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Proposed Changes to the Administration of the PT Act: Rules are not just not about dry needling

Monday, March 12, 2018   (0 Comments)
Posted by: Matthew Nicholas
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Proposed Changes to the Administration of the PT Act: Rules are not just not about dry needling

On February 23, 2018, the Illinois Register published the long awaited proposed rules for dry needling.  This marked the start of the 45 day comment period that will end April 9, 2018.  Providing there are not substantive objections to the rules as they are proposed, the next step will be for the Joint Committee on Administrative Rules (JCAR) to review for passage.  Once passed, we can celebrate the official end to our long fight to specifically incorporate dry needling in the physical therapist scope of practice in Illinois.

The IDFPR and the PT Board did not stop with dry needling rules in this proposed rule package.  Changes to existing rules have also been proposed in other areas that may impact you.  We’ll walk you through those changes below.   Moving forward, the IPTA supports these changes and does not intend to file any objections that could delay passage of any/all of the proposed rules.  If you have questions about specific circumstances that could be impacted by these changes, please contact the Chapter office (ipta@ipta.org) for additional assistance.

Foreign Trained Licensure Applicants:  A change in Section 1340.20 Approved Curriculum answers the question, when foreign trained individuals are required to complete additional course work in the U.S., where should they submit their new transcripts? Short answer:  “to FCCPT or another credentialing service acceptable to the Department”.  If we back up a bit, the rules explain that a foreign trained applicant is required to have their credentials evaluated and make up any deficiencies.  This rule just makes it clear that applicants should continue to work with their credentialing service until all educational requirements are met.  This applies to both PT and PTA applicants.

Remedial Plans for Applicants After 3 Exam Failures:  This change (Section 1340.40) provides for plans to include didactic training programs as well as the clinical ones previously allowed.  This applies for both PT and PTA applicants. 

Licensure by Endorsement:  The change in Section 1340.50 is to remove reference to an out of date procedure.  As written in the current Rules, it appears that there is a gap of time between applicants receiving notice that their application is complete and the granting or denial of a license.  In practice, the IDFPR notifies the applicant once that their application is complete and licensure is granted or the reason(s) why an application is denied.

Certain Fees Removed:  As IDFPR has moved to electronic issue of licenses and certificates, they are proposing discontinuing the practice of issuing a duplicate license for a fee as well as offering printed wall certificates and the fees associated with the certificate’s production. 

Continuing Education:  Three significant changes are proposed.  First, to address advances in technology, virtual participation in live educational events where the participant can communicate in real time with the speaker and other participants is no longer considered self-study.  Prerecorded webinars and presentations are still self-study, require a testing component, and can only make up 50% of your CE renewal requirement.  This change will help to eliminate geographical and physical barriers to participating in live educational events.  Translation:  events like the IPTA’s #Third Thursday and Spotlight on Research will officially be considered live study and not self-study for those participants who virtually attend.  Watching a “rerun” from our online #Third Thursday library and taking the test is self-study.  The flip side is the second change:  a physical inability to travel or similar extenuating circumstance no longer qualifies an individual for a waiver of CE requirements.  Full time service in the U.S. armed forces and illness/hospitalization/temporary disability can still potentially be considered hardships for CE waivers. The third change raises the maximum number of CE hours for a license renewal period from 5 to 10 for clinical instructors for PT students.  There is no change for PTA, making the requirement not proportionally equal:  5 of 20 hours for PTAs, 10 of 40 hours for PTs.

Testimonials in Advertising:  These proposed rules are a catch up from previously passed legislation.  The restriction on the use of testimonials in PT advertising was removed by the General Assembly in the passage of SB 3115 , back in 2014.  This clean up brings the rules into compliance with law.  Summary, testimonials are allowed in PT advertising and all advertisements should not be false, misleading, fraudulent, deceptive, make guarantees/warranties of success, play upon vanities or fears of the public, or include statements that promote unfair competition.

Intramuscular Manual Therapy (aka dry needling):  Since so much specific regulation was incorporated into the law (Practice Act), there wasn’t mush left to do.  If you review the proposed rule, you will see that it is primarily a “cut and paste” of what is stated in the PT Act.  A couple of statements help answer some of the frequently asked questions relating to incorporating dry needling in an Illinois licensed physical therapist’s personal scope of practice:

  • No further clarification is provided on the requirement of the 50 hours of education in certain areas.  The expectation is that those requirements are met as part of entry level education for a physical therapist.  The IPTA suggests you review your transcripts and keep record of how you can demonstrate completion if you were ever asked by the IDFPR to produce it.
  • Further information is given relating to the 30 hours of dry needling didactic coursework:  individuals can count any pre-study requirements associated with the specific practicum courses they plan to complete.  There are no additional requirements or instruction on how an individual is to document completion of this requirement.  The IPTA suggests that you keep a permanent record of what materials were used in the didactic coursework and supplement as needed to sufficiently demonstrate 30 hours of study.
  • No further clarification is provided on the 54 practicum hours, just make sure that they have been approved by either the FSBPT or check with the IDFPR on whether they, or another organization that they consider the FSBPT’s equivalent, has reviewed and approved the program before signing up to take it.
  • Direction is given for those individuals who have met some, but not all, of the requirements prior to the passage of the dry needling rules and/or adoption of these rules.  Basically, you have 12 months from the date of adoption of the rules to complete any outstanding requirements.  The IPTA suggests you consider your individual circumstances, such as did the curriculum taught in your program meet or exceed the 27 hour threshold and include the required areas?  If not, you may want to consider repeating a program or finding a “bridge” program that will ensure that you meet all requirements. 
  • The requirement of at least 200 patient treatment sessions is clarified to state that those must be completed under general supervision as recognized by the APTA, which define it as “the (supervising) PT is not required to be onsite for direction and supervision, but must be available by telecommunication.”  It is important to note that the rule refers to sessions, not patients, meaning multiple sessions with the same patient count as multiple sessions.  As far as general supervision, the rules do not specify who is qualified to supervise.  The IPTA suggests you use your best judgement and work to find an individual who has already met all of the educational requirements for dry needling practice in Illinois.  This could be a program instructor or a colleague who agrees to be available for consultation with you while you are providing dry needling treatment.  You need to also be able to provide documentation of how you completed this requirement, should you ever be asked by the IDFPR to provide it.  Consider the long term: in 20 years and after potentially changing places of employment once or several times, how could you demonstrate to the IDFPR that you completed 200 generally supervised visits in 2018?  The IPTA suggests you establish a permanent record that includes information such as date, areas treated and who provided general supervision, along with some type of way to identify the patient – without violating HIPAA requirements. 
  • Completion of a competency examination is clarified to mean that the IDFPR will accept exams administered as part of the practicum courses.  No “official” dry needling exam will be offered through the State.
  • The remainder of the rules are repeats of what is written in law: 
    • You are responsible for maintaining your dry needling education records (forever!).
    • New grads, unless you met all of the dry needling education requirements as part of your entry level PT education, don’t plan on adding dry needling to your personal scope of practice until you have been licensed for at least one year.
    • Dry needling cannot be delegated to PTAs or aides.
    • Don’t use “acupuncture” to describe what you do, and don’t refer to yourself as an “acupuncturist” unless you are separately licensed under the Acupuncture Practice Act.

There are a few other proposed changes to the rules that are editorial in nature (“therapist” instead of “therapy”) or relate to administrative processes that do not directly impact licensure. 

While the IPTA is providing this information to members, we cannot offer any assurances that these rules will be passed as proposed, nor should these informal interpretations and recommendations be considered legal advice.  The best advice we can (and always) give is to consider your individual circumstance and how laws apply to you.  Sometimes that requires consultation with the IDFPR, and other times you may need to consult with your personal legal counsel (attorney). 

The IPTA will continue to monitor the rules process and provide updates as information is available. 


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