It is quite common for clinicians and administrators to approach Myopain Seminars by asking questions about dry needling by physical therapy assistants. For example, last week, we received the following email:
“We recently received an email advertising a continuing education course for dry needling for PTs, PTAs, OTs and OTAs. I know state practice acts determine who can actually needle in their state, but I was wondering if you’ve noticed a growing trend in PTA’s dry needling. I see Illinois and some others interpret the act as a PTA can needle “if they are properly trained.” I was curious as to Myopain’s stance on this and if Myopain is considering training PTAs to do this.”
As mentioned in the email, whether PTAs and OTAs are legally allowed to use dry needling depends entirely on the laws and regulations in each state. While a few states allow PTAs to use dry needling, in most states, dry needling is not within the scope of PTAs. Let’s have a look at a few state regulations:
On August 2, 2024, the Alabama Board of Physical Therapy issued a letter regarding whether it is appropriate for a PTA to perform dry needling. In the letter, the Board highlighted that the Alabama Administrative Code does not elaborate on which treatment techniques are or are not within the individual PTA’s skill set. According to the Board,
“The Administrative Code allows for the fact that different clinicians have varying levels of training and skill above entry-level. To that end, the Administrative Code places responsibility on the directing physical therapist (PT) to determine what treatment is appropriate to delegate to a PTA. However, a PTA is also responsible for refusing to carry out treatment they believe is not in the patient’s best interests.”
To summarize, determining what treatment is appropriate to delegate to a PTA is the responsibility of the directing PT. Employers do not have the authority or responsibility to make that determination. Furthermore, the liability rests with licensees: the PTA and the directing PT. If any adverse event or mismanagement occurs leading to legal proceedings, the PTA and the directing PT are both accountable for what has been delegated to the PTA, and professionals are typically judged based on the acceptable standards of practice or care. It is not the role of the licensing board to establish best practices. There are many resources that provide guidance in this area, including the American Physical Therapy Association.”
The American Physical Therapy Association has published two educational resource guides on dry needling (Physical Therapists & Dry Needling; a Compendium for State Policy Makers (2011); Physical Therapists and the Performance of Dry Needling (2012)); unfortunately, neither guide includes any information about dry needling by physical therapy assistants. However, in 2018, the APTA amended one of its APTA House policies to confirm that dry needling is an intervention that should not be delegated by a physical therapist to a physical therapist assistant (see below).
In Illinois, “dry needling shall only be performed by a licensed physical therapist or licensed physical therapist assistant,” according to Section 1.5. Dry Needling of the PROFESSIONS, OCCUPATIONS, AND BUSINESS OPERATIONS, (225 ILCS 90/) Illinois Physical Therapy Act. Even though PTAs are technically allowed to use dry needling, they must meet all the same prerequisite requirements as PTs. In other words, before a PTA in Illinois can even start their dry needling education, they would have to take additional college credit hour programs. Since the prerequisite education is college credit hours, PTAs cannot just take some continuing education courses to meet the requirement. Most PTAs will not be able to meet the strict prerequisite requirements and, therefore, will not be able to use dry needling in Illinois. It is conceivable that some PTAs may have other degrees that could meet the prerequisites, but even in that case, direct supervision of a PTA performing dry needling will be required by a supervising PT who must have also completed the DN education.
According to the Kentucky Board of Physical Therapy,
“pursuant to 201 KAR 22:053 Section 3, a PTA can provide physical therapy services under the supervision and direction of a physical therapist who has the requisite education, training, and experience relating to those services.
That stated, the Kentucky Board of Physical Therapy recognizes that both the American Physical Therapy Association and Federation of State Boards of Physical Therapy have cautioned physical therapist assistants from engaging in dry needling, as they are not trained in the same competencies that qualify physical therapists to perform these services. Prior to performing dry needling services, the Board recommends that the physical therapist assistant seek guidance on this issue by reviewing the Analysis of Competencies for Dry Needling by Physical Therapists Final Report located at: http://www.apta.org/StateIssues/DryNeedling/.”
Interestingly, the Analysis of Competencies for Dry Needling by Physical Therapists Final Report, published in 2015 by the Federation of State Boards of Physical Therapy, does not appear to support dry needling by PTAs.
Because this report focused on the competencies required of the PT to perform dry needling, which are based on a strong foundation in evaluation and differential diagnosis, it is not appropriate to assume the same competencies would qualify a PTA to perform the treatment.
At Myopain Seminars, we are not sure what a PT or PTA in Kentucky would gain from reviewing the Analysis, as the only guidance the report provides is that it would be inappropriate to assume that a PTA would be qualified to use dry needling.
Although the position of the Kentucky Board of Physical Therapy suggests that the American Physical Therapy Association (APTA) and Federation of State Boards of Physical Therapy “have cautioned physical therapist assistants from engaging in dry needling,” the APTA maintains that dry needling is a selected intervention performed exclusively by physical therapists and not by physical therapy assistants.
According to Title 10, DEPARTMENT OF HEALTH AND MENTAL HYGIENE, Subtitle 38 BOARD OF PHYSICAL THERAPY EXAMINERS, 10.38.12 Dry Needling, “dry needling is not within the scope of practice of limited physical therapy and shall only be performed by a licensed physical therapist.” In Maryland, the scope of practice of PTAs is referred to as “the scope of practice of limited physical therapy.”
The Texas Board of Occupational Therapy Examiners and the Texas Board of Physical Therapy Examiners do not dictate the specific modalities, techniques, or procedures that may be incorporated into the occupational and physical therapy plan of care. However, practitioners (OTs/OTAs, PTs/PTAs licensed by the boards) must have demonstrable competence based on education and training, skill, and experience to perform any intervention. It would be a violation of the Act and Rules for an OT/OTA and PT/PTA to perform techniques or procedures for which they are not competent.
According to the Statutory Authority § 54.1-2400 of the Code of Virginia. 18VAC112-20-121. Practice of dry needling, “dry needling shall only be performed by a physical therapist trained pursuant to subsection A of this section and shall not be delegated to a physical therapist assistant or other support personnel.”
In 2018, the APTA House of Delegates amended the APTA House policy titled “INTERVENTIONS PERFORMED EXCLUSIVELY BY PHYSICAL THERAPISTS HOD P06‐18‐31‐36 to confirm that dry needling is an intervention that should not be delegated by a physical therapist to a physical therapist assistant. According to the APTA, selected interventions are performed exclusively by the physical therapist. Such interventions include but are not limited to, spinal and peripheral joint mobilization/manipulation and dry needling, which are components of manual therapy, and sharp selective debridement, a component of wound management.
Back to the initial email inquiry, the sender wondered if we “had noticed a growing trend in PTAs using dry needling and whether Myopain Seminars is considering training PTAs to do this.” Although we receive some inquiries from PTs and PTAs about dry needling by PTAs, it does not appear that there is a surge in the number of PTAs who treat their patients with dry needling. Currently, Myopain Seminars does not allow PTAs to attend our dry needling courses, which aligns with the national American Physical Therapy Association’s point of view. We are not convinced that a physical therapy assistant associate degree program prepares students sufficiently to use dry needling. For physical therapists, the HUMBRO study established that 86% of the required competencies to practice dry needling safely are covered by the doctoral education of physical therapists, but there is no similar analysis for the PTA associates degree.
Physical therapy assistants may consider attending the Myopain Seminars Manual Trigger Point courses instead, which share much of the theoretical background of our dry needling courses. Physical therapists and PTAs offering dry needling and manual trigger point therapy are complementary and improve the quality of patient care and a clinic’s bottom line.
Jan Dommerholt, PT, DPT | President/CEO, Myopain Seminars
