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This paper was submitted in the
Doctor of Acupuncture & Chinese Medicine program at
Pacific College of Health & Science on March 3, 2021.

Please cite my paper if you use any part of what I have written,
in any type of communication or publication.

This is not the original format, as I simply copied/paste onto my website.

Dr. Anna Dolopo
Doctor of Acupuncture & Chinese Medicine
Board Certified
Licensed Acupuncturist
posted online February 6, 2024


Dry Needling vs. Acupuncture in California

Anna Katherine Navida Dolopo

Pacific College of Health Sciences

Health Care Systems

Dr. Juli Olson

March 3, 2021


Legislation in California In California, dry needling (DN) is not legal for physical therapists

(PTs) to perform. The American Association of Chinese Medicine & Acupuncture (AACMA)

and California State Oriental Medicine Association (CSOMA) formally opposes DN performed

by PTs and provides 5 specific reasons to validate their claim.

Practice, Patient Care, Reiumbursement In California, since PTs are not legally allowed to

practice DN, licensed acupuncturists’ (LAcs) practices are not affected. Patients do not have to

choose between seeing an LAc for acupuncture and a PT for DN when it comes to treatment for

pain. LAcs who are either out of pocket or take insurance are not affected by reimbursement.

LAcs in California are not in competition with PTs who do DN and it will remain this way as

long as legislation regarding PTs and DN stays the way it is now.

Pros and Cons

In regard to legislature in California, the pro for LAcs is that we are not affected

by this topic as long as the policies do not change. The con for LAcs is that DN is legal in 36

states. It may just be a matter time for this to change and if it does, then LAcs are going to have

to compete with PTs when it comes to patients choosing between acupuncture from an LAc and

DN from a PT. Out of pocket or insurance reimbursement for LAcs may be affected if more

patients choose to receive therapy for pain issues from PTs who practice DN over acupuncture

from LAcs.

Educating Healthcare Administrators and Legislators

It is critical for LAcs to continue educating healthcare administrators and legislators with the outline provided by AACMA and CSOMA that details why PTs are violating California law if they were to be allowed to practice DN.


LAcs’ action plan should include continually educating Chinese medical students of

this hot topic, keeping professional organizations and their members informed about PTs and

their desire to change California legislature in their favor regarding DN, and keeping the

California Acupuncture Board in line with the opposition of PTs performing DN, which

AACMA and CSOMA details their reasons in length.

Legislation in California

The topic of physical therapists (PTs) being able to perform dry needling (DN) is very

controversial primarily because most licensed acupuncturists (LAcs) are adamant that dry

needling is considered to actually be acupuncture therapy.

Physical therapists who use dry needling are sidestepping laws and bypassing rules and

regulations created for consumer protection,” said Neal Miller, an acupuncturist from Los

Angeles with almost 30 years of experience, who’s served on the board of the California

Society of Oriental Medicine (CSOM) and the Acupuncture Integrated Medical Society

(AIMS). (Reno, 2016)

PTs do not believe that DN is related to acupuncture at all. PTs believe that DN “is part of

Western medicine and has nothing to do with acupuncture’s traditional Chinese medical tradition

that…alters the body’s energy into healthier patterns.” (Reno, 2016) DN is legal in 36 states and

D.C., but it is illegal in California, Oregon, Washington, New York, Hawaii, and New Jersey.

There are 8 states that are quiet about DN.

This paper will focus on legislation in California that has a strong stance in its position.

The AACMA and CSOMA formally oppose the practice of “dry needling” by

physical therapists in the state of California due to the following public safety and

regulatory reasons:

1. “Dry needling,” as defined by the American Physical Therapy Association

(APTA), follows the same definition as “acupuncture” in the state of California.

2. Current practice in states that allow “dry needling” by physical therapists do not

meet the standards adopted by the AMA (American Medical Association) on Regulating

Dry Needling.

3. Current practice in states that allow “dry needling” by physical therapists violate

the FDA’s (Food and Drug Administration) statement regarding the sale of acupuncture


4. The State of California maintains that it is unlawful for any person other than a

licensed acupuncturist, physician, surgeon, dentist, or podiatrist to practice acupuncture

or use any acupuncture technique that involves the application of a needle to the human


5. “Dry needling” as it is currently practiced by physical therapists in other states,

poses a hazard to public safety due to inherent risks of under-trained and unregulated

practitioners. (, 2021)

Unlike my contemporaries in the 36 states that allow DN by PTs, I do not have to think

of any PTs encroaching upon my profession if they offered DN next door to my office. AACMA

and CSOMA have detailed that acupuncture and DN have the same definition in the state of

California. From the perspective of the American Physical Therapy Association (APTA), they do

not agree with this statement. PTs and their patients are educated to understand that:

Dry needling is a technique physical therapists use…for the treatment of pain and

movement impairments. The technique uses a "dry" needle, one without medication or

injection, inserted through the skin into areas of the muscle…Dry needling is not

acupuncture, a practice based on traditional Chinese medicine and performed by

acupuncturists. Dry needling is a part of modern Western medicine principles and

supported by research. (“Dry Needling,” 2021)

The policy makers in California favor LAcs regarding DN in California. It is interesting

that LAcs consider DN as acupuncture, but PTs are adamant that DN is not acupuncture.

Effect on Practice, Patient Care and Reimbursement in California

As long as DN is not able to be performed by PTs in California, LAcs are not affected by

this topic. Our practices are not threatened by PTs who do DN. Patients do not have to choose

between acupuncture performed by LAcs or DN performed by PTs when it comes to treatment

for pain. For LAcs who accept insurance, since DN is not allowable by PTs, then reimbursement

is not an issue. If DN does somehow become legal for PTs to practice in California, then LAcs

will have to explain how acupuncture is beneficial for patients compared to DN. The consistent

message of PTs to anyone interested in DN is that acupuncture is based on pre-science theory

and DN is based on western medicine.

There are similarities but very significant differences between TCM style of acupuncture

and dry needling. Acupuncture follows rules and beliefs which have been established

since ancient times whereas; dry needling ignores ancient acupuncture philosophy. Most

if not all of TCM is based on pre-scientific ideas whereas, dry needling is totally based on

modern scientific, neurophysiology and anatomy. Dry needling is purely for pain relief

and is based on recent understanding in pain science, there is much less mystique

surrounding dry needling concerning pain abatement by the scientific community. (AZ

Multicare, 2021)

PTs who practice DN are well-trained to explain this technique in biomedical

terminology. Most LAcs do not have the explanation of what acupuncture does in biomedical

terms at the tip of our tongues. Patients who may not be interested in mystical medicine may

choose the PT DN route since that is the rhetoric that keeps being shared on their websites. From

the perspective of a patient suffering from pain, if all they keep reading on PTs’ websites is that

DN is only for pain and it’s based on western medicine and PTs keep reiterating that acupuncture

is based on ancient, pre-science medicine, then it may be safe to assume that some patients may

favor a medical modality that is research-proven to only treat pain and is not full of ancient,

mystic medicine.

Pros and Cons of PTs being allowed to practice DN in California

Pros: Dry needling is a relatively non-invasive procedure...The treatment is very low

risk… and most discomfort will be fleeting. “It also doesn’t require much time, so

patients can find relief quickly.”

Cons: For some individuals, the treatment itself can be painful, and the efficacy of dry

needling is still a question mark, according to an article published in the Journal of the

American Board of Family Medicine. While some studies on the technique have shown

promise, others suggest dry needling won’t offer much more than a placebo effect. The

other drawback is that costs for the multiple treatments can add up. (Loudin, 2014)

With regards to how legislation of DN affects LAcs, the pro definitely means that we do

not have to deal with PTs practicing next door and competing what they consider to be “western

acupuncture” and “can trace its origins back 2,000 years to China and somewhat corresponds

with traditional Chinese acupuncture points.” The cons for LAcs is that DN is legal in 36 states.

The trend is growing in the country and there are only 6 states that DN is illegal, California being

one of them. This legislation can only hold for as long as LAcs are united in policy making and

can stand strong against the lobbyists for the APTA.

Educating Other Healthcare Administrators and/or Legislatures

Having AACMA and CSOMA’s 5 explanations why DN is indeed acupuncture would be

the best way to educate healthcare administrators and legislatures. Educating that the definition

of DN is the same as acupuncture in the state of California would be the number one tool to get

administrators and policy makers to understand where LAcs are coming from; that DN by PT

does not meet American Medical Association’s standards; that PTs violate the Food and Drug

Administration’s statement regarding the sale of acupuncture needles; that in California only

licensed acupuncturists, physicians, surgeons, dentists and podiatrists are the only professionals

legally allowed to apply a needle to the human body; and that when PTs practice DN in other

states, they pose a hazard to public safety as they are under-trained and unregulated. This

education would be presented publicly to the Capitol as necessary, online on government and

state association websites and this message would be reiterated to the APTA.



As an LAc, I was not made aware of this issue until I started this doctorate program. On a

community level, it would be imperative to make sure all California Chinese medical schools

keep their students informed of this topic, keep this information circulating in the acupuncture

professional organizations, and keeping the Acupuncture Board in line with recognizing the

outlined oppositions of AACMA and CSOMA towards DN practiced by PTs.



AZ Multicare. (2018). Dry Needling. Retrieved February 25, 2021 from

California State Oriental Medical Association. (2018, September 12). Acupuncture Profession

Joint-Position Statement on Dry Needling in California.


Dry Needling by a Physical Therapist: What You Should Know. (2021). Choose PT. Retrieved

February 25, 2021 from



Loudin, A., (2014, December 1). Injured Again? The Scoop on Dry Needling and Graston

Technique. Daily Burn.





Reno, J. (2016, September 20). Acupuncturists and Physical Therapists Declare War Cry Over

‘Dry Needling.’ Healthline.




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