Dry needling and manual therapy - rights and records

Rafał has completed a dry needling course and wants to add it to his practice's offer. But before he inserts the first needle, he has doubts: can a physiotherapist even perform dry needling? Is a course certificate enough? What consent must the patient sign, and does his liability insurance cover this type of procedure?

Dry needling and advanced manual therapy are higher-risk techniques -- which means higher requirements for qualifications and records. In this article we explain who can perform them, how to document them, and how to protect yourself legally.

Can a physiotherapist perform dry needling and manual therapy

Yes. The Act of 25 September 2015 on the physiotherapy profession provides that a physiotherapist delivers healthcare services, including applying physiotherapy methods and therapeutic techniques. Manual therapy and dry needling (needling of trigger points within muscle and fascial tissue) fall within a physiotherapist's competence, provided they have the appropriate training.

Key distinction:

• Dry needling -- a physiotherapy technique that targets trigger points. It is not acupuncture in the sense of traditional Chinese medicine.
• Manual therapy -- manual techniques (mobilisations, manipulations, soft-tissue techniques) with varying levels of advancement and risk.

Simply being a physiotherapist isn't enough -- what matters is documented preparation for the specific technique.

Qualifications and courses -- what's required

The regulations don't establish a single, central "dry needling certificate." Two things are key, however:

1. An active physiotherapy licence number (PWZFz).
2. Documented preparation for performing the given technique -- completed courses/training confirmed by certificates.

In practice this means you must:

• Keep certificates of completed courses (dry needling, manual therapy of a given concept).
• Be able to demonstrate that the scope of your training matches the techniques you apply.
• Act within the limits of your competence -- the KIF code of ethics requires you not to undertake activities that exceed your training.

During a KIF inspection or a dispute with a patient, lacking a certificate confirming preparation for an invasive technique is a serious liability.

Informed consent -- an absolute must

Dry needling is an invasive technique (it breaches tissue continuity), so informed patient consent is not just good practice -- it's a necessity. A dry needling consent form should include:

• Description of the procedure -- what dry needling involves.
• Purpose -- what the technique is meant to achieve.
• Risks and possible complications -- post-procedure pain, bruising/haematoma, vasovagal fainting, risks related to the treatment area.
• Contraindications -- questions about anticoagulant medication, pregnancy, clotting disorders, skin infections, fear of needles.
• Alternatives -- other available therapy methods.
• Confirmation of understanding and signature of the patient and therapist, dated.

For higher-risk manual therapy (e.g. cervical spine manipulation), a separate, informed consent describing the risk is also recommended.

Documenting a dry needling procedure

In the treatment log, document every dry needling session in detail:

Element	What to record
Date and time	Exact time of the procedure
Indication	Why dry needling was applied
Location	Which muscles / trigger points
Technique	Type of needling, number of insertions
Patient reaction	Pain, local reaction, adverse events
Recommendations	What the patient should do after the procedure
Signature	Therapist performing the procedure

Good dry needling records are your primary defence should a patient report a complication or a claim.

Liability insurance and invasive techniques

This is a trap many people forget about. Standard liability insurance may not cover invasive techniques or specific methods if they weren't included in the policy's scope. Before you start dry needling:

• Check whether your liability policy covers dry needling.
• Ask your insurer directly about invasive techniques / dry needling.
• Make sure the scope actually covers the procedures you perform.

A procedure outside the policy's scope risks the insurer refusing to pay out in the event of a complication, leaving you personally liable.

[SP] Example -- Solo practice: Before adding dry needling to his price list, Rafał calls his insurer and extends his liability cover to include invasive techniques. He creates a separate informed consent form for dry needling and adds a scan of his course certificate to his records. He describes every procedure in the log: location, number of insertions, patient reaction.

[GR] Example -- Group practice: In the practice, only two of the four physiotherapists perform dry needling -- the ones who hold certificates. The regulations and procedures clearly state who is qualified for which techniques, so there's no doubt during an inspection that only trained people perform the procedures.

Contraindications and procedure safety

Before performing dry needling, you must take a history covering contraindications and document it. Situations requiring particular caution or withdrawal from the procedure include, among others:

• Taking anticoagulant medication and clotting disorders.
• Pregnancy (particularly areas that may carry risk).
• Local skin infections, inflammation, fresh wounds near the planned insertion site.
• Strong fear of needles, tendency to vasovagal fainting.
• Systemic conditions affecting healing and immunity.

A documented contraindication history isn't a formality -- it's evidence that you acted with due diligence, should a complication and claim arise.

Handling an adverse event

Even correctly performed dry needling can involve an adverse reaction (fainting, haematoma, increased pain). It's worth having a simple procedure:

1. Stop the procedure and make the patient safe.
2. Provide first aid appropriate to the situation.
3. Record the event in the documentation: what happened, how you responded, the patient's condition.
4. Refer the patient to a doctor if necessary.

An honest account of an adverse event protects you better than silence -- it shows you responded correctly and transparently.

Most common mistakes

• No separate consent for dry needling -- general consent for physiotherapy isn't enough for an invasive technique.
• Terse entry of "dry needling" -- without location, number of insertions, and patient reaction.
• Technique not included in liability cover -- a gap in insurance in the event of a complication.
• No certificates in the records -- you can't demonstrate preparation.
• Performing techniques beyond your competence -- a breach of the KIF code of ethics.

Frequently asked questions

Can I perform dry needling as a physiotherapist without a doctor's consent?

Dry needling falls within a physiotherapist's competence under the Act on the physiotherapy profession, provided you have an active PWZFz and documented preparation (a completed course). What matters is acting within your competence and obtaining the patient's informed consent.

What certificate qualifies you to perform dry needling?

The regulations don't specify a single official certificate. However, you must hold and keep documents confirming completion of a dry needling course and be able to show that its scope matches the techniques you apply. Lacking such confirmation is a liability during a KIF inspection.

Do I need separate consent for dry needling?

Yes. Dry needling is an invasive technique, so in addition to general records you need a separate informed consent form describing the procedure, risks, contraindications, and alternatives, signed by the patient and the therapist.

Does my liability insurance cover dry needling?

Not always. A standard liability policy may not cover invasive techniques. Before starting dry needling, ask your insurer directly whether the policy's scope covers dry needling, and extend the cover if necessary.

CTA: Adding dry needling or manual therapy to your offer? The STANDARD package includes ready-made informed consent forms for invasive procedures and record templates that protect you during an inspection or dispute. See FizjoReady packages →

Related articles:
- Medical records in physiotherapy -- which documents are mandatory?
- Physiotherapist liability insurance -- what you need to know
- KIF inspection at your practice -- what to expect and how to prepare