia
March 22′
Thank you for contacting the WV Board of Occupational Therapy.  The Board continues to support the current published position statement of AOTA, that dry needling is not within the scope of practice for occupational therapists.
Sincerely,
Vonda K. Malnikoff
Executive Secretary, WVBOT
1063 Maple Dr., Suite 4B
Morgantown, WV  26505
304-285-3150
Wyoming
March 22′
After reviewing our statutes, the Board has determined that the Board of Occupational Therapy’s Practice Act/Statute DOES support that Wyoming licensed Occupational Therapists who are properly trained are able to use dry needling techniques in their practice.
The Wyoming Board of Occupational Therapy recommends the use of the following guidelines when engaging in dry needling and intends to add these recommendations, or similar requirements to the Board’s rules and regulations in the near future.
  • Licensees will need to have evidence of competence before they can begin using dry needling techniques in their practice.
  • Licensed occupational therapists shall be able to demonstrate upon the Board’s request that they have received training in dry needling that meet the Board’s requirements.
  • Training shall include, but not be limited, to training in indications, contraindications, potential risks, proper hygiene, proper use and disposal of needles, and appropriate selection of clients.
  • Training shall include a minimum of twenty-seven (27) hours of live face-to-face instruction. Online courses are not appropriate training in dry needling.
  • Dry needling may not be performed by an occupational therapy assistant or any other supportive personnel.
  • The occupational therapist shall supply written documentation, upon request by the Board, that substantiates appropriate training as required by this rule. Failure to provide written documentation may result in disciplinary action taken by the Board. WY Link

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