Is Dry Needling Legal for Physical Therapists and Occupational Therapists? Every State's Rule

The answer depends heavily on whether you're a PT or an OT. For physical therapists it's yes in 35 of the 50 states and DC, usually after a set course of 24 to 80 hours, and no in California, Hawaii and Oregon (Oregon's law changes on July 1, 2027). For occupational therapists it's yes in only 12, no in 4, and silent in most, and in both professions assistants are barred almost everywhere a rule mentions them.

This article goes through every state and DC for PTs and OTs: the status, the exact words of the rule, the training it asks for, and whether PTAs and OTAs may do it. I'm an occupational therapist, and I've stuck to what the rules say. Medicare has its own section at the end, because it decides what gets paid, not what you're allowed to do.

This isn't legal advice. I checked every rule on November 9, 2026, on the state's own legislature, code or board site. Your board's current rule is the one that counts.

The Short Answer

• PTs: allowed in 35 of the 51 jurisdictions. 25 set requirements in a statute, rule or board document: a course with hands-on training, often years of practice, written consent, and in some states registration with the board before you start. The other 10 allow it with no set training standard, and in 8 of those (Alaska, Arkansas, Connecticut, Kentucky, Maine, North Dakota, South Carolina and Texas) the only source is a board statement, a board ruling or an attorney general opinion.
• PTs: not allowed in 3. California (board statement), Hawaii (a statute that bars "invasive procedures") and Oregon (an attorney general opinion, until a 2025 law takes effect on July 1, 2027).
• PTs: no rule either way in 13. Alabama, Massachusetts, Michigan, Minnesota, Missouri, New Hampshire, New York, Ohio, Oklahoma, Pennsylvania, Rhode Island, Vermont and Wisconsin. In Alabama and Ohio the board has spoken only about PTAs. Silence is not permission.
• Training hours vary a lot. Where a state sets them, they run from a 24-hour course (Arizona, New Mexico) to Utah's 304 hours and Washington's 325, which count supervised treatment time.
• PTAs: barred in at least 22 jurisdictions. Illinois is the only state that lets PTAs dry needle, after the same training and with a PT in direct line of sight.
• OTs: allowed in 12. DC, Florida, Illinois, Louisiana, Maryland, Mississippi, Nebraska, North Carolina, North Dakota, Tennessee, Utah and Wyoming. Colorado and Delaware have passed laws that start by 2027. California, Georgia, Nevada and Oregon say no. The other 33 say nothing.
• OTAs: allowed in 2 (Illinois and North Carolina) and barred by name in 7 of the other 10 states that allow OTs.
• Medicare treats dry needling as acupuncture and pays for it only for chronic low back pain, from practitioners with an acupuncture degree and license.

Every State at a Glance

How to read the table. Allowed means an official source says PTs (or OTs) may dry needle but sets no training standard. Allowed with requirements means a statute, rule or board document sets the conditions. Prohibited means a statute, the board, the attorney general or a court says it is outside the scope or needs a law change. Not addressed means the practice act, the rules and the board's published statements say nothing about that profession doing it, and the rule column links the scope section that would govern. Where a law has passed but not started (Colorado and Delaware for OTs, Oregon for PTs), the cell gives the start date, and until then the earlier answer applies. The type of each source is in parentheses after its link, so you can tell what the law says from what a board says.

Where PTs Can't Dry Needle

California. The Physical Therapy Board's executive officer told a 2018 board meeting that "dry needling is not within the current scope of practice of PTBC and those practicing dry needling within the Board's jurisdiction may face enforcement by the Board," and that it would take a change in the law (PTBC minutes, Sept. 13-14, 2018 (opens in a new tab)). The acupuncture board says the same from its side: "In California, dry Needling is treated as the unlicensed practice of acupuncture when performed by unlicensed individuals or other medical professionals who are not expressly permitted by law" (Acupuncture Board, Licensing Committee materials, June 12, 2025 (opens in a new tab)). A 2026 bill, AB 2497, started out with dry needling for PTs, but "That language was removed from the bill on May 18, 2026" (Medical Board of California, bill analysis (opens in a new tab)).

Hawaii. The practice act doesn't use the words dry needling. It bans the whole category: "A physical therapist shall not use invasive procedures. For purposes of this section, an invasive procedure is the breaking or puncturing of a person's good skin integrity, for example, through surgery or injections" (HRS § 461J-2.5 (opens in a new tab)). Bills to carve out dry needling were filed from 2019 to 2021 and didn't pass.

Oregon, until July 1, 2027. In 2017 the state Department of Justice was asked, "Is the practice of 'dry needling' within the scope of practice of a physical therapist licensed in Oregon?" Its short answer was no (Op. OP-2017-2 (opens in a new tab)). A 2025 law reverses that, but not yet: "A physical therapist may perform dry needling, as defined by the Oregon Board of Physical Therapy by rule," with the board to set training rules, and the section "becomes operative July 1, 2027" (ORS 688.129 (opens in a new tab); the session law is Or. Laws 2025, ch. 627, § 24 (opens in a new tab)).

Court Fights and Attorney General Opinions

Acupuncture boards and associations have challenged PT dry needling in several states. Here is where that left the answer.

• North Carolina. The PT board issued a declaratory ruling in 2016 that dry needling is physical therapy, and the state acupuncture board took it to court. The case reached the North Carolina Supreme Court (N.C. Acupuncture Licensing Bd. v. N.C. Bd. of Physical Therapy Exam'rs, No. 380A17, Dec. 7, 2018 (opens in a new tab)), and the board's ruling stood. The board's current position statement relies on it: "Therefore, any utilization of dry needling techniques that satisfy the foregoing language is within the scope of physical therapy practice in NC." It also draws a line: "perineural dry needling extends beyond the current definition of dry needling thereby is not within the scope of physical therapy practice in NC" (NCBPTE position statement, reviewed June 5, 2024 (opens in a new tab)).
• Iowa. The Iowa Association of Oriental Medicine and Acupuncture asked the PT board to declare dry needling acupuncture. The board declared it physical therapy instead, and on January 10, 2018 the Iowa Court of Appeals upheld that: "we conclude its determination that the practice of dry needling falls within the definition of physical therapy was not irrational, illogical, or wholly unjustifiable." The court also noted the board's position "that physical therapists cannot engage in dry needling absent adequate training to competently perform the technique" (Iowa Court of Appeals, No. 16-1902 (opens in a new tab)). The board's rule now lists dry needling among the procedures in its definition of physical therapy (Iowa Admin. Code r. 481—800.1 (opens in a new tab)).
• Texas. There is no Texas rule. The acupuncture board asked the attorney general, who concluded: "A court would likely conclude that the Board of Physical Therapy Examiners has authority to determine that trigger point dry needling is within the scope of practice of physical therapy" (Tex. Att'y Gen. Op. KP-0082, 2016 (opens in a new tab)). That opinion is the main support for Texas PTs, and it sets no training standard.
• Washington. In 2016 the attorney general said "The practice of dry needling does not fall within the scope of practice of a licensed physical therapist" (AGO 2016 No. 3 (opens in a new tab)). The legislature answered in 2023 with an endorsement that takes 325 hours of instruction and clinical experience (RCW 18.74.200 (opens in a new tab)).
• Nevada. Before 2019 the Legislative Counsel Bureau advised, as quoted in the OT board's 2019 notice, that "In order for licensed physical therapists to practice dry needling in Nevada, it is the opinion of this office that the Legislature would need to change Nevada's existing laws by enacting clear statutory authority allowing licensed physical therapists to practice dry needling in Nevada." The legislature did that in 2019 for PTs, but not for OTs (Nevada OT Board advisory notice, 2019 (opens in a new tab)).
• Connecticut. The PT board's 2022 declaratory ruling, issued with the Connecticut Society of Acupuncturists taking part, says the PT scope "Permits dry needling as a rehabilitative procedure with an assistive device for the purpose of preventing, correcting or alleviating a physical disability" (final declaratory ruling (opens in a new tab)).

Occupational Therapists

As an OT, this is the part I watch most closely, and it's the part changing fastest.

New laws since 2025. Nebraska added dry needling to the OT act in 2025: "An occupational therapist may perform dry needling only in accordance with the level of education and training successfully completed" (Neb. Rev. Stat. § 38-2530 (opens in a new tab)). Utah set up registration with the same 304-hour course PTs take (Utah Code § 58-42a-307 (opens in a new tab)). Florida's 2026 law took effect July 1, 2026, and the OT board's rule followed on October 6, 2026; it asks for an application to the board "Within 60 days of the effective date of this rule, or within 60 days of the intent to perform dry needling in the state of Florida" (Fla. Admin. Code r. 64B11-4.008 (opens in a new tab)).

Passed but not started. Colorado's law reads "ON AND AFTER SEPTEMBER 1, 2027, AN OCCUPATIONAL THERAPIST MAY PERFORM DRY NEEDLING," with rules due by June 1, 2027 (HB 26-1042 (opens in a new tab)). Delaware's, signed August 31, 2026, requires "a written physician referral specific to dry needling" and takes effect 12 months after enactment or sooner once rules are in place (HB 165 (opens in a new tab)). Until then, OTs in both states should wait.

Hand and upper limb only. Tennessee and Louisiana allow OT dry needling of the upper limb, and Maryland allows it only for certified hand therapists: "Dry needling is not within the scope of practice of limited occupational therapy and shall only be performed by a licensed occupational therapist with a hand therapy certification" (COMAR 10.46.09.04 (opens in a new tab)).

Boards that said yes without a rule. North Carolina's OT board decided in 2023 that "dry needling is a physical agent modality within the scope of practice of occupational therapy in North Carolina" (NCBOT FAQ (opens in a new tab)). North Dakota's board doesn't certify any modality and leaves proficiency to the OT (NDBOTP practice page (opens in a new tab)), and DC's board agreed in 2019 minutes that OTs with advanced training or certification may do it.

Boards that said no. Georgia's OT board concluded that "dry needling is not statutorily authorized in the Occupational Therapy Practice Act and is therefore not within the scope of occupational therapy within the State of Georgia" (position statement, 2024 (opens in a new tab)). A 2026 bill to change that, SB 411, passed the Senate and a different version passed the House, but the record ends on April 2, 2026 without final passage (Georgia General Assembly, SB 411 (opens in a new tab)). Nevada's board: "Occupational Therapists are NOT authorized to perform dry needling until such time as statutory authority is granted by the Nevada Legislature" (advisory notice (opens in a new tab)). Oregon's OT board answers its own question, "Can OT's practice Dry Needling in Oregon? No" (OTLB topics page (opens in a new tab)). Alaska's board said no in June 2023, then "temporarily retracted" that statement in November 2023 while it works on regulations (board FAQ (opens in a new tab)).

PTAs and OTAs

Most states that mention assistants bar them, often in so many words, as in Wyoming's "Dry needling may not be performed by a physical therapy assistant or a physical therapy aide" (Wyo. PT Board Rules ch. 7, § 3 (opens in a new tab)). The exceptions:

• Illinois allows both. "Dry needling shall only be performed by a licensed physical therapist or licensed physical therapist assistant" (225 ILCS 90/1.5 (opens in a new tab)), and the OT act has the same sentence for OTs and OTAs. The assistant needs the full training, and the rule requires the supervising therapist to maintain "direct line of sight observation and supervision" while the treatment is given (68 Ill. Adm. Code 1340.75 (opens in a new tab)).
• North Carolina lets OTAs dry needle if "both the supervising occupational therapist and occupational therapy assistant must demonstrate and document competency in the techniques and modality" (NCBOT FAQ (opens in a new tab)).
• Alabama has no rule at all, and its board wrote in 2024 that "determining what treatment is appropriate to delegate to a PTA is the responsibility of the directing PT" (board letter (opens in a new tab)).
• Kentucky doesn't bar PTAs, but its board notes that APTA and FSBPT "have cautioned physical therapist assistants from engaging in dry needling" (Kentucky PT Board FAQ (opens in a new tab)).

If you work under a compact privilege, the rules of the state where the patient is apply, and that includes dry needling. Our licensure compact tool links each state's board. For which assistant visits fit where in a home health plan, see assistant visits and the order they go in.

Medicare and Dry Needling

This section is federal payment policy, not state law. Your state can allow dry needling and Medicare can still refuse to pay for it, and the reverse doesn't make it legal.

CMS counts dry needling as acupuncture. In the decision that created national coverage for acupuncture, CMS wrote: "CMS considers dry needling as a type of acupuncture" (Decision Memo CAG-00452N, Jan. 21, 2020 (opens in a new tab)). The national coverage determination then sets the limit (NCD 30.3.3 (opens in a new tab)):

All types of acupuncture including dry needling for any condition other than cLBP are non-covered by Medicare.

Chronic low back pain (cLBP) is covered: "Up to 12 visits in 90 days are covered," with "An additional 8 sessions" for patients who improve and "No more than 20 acupuncture treatments" a year (NCD 30.3.3 (opens in a new tab)).

Who may furnish it, and where that leaves PTs. The NCD names who can deliver covered acupuncture (NCD 30.3.3 (opens in a new tab)):

Physician assistants (PAs), nurse practitioners (NPs)/clinical nurse specialists (CNSs) (as identified in 1861(aa)(5) of the Act), and auxiliary personnel may furnish acupuncture if they meet all applicable state requirements and have: a masters or doctoral level degree in acupuncture or Oriental Medicine from a school accredited by the Accreditation Commission on Acupuncture and Oriental Medicine (ACAOM); and, a current, full, active, and unrestricted license to practice acupuncture in a State, Territory, or Commonwealth (i.e. Puerto Rico) of the United States, or District of Columbia.

Physical therapists aren't named. A PT could furnish covered acupuncture only as auxiliary personnel, which means holding that acupuncture degree and an acupuncture license, and working under the supervision of a physician, PA, NP or CNS as the NCD requires. A DPT plus a state dry needling course doesn't meet it. The same goes for OTs.

The CPT codes. CPT 20560 (needle insertion without injection, 1 or 2 muscles) and 20561 (3 or more muscles) arrived in 2020. CMS valued them in the CY 2020 Physician Fee Schedule but declined to list them as therapy codes, explaining (84 FR 62568, 62724 (opens in a new tab)):

We are not finalizing these codes as "always" or "sometimes" therapy services because dry needling services are non-covered unless otherwise specified through a national coverage determination (NCD).

When the NCD took effect, CMS told its contractors to "recognize and pay for acupuncture for cLBP services reported with CPT codes 97810, 97811, 97813, 97814, 20560, and 20561 as covered services under NCD 30.3.3" (MLN Matters MM11755 (opens in a new tab)). So 20560 and 20561 are payable by Medicare only as acupuncture for chronic low back pain, from a qualified practitioner.

Key Takeaways

• PTs can dry needle in 35 of 51 jurisdictions. Most set a course with hands-on training, and many add years of practice, consent forms or board registration.
• California, Hawaii and Oregon don't allow PT dry needling; Oregon will from July 1, 2027.
• OTs can dry needle in 12 jurisdictions, some only on the upper limb or as hand therapists. Colorado and Delaware start by 2027, and Georgia, Nevada, Oregon and California say no.
• Assistants are barred almost everywhere a rule mentions them; Illinois (PTAs and OTAs) and North Carolina (OTAs) are the exceptions.
• In 13 states for PTs and 33 for OTs, nothing addresses it. That is a question for your board, not a yes.
• Medicare pays for dry needling only as acupuncture for chronic low back pain, from practitioners with an acupuncture degree and license.
• This isn't legal advice. I checked these rules on November 9, 2026, and your board's current rule is the one that counts.

Frequently asked questions

Can physical therapists do dry needling in my state?

In most states, yes. 35 of the 50 states and DC allow it today. 25 of them set requirements in a statute, rule or board document, usually a course of 24 to 80 hours with hands-on training (more in Illinois, Nevada, Utah and Washington), sometimes years of practice, registration with the board and written consent. 10 allow it with no set training standard. California and Hawaii don't allow it, and Oregon won't until July 1, 2027. The other 13 states have no rule either way, which is not the same as permission.

Can occupational therapists do dry needling?

Only in a minority of states. 12 jurisdictions allow it now: DC, Florida, Illinois, Louisiana, Maryland, Mississippi, Nebraska, North Carolina, North Dakota, Tennessee, Utah and Wyoming. Louisiana and Tennessee limit it to the upper limb, and Maryland to certified hand therapists. Colorado and Delaware have passed laws that start by 2027. California, Georgia, Nevada and Oregon say OTs can't. The other 33 say nothing, and in most of those an OT board would want a clear rule before you start.

Can a PTA or OTA perform dry needling?

Almost never. Illinois lets both PTAs and OTAs dry needle after the same training as the therapist, with the supervising therapist in direct line of sight, and North Carolina lets OTAs do it when both the OT and the OTA document competency. At least 22 jurisdictions bar PTAs, and 7 of the states that allow OTs to dry needle bar OTAs by name. Most other states don't mention assistants at all.

Does Medicare pay for dry needling?

Only as acupuncture for chronic low back pain. CMS treats dry needling as a type of acupuncture and covers it only under NCD 30.3.3, for up to 12 visits in 90 days and 20 a year. The practitioner must be a physician, or a PA, NP, CNS or auxiliary staff member who holds a master's or doctoral degree in acupuncture and an acupuncture license. A physical therapist's dry needling training doesn't meet that standard, and for any other condition Medicare doesn't cover it.

Sources

Every state's rule is linked in the table, to the state's legislature, its official administrative code publisher, its board, its attorney general or its courts. All were read on November 9, 2026. The national sources:

• CMS, NCD 30.3.3, Acupuncture for Chronic Low Back Pain (opens in a new tab), effective January 21, 2020.
• CMS, Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N) (opens in a new tab).
• CMS, MLN Matters MM11755 (opens in a new tab), implementing the NCD for claims.
• Federal Register, CY 2020 Physician Fee Schedule final rule, 84 FR 62568 (opens in a new tab), section on trigger point dry needling (CPT 20560 and 20561).
• Other practice-act articles in this series: dating a former patient, supervising PT and PTA students and holding both COTA and PTA licenses.