HB 2184
In CommitteeHouse
OT intramuscular needling
Concerning occupational therapists performing intramuscular needling.
This status may be delayed. See Action History below for the latest updates.
How does a bill become law?
- Introduced: The bill is filed and assigned a number.
- Committee: A subject-matter committee holds hearings, takes public testimony, and decides whether to advance the bill.
- Floor Vote: The full chamber (House or Senate) debates and votes on the bill.
- Opposite Chamber: The bill repeats the committee and floor vote process in the other chamber.
- Governor: The Governor reviews the bill and decides whether to sign or veto it.
- Signed: The bill has been signed into law.
AI Analysis
This bill formally authorizes occupational therapists in Washington to perform intramuscular needling (dry needling) as part of their scope of practice, but only after completing rigorous training and obtaining a state-issued endorsement. It establishes clear standards for education, supervision, patient consent, and coordination with other providers.
- Adds a formal definition of intramuscular needling (also called 'dry needling') to state law, clarifying it is a skilled intervention using sterile needles to treat neuromusculoskeletal pain and movement issues.
- Allows occupational therapists to perform intramuscular needling only after obtaining a state-issued endorsement from the Department of Health, approved by the Board of Occupational Therapy Practice.
- Sets strict training requirements for endorsement: 100 hours of didactic instruction, 75 hours of in-person hands-on training, and 150 hours of supervised clinical practice (at least 150 treatment sessions).
- Requires occupational therapists to obtain informed consent from patients before performing intramuscular needling, including specific information about risks, benefits, and how the procedure differs from acupuncture.
- Prohibits delegation of intramuscular needling to aides or assistants and requires the occupational therapist to be present for the entire procedure.
- Requires occupational therapists to coordinate care with acupuncturists or Eastern medicine practitioners when treating the same patient for the same condition to avoid duplication of services.
Who is affected
- Occupational therapists — Occupational therapists in Washington must obtain a new state-endorsed credential to legally perform intramuscular needling; they must meet specific education, training, and experience requirements before practicing this technique.
- Patients receiving occupational therapy — Patients receiving occupational therapy may gain access to intramuscular needling as part of their treatment plan, but only after their therapist completes specialized training and they sign a detailed informed consent form that distinguishes the procedure from acupuncture.
- Other healthcare providers — Other licensed providers (e.g., physicians, naturopaths, acupuncturists, physical therapists) may serve as qualified supervisors for occupational therapists seeking intramuscular needling endorsement, and must meet specific credentialing criteria.
- State regulatory agencies — The Washington State Department of Health and the Board of Occupational Therapy Practice will be responsible for reviewing applications, issuing endorsements, and ensuring compliance with training and practice standards.
Pro/Con Analysis
Stronger case for benefits
Potential Benefits (5)
Expands access to a targeted pain management technique for patients receiving occupational therapy—particularly those with chronic musculoskeletal pain—while requiring robust informed consent and supervision, thereby improving safety and patient autonomy.
HealthcarePeopleRef: Sec. 2(1)(a)(iii), Sec. 2(7)Establishes high training standards (100+75+150 hours) and restricts supervision to licensed providers (e.g., physicians, NPs, PTs), enhancing patient safety and reducing risk of improper or unsafe practice—especially compared to states with minimal or no regulation of dry needling by OTs.
HealthcarePeopleRef: Sec. 2(1)(a)(i)-(ii), Sec. 2(2)Allows prelicensure training to count toward endorsement, enabling newer occupational therapists to gain the credential earlier in their careers—potentially increasing workforce capacity and reducing long-term training costs for individuals.
EducationPeopleRef: Sec. 2(5)Prohibits delegation of intramuscular needling to aides or assistants and requires the therapist to be present throughout the procedure, reducing risk of errors or unsafe practice by unlicensed personnel.
Public SafetyPeopleRef: Sec. 2(4)Requires coordination with acupuncturists for overlapping care, which may reduce unnecessary duplication of treatment and improve continuity of care—especially for patients receiving integrative pain management.
HealthcareLean peopleRef: Sec. 2(6)
Potential Concerns (5)
Increases barriers to entry for occupational therapists seeking to expand their scope of practice, potentially limiting workforce availability and increasing wait times for patients seeking this modality—especially in rural or underserved areas where training opportunities and qualified supervisors are scarce.
HealthcarePeopleRef: Sec. 2(1)(a)(iii)Mandates care coordination between occupational therapists and acupuncturists for overlapping conditions, which may improve patient safety but adds administrative burden and could delay treatment if coordination is not well-resourced or standardized across providers.
HealthcarePeopleRef: Sec. 2(6)The 325-hour training requirement (100 didactic + 75 hands-on + 150 clinical) is rigorous and may exclude qualified occupational therapists who lack time, financial resources, or access to approved training programs—particularly those working full-time or in non-academic settings.
EducationLean peopleRef: Sec. 2(1)(a)(i)-(iii)Requires informed consent that explicitly distinguishes intramuscular needling from acupuncture, which may increase patient confusion or anxiety if not clearly communicated—especially for patients unfamiliar with the distinction—potentially undermining truly informed consent.
Public SafetyLean peopleRef: Sec. 2(7)The bill notes possible slight increase in state administrative costs for endorsement processing and oversight, though no dollar amount is provided; this could strain Department of Health and Board resources, especially if application volume exceeds projections.
Local GovernmentRef: Fiscal Impact section
Who Is Most Affected
Occupational therapists gain legal authority to perform a clinically valuable technique, but must invest significant time and money in training and supervision; those in urban or academic settings with training access benefit more than those in rural or under-resourced clinics.
Patients—especially those with chronic musculoskeletal pain—gain access to a potentially effective, non-pharmacologic intervention within their existing OT care; however, access may be limited by therapist availability, training costs passed on via fees, or delays due to coordination requirements.
Physicians, NPs, and physical therapists may benefit from expanded roles as supervisors, but may also face increased demand for supervision duties without compensation; acupuncturists gain formalized coordination responsibilities, which may reduce treatment overlap but not necessarily increase revenue.
The Department of Health and Board of Occupational Therapy Practice gain new regulatory responsibilities, including application review and compliance monitoring—adding administrative burden without new funding, potentially diverting resources from other priorities.
Patients with chronic pain, especially those seeking non-opioid alternatives, benefit from expanded access to a skilled intervention within their existing care team; low-income patients may benefit less if therapists pass training costs onto patients or if services remain underinsured.