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IntroducedHB26-10422026 Regular Session

A New Way to Treat Pain: Occupational Therapists Could Soon Offer Dry Needling in Colorado

Sponsors: Lisa Feret, Brandi Bradley, Matt Ball·Health & Human Services·

Editorial photograph for HB26-1042

Illustration: Assembly Required

The Bottom Line

If you're recovering from an injury or dealing with chronic pain, your occupational therapist might soon have a powerful new tool in their kit. This bill allows licensed occupational therapists to perform dry needling—a muscle-targeting treatment that relieves pain and improves movement—saving you the hassle and cost of getting referred to a separate physical therapist or acupuncturist.

What This Bill Actually Does

To understand this bill, it helps to understand the treatment. Dry needling involves inserting thin, solid needles (similar to those used in acupuncture) directly into myofascial trigger points. It is designed to release tight muscle bands, relieve pain, and improve range of motion. Currently in Colorado, physical therapists and acupuncturists can legally perform dry needling, but occupational therapists (OTs)—who often treat the exact same types of musculoskeletal injuries—cannot.

House Bill 26-1042 changes that. Starting September 1, 2027, the bill officially authorizes licensed occupational therapists to perform dry needling on their patients. But the state isn't just handing out needles to anyone with an OT license. The bill builds in strict guardrails to ensure patient safety. An occupational therapist must prove they have the knowledge, skill, and documented competency to perform the procedure. They must also successfully complete a rigorous dry needling course that meets specific educational and clinical prerequisites.

To ensure standards remain high, the bill tasks the Department of Regulatory Agencies (DORA) with writing the official rules for this new authority by June 1, 2027. The legislation explicitly mandates that these new rules must be just as strict as the requirements already in place for physical therapists. Before finalizing anything, DORA's director must also consult with the Colorado Medical Board. Finally, the bill requires occupational therapists to get written informed consent from every single patient. This paperwork must clearly explain the potential benefits and risks of the procedure, and it must include a specific legal disclaimer stating that the occupational therapist is not a licensed acupuncturist.

What It Means for You

If you've ever dealt with a frozen shoulder, severe carpal tunnel syndrome, or a nagging sports injury, you know how crucial occupational therapy is for getting your daily life back on track. Right now, if your OT evaluates you and decides that dry needling would perfectly complement your rehabilitation plan, their hands are tied. They have to refer you out to a physical therapist or an acupuncturist. For you, that means scheduling another appointment, driving across town, paying an additional specialist copay, and trying to coordinate communication between two different healthcare providers.

If HB26-1042 becomes law, you will eventually be able to get this treatment right in your normal OT session. That is a massive win for your wallet and your calendar. By keeping your care under one roof, you streamline your recovery process. However, you will need to be a little patient. Even though the bill is moving quickly this year, the actual authority to perform dry needling doesn't kick in until September 1, 2027. The state needs that gap year to finalize the safety rules and give occupational therapists time to complete their required continuing education courses.

Here are a few concrete steps you can take to prepare for this shift in healthcare access:

  • Talk to your provider: If you are currently receiving occupational therapy, ask your therapist if they plan to pursue dry needling certification once the state finalizes the rules next year.
  • Check your insurance coverage: Dry needling coverage varies wildly depending on your health plan. Call your insurance provider to find out if they cover the procedure under standard occupational therapy billing codes, or if it requires out-of-pocket payment.
  • Track your medical expenses: If you currently pay out-of-pocket for separate acupuncture or physical therapy sessions just for dry needling, calculate what you spend annually so you can budget for consolidating that care with your OT in late 2027.

What It Means for Your Business

For healthcare administrators, clinic owners, and independent occupational therapists, this legislation represents a significant service expansion opportunity. If you run a standalone occupational therapy clinic, you have historically had to refer out patients who needed dry needling, effectively handing revenue over to competing physical therapy practices. If you run a multidisciplinary practice that employs both PTs and OTs, this bill levels the playing field among your staff, allowing for more flexible patient scheduling and cross-coverage.

However, unlocking this new revenue stream will require careful compliance planning. The state is mandating strict oversight. By June 1, 2027, DORA will release the finalized supervisorial, educational, and clinical prerequisites. You will need to budget for your staff to take these continuing education courses, which can be expensive and require time away from the clinic. You will also need to completely overhaul your patient intake paperwork. The law requires a very specific written informed consent document that outlines risks, benefits, and explicitly states the provider is not an acupuncturist. Failing to include that exact phrasing could expose your clinic to disciplinary action.

Here are the action items clinic owners should prioritize to stay ahead of the curve:

  • Audit your staff's interest: Survey your occupational therapists this week to find out who actually wants to perform dry needling. Use this headcount to forecast continuing education costs and travel budgets for late 2026 and early 2027.
  • Review your malpractice policy: Call your commercial insurance broker and ask how adding dry needling to your OTs' scope of practice will impact your liability premiums. You want to price this into your operating budget now.
  • Draft a mock consent form: Start outlining the required informed consent document based on the bill's language. Having a template ready will prevent a last-minute scramble when the final DORA rules drop next year.

Follow the Money

This is one of those rare pieces of healthcare legislation that won't cost Colorado taxpayers a single dime. According to the nonpartisan Legislative Council Staff fiscal note, HB26-1042 requires no state appropriation.

The Department of Regulatory Agencies (DORA) will experience a slight bump in their administrative workload to draft the new rules, conduct public outreach, and process any future patient complaints. However, because DORA already regulates occupational therapists and already manages dry needling rules for physical therapists, they can absorb this extra work using their existing budget. The state might see a tiny trickle of new revenue if an occupational therapist is fined for a disciplinary infraction down the road, but state analysts assume licensed professionals will overwhelmingly comply with the law. For local governments, school districts, and general taxpayers, the financial impact is exactly zero.

Where This Bill Stands

HB26-1042 is sailing through the legislative process with zero friction. Introduced in mid-January by Representatives Lisa Feret and Brandi Bradley, the bill easily cleared the House Health & Human Services committee. On February 18, 2026, it passed the full House of Representatives on its third reading without a single amendment—a strong indicator of broad, bipartisan consensus.

The bill now heads to the Senate, where it is being sponsored by Senator Matt Ball. Given the complete lack of organized opposition, the zero-dollar fiscal note, and the fact that it perfectly mirrors existing physical therapy laws, this bill is on a glide path. Expect it to clear the Senate quickly and land on the Governor's desk well before the legislative session adjourns in May.

The Opportunity Signal

Where this bill creates practical upside for operators: the opening, the key constraints, and the move to make while the window is still favorable.

  • In-Clinic Dry Needling Service Launch

    Licensed occupational therapy clinics and independent OTs in Colorado can significantly expand their service offerings by incorporating dry needling. This allows them to treat a broader range of musculoskeletal conditions in-house, retaining revenue previously lost to referrals to physical therapists or acupuncturists. The timing is critical now to prepare for the September 2027 rollout, requiring upfront investment in staff training and compliance updates, but offering a competitive edge and increased patient convenience. The primary execution risk lies in ensuring full compliance with stringent DORA regulations and potential variations in insurance reimbursement policies for the new service.

    • New authority for OTs to perform dry needling becomes effective September 1, 2027.
    • Requires OTs to complete a rigorous, DORA-approved dry needling course and demonstrate competency.
    • Mandatory written informed consent forms, including a specific disclaimer, must be used for every patient.
    • DORA rules regarding educational, clinical, and supervisorial prerequisites will be finalized by June 1, 2027.

    Next move: By late 2026, survey your current occupational therapists on interest and willingness to complete the required dry needling certification, and begin budgeting for continuing education courses and potential increases in malpractice premiums.

  • Professional Dry Needling Certification Program Development

    Educational institutions, professional associations, or specialized training companies have a significant opportunity to develop and offer the mandatory dry needling certification courses required for Colorado OTs. With a clear implementation date of September 2027, hundreds of OTs will seek this training as soon as the Department of Regulatory Agencies (DORA) finalizes its requirements. Success hinges on quickly aligning curricula with DORA's forthcoming strict standards, which must mirror those for physical therapists, and securing any necessary state or professional recognition for the program. This is a time-sensitive opportunity to become a leading provider in a new, mandated professional development market.

    • DORA will release specific educational and clinical prerequisites for OT dry needling training by June 1, 2027.
    • Courses must be 'rigorous' and ensure OTs have documented competency in the procedure.
    • The training standards will be comparable to the strict requirements already in place for physical therapists.
    • A large pool of licensed occupational therapists in Colorado will need to complete this training within a short window.

    Next move: By June 2027, review the finalized DORA rules for OT dry needling education requirements and begin curriculum development to align with these standards, aiming for program launch in late 2027.

  • OT Clinic Compliance and Consent Form Consulting

    Legal firms and specialized healthcare compliance consultants can offer critical services to occupational therapy practices preparing for the new dry needling authority. This includes drafting or reviewing the mandatory, highly specific written informed consent forms, updating patient intake procedures, and advising on adherence to DORA's forthcoming rules regarding supervision, documentation, and patient communication. With clear deadlines for rule finalization (June 2027) and implementation (September 2027), clinics will need expert guidance to navigate the new regulatory landscape and avoid potential disciplinary actions. The market opportunity arises from practices needing to comply with new, strict regulations quickly.

    • DORA will finalize strict new rules for OT dry needling by June 1, 2027.
    • A mandatory, specific written informed consent form, including a legal disclaimer, is required for every patient.
    • Compliance standards will be 'just as strict' as those currently in place for physical therapists.
    • Non-compliance with consent or procedural rules could expose clinics to disciplinary action.

    Next move: By September 2027, develop a templated, customizable written informed consent document for Colorado OT practices, ensuring it explicitly incorporates the bill's requirements and anticipates DORA's forthcoming strict rules.

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Frequently Asked Questions

What does HB26-1042 do?
This bill allows occupational therapists in Colorado to perform dry needling on their patients starting in September 2027. To do this, the therapist must complete specific training and have patients sign a consent form that explains the risks and clarifies the therapist is not an acupuncturist. It essentially gives patients another option for receiving dry needling treatments.
What is the current status of HB26-1042?
HB26-1042 is currently "Introduced" in the 2026 Regular Session. It was introduced by Rep. L. Feret and is assigned to the Health & Human Services committee.
Who sponsors HB26-1042?
HB26-1042 is sponsored by Lisa Feret, Brandi Bradley, Matt Ball.
How does HB26-1042 affect Colorado businesses?
Licensed occupational therapy clinics and independent OTs in Colorado can significantly expand their service offerings by incorporating dry needling. This allows them to treat a broader range of musculoskeletal conditions in-house, retaining revenue previously lost to referrals to physical therapists or acupuncturists. The timing is critical now to prepare for the September 2027 rollout, requiring upfront investment in staff training and compliance updates, but offering a competitive edge and increased patient convenience. The primary execution risk lies in ensuring full compliance with stringent DORA regulations and potential variations in insurance reimbursement policies for the new service. Educational institutions, professional associations, or specialized training companies have a significant opportunity to develop and offer the mandatory dry needling certification courses required for Colorado OTs. With a clear implementation date of September 2027, hundreds of OTs will seek this training as soon as the Department of Regulatory Agencies (DORA) finalizes its requirements. Success hinges on quickly aligning curricula with DORA's forthcoming strict standards, which must mirror those for physical therapists, and securing any necessary state or professional recognition for the program. This is a time-sensitive opportunity to become a leading provider in a new, mandated professional development market. Legal firms and specialized healthcare compliance consultants can offer critical services to occupational therapy practices preparing for the new dry needling authority. This includes drafting or reviewing the mandatory, highly specific written informed consent forms, updating patient intake procedures, and advising on adherence to DORA's forthcoming rules regarding supervision, documentation, and patient communication. With clear deadlines for rule finalization (June 2027) and implementation (September 2027), clinics will need expert guidance to navigate the new regulatory landscape and avoid potential disciplinary actions. The market opportunity arises from practices needing to comply with new, strict regulations quickly.
What committee is reviewing HB26-1042?
HB26-1042 is assigned to the Health & Human Services committee in the Colorado House.
When was HB26-1042 last updated?
The last action on HB26-1042 was "Introduced In Senate - Assigned to Health & Human Services" on 02/20/2026.

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