It depends on the state. Florida approves OTs with two years of practice, 50 hours of approved face-to-face CE and 25 qualifying sessions. Tennessee allows upper-limb dry needling after 50 foundational and 24 in-person hours. Maryland limits it to certified hand therapists who register. Most states have no specific OT rule.
Dry needling by OTs is regulated state by state, and the rules range from a formal board approval to silence. Florida, Tennessee and Maryland have written rules for OTs; Wyoming's board has published its position; most other states have said nothing specific. Where a state has a rule, it sets the training hours, any supervised sessions, who may perform it and whether you must register before your first patient. The rules below are the registration and training requirements only, not clinical practice.
How does Florida's approval work?
Florida authorizes it by statute, and the board must approve you first. Its board says OTs must meet section 468.227, Florida Statutes, and Rule 64B11-4.008, which require:
- at least two years of practice as a licensed OT;
- 50 hours of board-approved, face-to-face continuing education; and
- 25 patient sessions of dry needling, either supervised by an OT, PT or chiropractic physician with an active license who has performed dry needling for at least a year, or completed as an OT licensed in any state or in the US Armed Forces.
The board says it is now accepting applications, that no fee is required for the application, and that OTs "may not provide dry needling services until approved by the Board." Approved courses are listed through CE Broker once the board approves the providers.
What does Tennessee require?
Tennessee allows dry needling "to the upper limb," defined as the hand, wrist, elbow and shoulder girdle, under Tenn. Comp. R. & Regs. 1150-02-.21:
- Foundational instruction: 50 hours covering musculoskeletal and neuromuscular systems, pain mechanisms, trigger points and universal precautions, which the rule says are "generally satisfied" in OT school or through board-approved CE.
- Dry needling instruction: 24 hours specific to the upper limb, covering technique, indications and contraindications, documentation, adverse effects, psychomotor competency and OSHA's bloodborne pathogens protocol.
- In person only: all instruction "must be obtained in person and may not be obtained online or through video conferencing."
- Course approval: courses must be approved by the board or its consultant, and an OT trained in another state must submit the same documentation a course provider would and receive approval before practicing.
- New licensees: a newly licensed OT waits at least one year unless pre-licensure coursework meets the rule.
Only a licensed OT may perform it; it "may not be delegated to an occupational therapy assistant or support personnel." Patients must receive written information on the risks, benefits and potential side effects, and the OT must document training on the board's request.
Why does Maryland require the CHT?
Maryland's rule is the narrowest. It covers dry needling "performed by occupational therapists who are certified hand therapists (CHTs)," limited to the hand, wrist, elbow and shoulder. Requirements under COMAR 10.46.09:
- CHT in good standing, plus at least two years of OT practice;
- 52 hours of instruction: 27 in board-approved course content (live or real-time interactive) and 25 hands-on hours under a practitioner who has practiced dry needling at least five years, with no online substitute for the hands-on part;
- registration with the board before practicing, with proof of CHT recertification to keep it; and
- written informed consent specific to dry needling in the patient record.
See licensing questions for hand therapists for the CHT itself.
Where else has a board spoken?
Wyoming's board says in its FAQ that its practice act "DOES support that Wyoming licensed Occupational Therapists who are properly trained are able to use dry needling techniques." It recommends at least 27 hours of live, face-to-face training (online courses "are not appropriate"), bars OTAs and support personnel from performing it, requires written documentation of training on request, and says it intends to add these or similar requirements to its rules.
California's advanced practice regulations cover hand therapy, physical agent modalities and swallowing (16 CCR §§ 4150 to 4155); dry needling is not among them. In California and the many states we have not listed, do not assume silence means permission. Ask the board in writing and keep the answer.
Can OTAs perform dry needling?
Not in the states above. Tennessee's rule and Wyoming's guidance both bar OTAs, and Maryland's rule is limited to OTs who are CHTs. Florida's approval is for occupational therapists.
Does a compact privilege let you dry needle in another state?
A privilege lets you practice under the remote state's laws, not your home state's (OT Compact, Section 4.C). Maryland and Tennessee both issue privileges, so their dry needling rules apply to an OT practicing there under a privilege, including any registration or course approval. Ask the board how a privilege holder meets its requirements before you treat. Physical therapists face their own patchwork; our sister site covers it in dry needling across state lines.
How do we help?
We do not provide dry needling training or vouch for anyone's competence. We check what the state requires, confirm your courses and supervised sessions meet it, and file the license and any board application together. Licenses by endorsement are $599 per state; board fees are separate. See also physical agent modality rules by state and the state license index.
Common questions
- Can occupational therapists dry needle in Florida?
- Yes, after board approval. Florida requires two years of OT practice, 50 hours of board-approved face-to-face CE and 25 qualifying patient sessions, and OTs may not dry needle until approved.
- Can OTAs perform dry needling?
- Not in Tennessee or Wyoming, which both bar OTAs, and Maryland limits it to OTs who are certified hand therapists. Florida's approval is for OTs.
- Can I take dry needling training online?
- Not for Tennessee, which requires in-person instruction, or for Wyoming's recommended training. Maryland allows real-time interactive coursework but not online hands-on hours.
- Is dry needling allowed for OTs in my state if the board has not said anything?
- Do not assume so. Ask the board in writing and keep its answer before treating any patient.
Need Help with Your Application?
We handle the OT licensing process end-to-end — eligibility screening, documents, board follow-ups, and tracking.