I support the petitioner's requests that regulations be amended to 1) define invasive procedure and 2) further define the practice of pelvic floor therapy (PFT) as a noninvasive procedure.  Current regulations state solely that dry needling is an invasive procedure but does not indicate what actually constitutes an invasive procedure.  The proposal seeks not only to demonstrate how a procedure is determined to be invasive but also explicitly categorizes PFT as noninvasive (as is implied under current regulations).