What’s Next for Oregon? Legislative News – Sept 2025

Introduction

When Oregon Governor Tina Kotek signed House Bill 3824 into law on August 7, 2025, she directed the Oregon Board of Physical Therapy to actively consult with the Oregon Medical Board when adopting rules to ensure that the practice of dry needling has limited application to the practice of musculoskeletal pain and movement resolution and that an appropriate training standard is adopted. The Oregon licensing board director has suggested that the rulemaking process to finalize requirements and implement all the parts of the bill may not be completed until July 2027.

In her letter, the Governor outlined that the Bill “permits physical therapists to perform dry needling as described by the Board by administrative rule, including the establishment of training requirements to ensure a physical therapist can competently perform dry needling.” The governor mentioned that “standards and definitions of dry needling vary across the country.”

The acupuncture lobby argued that “dry needling will undermine the acupuncture profession,” and they even suggested that adopting dry needling by physical therapists would be an example of cultural appropriation and “erroneous and offensive to the origins of acupuncture.”

As we mentioned in a previous blog, when the acupuncture lobby cited “Brady S, et al. Adverse events following trigger point dry needling: a prospective survey of 20,000 treatments. PM&R. 2014;6(9):847–852,” it was evident that they had used AI to develop their arguments. The cited reference does not exist: Page 847 of issue 9 in volume 6 (2014) of the PM&R journal is in the middle of an article entitled “Neuromuscular Ultrasound Application to the Electrodiagnostic Evaluation of Quadrilateral Space Syndrome,” written by Chen, Onishi, Zhao, and Chang (PM&R. 2014;6(9):845-848).

In this essay, we will review the various standards and definitions of dry needling across the country to assist the Oregon Board of Physical Therapy in its efforts to adopt rules for dry needling. Of course, although these are completely unsolicited recommendations, we do have over 20 years of experience dealing with legislative dry needling regulations throughout the country.

First, let’s break down one of the arguments.

The fear that “dry needling will undermine the acupuncture profession” is not based on factual analysis or precedent anywhere in the world. For example,

1. When the State of Maryland approved dry needling by physical therapists in 1984, the Acupuncture Society supported the decision. With very few acupuncturists in Maryland, the Board of Acupuncture did not even exist in 1984. Maryland did have a small acupuncture school, known as the Traditional Acupuncture Institute. The school was founded in 1974 as the Centre for Traditional Acupuncture. In 1986, the school was approved to offer its first graduate degree, which was two years after dry needling was approved. The school changed its name a few more times to the Tai Sophia Institute in 2000, followed by the Maryland University of Integrative Health in 2013, not to be confused with the University of Maryland. In 2025, there are 1,320 licensed acupuncturists in the State of Maryland, compared to approximately 1,000 out of 7,700 physical therapists who are approved to use dry needling. Only 13% of all licensed physical therapists in Maryland use dry needling in their clinics. This suggests that allowing physical therapists to use dry needling in 1984 did not undermine the acupuncture profession.
2. When Myopain Seminars (operating as the Janet G. Travell Seminar Series) offered the first dry needling courses in Spain in 1996, acupuncture was a fringe profession in Spain. Today, according to Market Research Future, “the Spain acupuncture market is experiencing notable growth driven by an increasing acceptance of traditional medicine and alternative therapies among the Spanish population.”

It is even conceivable that the use of solid filament needles by non-acupuncture healthcare professions may further legitimize acupuncture itself. It could well be a win-win for all involved professions.

Our advice to the Oregon Board of Physical Therapy: clarify that dry needling by physical therapists does not constitute the practice of acupuncture. Dry needling by physical therapists is a form of instrument-assisted manual therapy, consistent with the 2023 APTA Guide to Physical Therapy Practice 4.0.^[1]

Standards and Definitions of Dry Needling

Terminology

Most states have adopted the term “dry needling,” however, some states, including Washington and North Carolina, refer to dry needling as “intramuscular stimulation.” However, dry needling applications involve much more than just needling intramuscularly. There is considerable evidence of the efficacy of scar tissue needling and fascial needling; limiting the scope of dry needling due to terminology would be self-restricting and not in the best interest of patients.

Some countries, such as Spain, refer to dry needling as “minimally invasive physiotherapy,” which is somewhat analogous to being “minimally pregnant.” Dry needling is a treatment procedure using a very thin needle, but it is invasive, nevertheless.

Our advice to the Oregon Board of Physical Therapy: Use the term “dry needling” and do not restrict the use of dry needling to muscles only.

Number of Hours

Dry needling is within the scope of physical therapy practice in most states; however, the requirements vary significantly. For example, Maryland requires completion of 40 hours of hands-on training and 40 hours of theory instruction. A physical therapist shall have practiced physical therapy for at least two years before performing dry needling in Maryland. Although the Maryland Board of Physical Therapy Examiners provides Continuing Education Units (CEUs) for online theoretical education, to qualify for being approved to use dry needling in the clinic, the Maryland Board demands that online education must be live. In Colorado, a physical therapist must have completed 46 hours of training. In Washington, dry needling training and education requirements include 150 hours of training and 150 supervised treatment sessions, which must be completed within 18 months of completing the didactic and in-person training.

In contrast, other states have no minimum criteria. The North Carolina Supreme Court ruled that dry needling is within the scope of physical therapy without requiring a minimum number of hours of dry needling education. North Carolina “strongly encourages” physical therapists to satisfy dry needling principles but has no specific requirements. The regulations signed into law in the Commonwealth of Virginia do not stipulate any minimum number of hours:

“The training shall be specific to dry needling and shall include emergency preparedness and response, contraindications and precautions, secondary effects or complications, palpation and needle techniques, and physiological responses. The training shall consist of didactic and hands-on laboratory education and shall include passage of a theoretical and practical examination. The hands-on laboratory education shall be face-to-face. The practitioner shall not perform dry needling beyond the scope of the highest level of the practitioner’s training.”

There is no obvious correlation between the number of required training hours and a state’s ability to protect the public. The number of significant adverse events does not appear to be higher in Virginia compared to any other state, although objective data is not available.

Our advice to the Oregon Board of Physical Therapy:

1. Do not stipulate any minimum number of hours, as any number is entirely random and arbitrary. Instead, follow the lead of the Virginia Board of Physical Therapy and require that physical therapists demonstrate competency like any other physical therapy modality or approach.
2. Allow physical therapists to use dry needling after having completed one course offered by an approved dry needling course provider. Dry needling should be limited to only the muscles that were covered during the course.
3. Do not require that online theoretical education must be live.

Waiting Period

Several states require that “a physical therapist shall have practiced physical therapy for at least 2 years before performing dry needling in the State” (Maryland). As we have mentioned previously, safe dry needling is guided by excellent anatomical knowledge. In our experience, new graduates possess a significantly better mastery of detailed anatomy than physical therapists who graduated 10-15 years ago. Boards that require an arbitrary waiting period appear to insist that physical therapists forget their detailed anatomy knowledge before being allowed to use an invasive procedure.

Our advice to the Oregon Board of Physical Therapy: Do not require an arbitrary waiting period before physical therapists can use dry needling in clinical practice.

Pre-Approval Process

Washington and Maryland require that physical therapists submit proof of their dry needling education to the Health Department (WA) or the Board of Physical Therapy Examiners (MD) for evaluation and approval. Once approved, they are allowed to use dry needling independently in their clinics. The majority of states do not have such an approval process, and there is no evidence that an approval process reduces the risk of serious adverse events. Knowing how many physical therapists use dry needling may be helpful.

Our advice to the Oregon Board of Physical Therapy: Do not require a pre-approval process, but consider setting up a registration process, perhaps as part of the license renewal application.

Course Provider Approval Process

In March 2025, we counted 58 different dry needling course providers in the United States. Some course providers began teaching dry needling courses after completing only one course themselves, which seems hardly a qualifying criterion. Other course providers are less than honest in their applications to become approved providers. For example, one course provider claimed that their graduate physical therapy school training included a complete course in dry needling. Upon verification, the instructor of the course that introduced dry needling to this course provider confirmed that students only needled the quadriceps muscle. The same course provider stated that, following graduation from PT school, they moved to another state (yes, that state was Oregon!), where they performed dry needling for several years, even though dry needling was not yet within the scope of their practice. Nevertheless, the course provider has been approved in several states throughout the country as a qualified instructor of dry needling courses.

Other dry needling courses include information directly copied from the practice of acupuncture, including point location and acupuncture nomenclature. Governor Kotek confirmed that dry needling performed by a physical therapist does not constitute acupuncture.

Our advice to the Oregon Board of Physical Therapy:

1. Develop rules that establish the minimum qualifications for course providers. Consider and verify which courses they have completed and their years of experience.
2. Be familiar with the requirements in other states. A course provider who admits to using dry needling in a state where it is not legally allowed should be disqualified.
3. Verify the accuracy of applications. Submitting false and inaccurate information should be a reason to be disqualified.
4. Review the course materials, including presentations, course manuals, and other relevant documents. If the dry needling course is (partially) based on acupuncture practice, the course should be disqualified.

Of course, we do not know whether the Oregon Board of Physical Therapy will consider our recommendations. There may be state requirements or other legislative issues that are unknown to us. To meet the Board’s requirement to protect the public in Oregon, the Board should approach the regulatory process carefully and avoid following the footsteps of other states that have resulted in overregulation. Rules should be written from the perspective of safe physical therapy practice in Oregon, without considering any potential opposition.

Jan Dommerholt, PT, DPT | President & CEO, Myopain Seminars

Reference

1.             American Physical Therapy Association, APTA Guide to Physical Therapist Practice 4.0. 2023, American Physical Therapy Association: Alexandria, VA.