In regards to regulation 18VAC125-20, I am opposed to this regulation as it is contrary to the established law and ignores significant evidence regarding the area it attempts to regulate. This regulation differs from other regulations in that the Board of Counseling Regulations does not forbid any other type of therapy nor do they prescribe a treatment approach for any other situation for which a person may come to counseling. The Board is not empowered to prescribe the interventions and direction of therapy, only the manner of practice. Furthermore, the regulation is not consistent with subsection 54.1-2969 of the Code of Virginia.