National Center for Acupuncture Safety and Integrity (NCASI).  This letter alleged that physical therapists’ (PT) use of acupuncture needles in “trigger point dry needling” (TPDN) procedures, and various state boards’ determination that TPDN is within the physical therapist scope of practice, are inconsistent with the requirements for acupuncture needles under the Federal Food, Drug, and Cosmetic Act (FDC Act), 21 U.S.C. § 301 et seq. and U.S. Food and Drug Administration (FDA) implementing regulations.  It was determined that the FDA regulations at 21 C.F.R. §§ 880.5580 and 801.109 make clear that the determination of who is authorized to use acupuncture needles is a matter left to the states.

Read the full letter – APTA Response to NCASI letter on FDA and Dry Needling 2014