Understanding Dry Needling Scope of Practice Across Professions in 2026
Dry needling has become one of the most talked-about and widely adopted manual therapy techniques in healthcare — but who is legally permitted to perform it varies widely by profession and by state. As clinicians seek to integrate dry needling into their practice, understanding the legal scope of practice and relevant definitions is essential for safe, compliant, and effective patient care.
In this guide, we’ll clarify:
The FSBPT’s updated definition of dry needling
How dry needling fits into the scope of practice for:
Physical Therapists (PTs)
Occupational Therapists (OTs)
Athletic Trainers (ATCs)
Chiropractors (DCs)
Key considerations for competency, training, and compliance
Let’s jump in.
What Is Dry Needling – According to FSBPT
The Federation of State Boards of Physical Therapy (FSBPT) — a widely referenced authority on physical therapy practice and regulatory content — conducted an updated competency study and arrived at a clear definition that many jurisdictions are using as a model for scope language. Dry Needling Academy’s Co-owner Keri Maywhort, PT, DPT, OCS was a member of the task force that created the definition initially, and updated it in 2024.
FSBPT defines dry needling as:
“A skilled intervention performed by a physical therapist using needles to penetrate the skin and/or underlying tissues to affect functional change in anatomical structures and systems for the evaluation, management, and prevention of neuromusculoskeletal conditions, pain, movement impairments, and disability.”
This definition emphasizes a few important points:
Dry needling is not simply inserting needles — it is a skilled intervention grounded in anatomy, neuromusculoskeletal assessment, and clinical decision-making.
The goal is not merely pain relief, but functional change — including movement, pain, and disability management.
The definition intentionally separates dry needling from other needle-based modalities (like acupuncture) by focusing on structural and functional outcomes rather than energy meridians or traditional acupuncture frameworks.
This FSBPT language has become a foundational regulatory tool used in many state practice acts or guidance documents to clarify what dry needling involves and who may be competent to provide it.
Scope of Practice for Physical Therapists (PTs)
National Perspective
Physical therapists have been at the forefront of dry needling in the United States. Many state practice acts now explicitly allow qualified PTs to perform dry needling as part of physical therapy services.
Under the FSBPT definition and related state laws, dry needling — when performed by a licensed PT with documented competency — is widely accepted as within the physical therapy scope in most states.
Which States Don’t Allow Dry Needling for PTs?
As of 2026, only a small number of states still have explicit prohibitions or limitations on PT dry needling. These historically restrictive states include:
California (Currently has language written, waiting on a representative to sponsor it).
Hawaii
New York
Washington and Oregon are two of the more recent states to adopt it into their practice act. PTs are actively needling and working towards the hourly requirements in Washington (75 hours of in person training) at this time. Oregon signed it into law in August 2025 to be operative July 1, 2027. The Oregon PT board is working on the rules they want put in place before summer 2027. Illinois is the only state where the language around use of electrical stimulation (in reference to dry needling) is not clear. Here is a link to their rules: Illinois Statutes Chapter 225
Regulatory change continues to occur, and legislative efforts to modernize PT practice acts are underway in many regions.
Competency and Training Requirements
Most states that allow PT dry needling also require:
Additional post-professional training in dry needling (didactic and supervised)
Ability to demonstrate competency (through on-course assessment, or supervised sessions)
Clear informed consent and safety documentation before treatment
FSBPT’s dry needling competency research shows that while many core skills (evaluation, examination, and diagnosis) are part of entry-level PT education, specialized training is still needed for the hands-on psychomotor skills required for safe and effective needling.
Scope of Practice for Occupational Therapists (OTs)
Occupational therapy’s relationship with dry needling is less uniform than physical therapy. While there’s growing interest in including dry needling under OT’s physical agent modalities, the regulations vary significantly by state.
AOTA’s Position
The American Occupational Therapy Association (AOTA) includes physical agent modalities (PAMs) within the profession’s domain, recognizing their role in preparing clients for meaningful activities and occupations. AOTA supports the integration of PAMs when appropriate and within a state’s regulatory framework.
However, AOTA does not universally authorize dry needling nationwide; actual scope of practice is still determined by individual state boards and statutes.
State-by-State Variability
Some states allow OTs to perform dry needling with documented training and competency.
Other states have explicit prohibitions, limiting invasive needle techniques to professions like acupuncturists or PTs
Some states do not have explicit language in their practice act, but do have recommendations set forth by the state’s Occupational Therapy Association Chapter.
This means occupational therapists must review their state practice act language and board interpretation before providing dry needling.
Because occupational therapy regulation tends to be more conservative around invasive procedures, many practitioners rely on clarifying language from the state OT board or seek legal guidance before integrating dry needling into practice.
Athletic Trainers (ATCs): A Growing Presence
Athletic trainers (ATCs) are increasingly included in the discussion on dry needling, with state regulations evolving rapidly.
Professional Position and Regulation
The Board of Certification for the Athletic Trainer (BOC) recognizes the competence of ATCs to use dry needling when allowed by state law and when appropriate training and certification standards are met.
State guidelines typically require:
Completion of a BOC-approved dry needling course (*Dry Needling Academy’s courses are BOC approved!)
Documentation of competency (didactic + hands-on training)
Physician supervision letter or protocol in some jurisdictions
Examples of State Requirements
Alabama: ATCs may perform dry needling after a BOC-approved course and submission of a supervising physician’s attestation.
Other states have more stringent supervised clinical requirements, reflecting growing but variable recognition of ATCs’ role in needle-based interventions.
Here is an article published by the BOC in March, 2025 covering an overview of dry needling regulations up to that point: Dry Needling State Regulation Updates
Since dry needling remains a relatively new area for ATCs, staying informed about state licensure rules and scope language is critical for athletic trainers before providing this service.
Chiropractors and Dry Needling
Chiropractic practice acts in many states also encompass needle-based treatments, though the regulatory language varies.
Broad Chiropractic Authority
In many jurisdictions, chiropractors are legally empowered to perform dry needling as part of musculoskeletal care. However:
Some states require clear training documentation.
Some states interpret dry needling within acupuncture scope unless additional credentials are held.
Documentation and consent requirements still apply, and training expectations may differ from state to state.
For example, certain states explicitly require training documentation or consent protocols before DCs can utilize dry needling.
Key Considerations Across Professions
Regardless of profession, there are essential principles clinicians must follow before using dry needling:
1. Know Your State Law
Always consult your state practice act and board rules to confirm whether dry needling is authorized, permitted with conditions, or prohibited under your license.
2. Complete Approved Education & Document Competency
Training should include:
Hands on training
Anatomy and safety
Needle hygiene and risk management
Clinical reasoning and assessment
State boards often require proof of training and competency before practice. This protects clinicians and patients alike.
3. Informed Consent and Documentation
Dry needling is invasive, so documenting:
Patient consent that includes risks and benefits (verbal and written consent is advised)
Structures that are treated during each session
Treatment outcomes
is crucial for patient safety, optimal clinical practice and regulatory compliance.
4. Distinguish Dry Needling from Acupuncture
Most scope definitions (including FSBPT’s) emphasize that dry needling is distinct from acupuncture — it focuses on functional, neuromusculoskeletal change rather than traditional meridian theories. Clear documentation and terminology separate these practices in both clinical and legal contexts.
Conclusion
Dry needling is no longer experimental — it’s an established intervention across multiple healthcare professions with a solid and growing case of evidence to prove its efficacy. But scope of practice depends on profession and state law:
PTs: Widely authorized in most states using FSBPT-aligned definitions and competency requirements — with only a few jurisdictions still restricting practice.
OTs: Recognized nationally as physical agent modality, but dependent on state rules and regulatory interpretation.
ATCs: Increasingly permitted with BOC-approved credentialing and state protocols.
Chiropractors: Broad but variable inclusion, often hinging on state practice acts and training expectations.
Understanding your local regulations, documenting competency, and using clear, updated definitions like the FSBPT’s dry needling description are essential for safe, effective, and compliant practice.
References
FSBPT Dry Needling Competency Update (2024) — updated definition and competency context.
AOTA Policy E.18 -Language in support of dry needling
BOC Athletic Trainer dry needling state regulation updates. (March 2025)
Chiropractic dry needling regulations (Published 2019) ** a handful of states’ practice acts have changed since this publication. Check individual practice acts for the most up to date information
