Treatment of spinal tissue

A method of treating an intervertebral disc without piercing the disc involves navigating a treatment element to the intervertebral disc and contacting the treatment element with an exterior of the intervertebral disc. The method further involves applying an energy-based treatment to the exterior of the intervertebral disc to modify a property of a target tissue of the intervertebral disc. The target tissue may be, for example, annulus fibrosus and/or nucleus pulposus tissue. The treatment element is then removed, and the property remains modified after the treatment element is removed and the target tissue heals, thereby treating the intervertebral disc.