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QUESTION: Are athletic trainers able to provide dry needling services?


ANSWER: According to the NATA, "Currently, there is no profession-wide standard that defines athletic trainer competence in dry needling. Prior to performing dry needling, athletic trainers must ensure their state practice act does not prohibit them from performing dry needling as part of the athletic training plan of care. Additionally, athletic trainers must satisfy any requisite educational and training necessary to provide dry needling. Athletic trainers may have to produce evidence of appropriate training and demonstrate knowledge and competency in dry needling."  With the recent passage of the practice act House Bill 4710, acupuncturist have been granted licensure in the state of Michigan. Public Act 140 of 2019 (PA 140) is effective as of March 4, 2020. An “Acupuncturist” means an individual who is licensed under this part to engage in the practice of acupuncture.”

PA 140 defines “dry needling” as “a rehabilitative procedure using filiform needles to penetrate the skin or underlying tissues by targeting only myofascial trigger points and muscular and connective tissues to affect change in body structures and functions for the evaluation and management of neuromusculoskeletal pain and movement impairment. Dry needling does not include the stimulation of auricular points or other acupuncture points.” That is, an individual may be required to become licensed as an acupuncturist prior to performing dry needling.


PA 140 also addresses exemptions from licensure as indicated in the following selected language:

(a) Except as otherwise provided in subdivision (e), an individual licensed, registered, or otherwise authorized under any other part or act who is performing activities that are considered to be within the practice of acupuncture if those activities are within the individual’s scope of practice and the individual does not use the words, titles, or letters protected under section 16511.

(b) A physician who is licensed under part 170 or part 175 if the physician has completed a total of not less than 300 hours of systematic acupuncture education that include not less than 100 hours of live lectures, demonstrations, and supervised clinical training specific to acupuncture.

(e) Dry needling by an individual licensed, registered, or otherwise authorized under any other part if dry needling is within the individual’s scope of practice.


The language seems to open the possibility that an athletic trainer could provide dry needling with training. However, the language also only suggests that this applies only to physicians as indicated from the above exemptions. The Michigan Athletic Trainers’ Society’s (MATS) recommendation is to exercise caution since the practice of acupuncture (and therefore dry needling) has recently received further protection with the passage of PA 140 of 2019. MATS also recommends for each individual to consult with the Michigan Department of Licensing and Regulatory Affairs (LARA) for a more definitive answer since MATS does not interpret Michigan laws, rules, and regulations. In addition, the individual should also consult their organization's legal team and directing physician for further guidance.

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