Dear Virginia Board of Counseling,

The Trevor Project is proud to support the NOIRA regarding regulations 18VAC115-20, -30, -50, and -60, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed psychologists in Virginia.

The Trevor Project is the world’s largest suicide prevention and crisis intervention organization for LGBTQ (Lesbian, Gay, Bisexual, Transgender, Queer, and Questioning) young people. We work every day to save young lives by providing support through free and confidential suicide prevention and crisis intervention programs on platforms where young people spend their time: our 24/7 phone lifeline, chat, text, and soon-to-come integrations with social media platforms. We also run TrevorSpace, the world’s largest safe space social networking site for LGBTQ youth, and operate innovative education, research, and advocacy programs.

The Trevor Project’s 2019 National Survey on LGBTQ Mental Health, a cross-sectional national survey of LGBTQ youth across the United States, surveyed over 34,000 respondents, making it the largest survey of LGBTQ youth mental health ever conducted. This survey found that five percent of LGBTQ youth reported being subjected to conversion therapy (with approximately 2/3rds of LGBTQ youth reporting experiencing some effort to change their sexual orientation or gender identity). Given the frequency with which youth will not know to identify their experience of such pressure coming from a licensed professional as "conversion therapy," that five percent number should be viewed as a floor. The same survey found 42 percent of LGBTQ youth who underwent conversion therapy reported a suicide attempt in the past year. These individuals reported attempting suicide in the past 12 months more than twice the rate of their LGBTQ peers who did not report undergoing conversion therapy. 57 percent of transgender and nonbinary youth who have undergone conversion therapy reported a suicide attempt in the last year.

Far from being a relic of history, the practice of conversion therapy is active and ongoing in Virginia today. A 2018 study by the Williams Institute at the University of California, Los Angeles School of Law shows that nearly 700,000 LGBTQ adults have been subjected to conversion therapy, with 350,000 of them receiving the dangerous and discredited treatment as youth. That number grows by thousands each year as the Williams Institute estimates that nearly 57,000 LGBTQ youth will be subjected to conversion therapy in the next few years by either a religious or spiritual advisor. An estimated 20,000 LGBT youth currently ages 13 to 17 will undergo conversion therapy from a licensed healthcare professional before the age of 18. These are the youth this regulation would protect.

In the past year alone, The Trevor Project has been contacted by more than 2,500 young Virginians. Nationally, many of the young people that we serve are survivors of conversion therapy or have a credible fear that their family members will compel them to go through conversion therapy. Supervisors for The Trevor Project’s crisis services report that these issues come up regularly in conversation with youth coming to us for help, and as often as weekly. These impressions are borne out by data collected on TrevorLifeline, TrevorText, and TrevorChat, as our records show that since 2010 hundreds of contacts have reached out to The Trevor Project with specific concerns around this practice and terms like “conversion therapy,” “reparative therapy,” and “ex-gay” have appeared on our text-based platforms with disturbing frequency.

Some of these LGBTQ youth contact us because their parents are threatening to send them to conversion therapy. Others call us because they are in conversion therapy, it is not working, and their feelings of isolation and failure contribute to suicidal thoughts and behaviors. We’ve had youth reach out because friends or loved ones are being subjected to conversion therapy. And finally, young people have come to The Trevor Project in a state of profound distress because a someone they know has died by suicide during or after being subjected to conversion therapy.

As to questions raised by conversion therapy proponents about the constitutionality of protections for youth from these practices, policymakers can be assured that multiple federal courts—including the Third and Ninth U.S. Circuit Courts of Appeals—have upheld similar laws protecting youth from conversion therapy. The U.S. Supreme Court has also twice declined to hear appeals to positive federal court rulings upholding laws restricting conversion therapy. The power of states to regulate medical treatments, including professional therapy, to ensure the public’s health and safety is long established in Supreme Court precedent; indeed, it is a core purpose of professional licensing boards to regulate potentially dangerous medical treatments. Conversion therapy is no exception.

This policy does not restrict any protected First Amendment speech. It prohibits discredited treatments by state-licensed mental health care professionals. It does not apply to clergy or to individuals who provide religious instruction not selling these discredited practices in the public marketplace. It also does not prevent anyone from publishing, discussing, or advocating any viewpoints or beliefs regarding sexual orientation, gender identity, or anything else.

Despite these facts, conversion therapy proponents have suggested that dicta from NIFLA v. Becerra supports their oft-repeated and rejected claim that protecting youth from conversion therapy violates the free speech rights of licensed professionals. This is not the case, as NIFLA’s discussion of the professional speech doctrine has no effect on the constitutionality of conversion therapy bills. NIFLA concerned a California law that required licensed and unlicensed crisis pregnancy centers to post certain notices. By contrast, anti-conversion therapy policies regulate professional conduct, not professional speech, so the NIFLA case is inapplicable. In fact, in his opinion in NIFLA, Justice Thomas reaffirmed a distinction between professional speech and professional conduct, by explicitly stating that “under [the Supreme Court’s] precedents, States may regulate professional conduct, even though that conduct incidentally involves speech.”

Likewise, it is long established that the fundamental rights of parents do not include endangering their children by forcing them to undergo medical practices that have been rejected by the scientific community as discredited and harmful. The law already protects against other forms of child endangerment, and legal protections and professional guidance make it clear to parents that so-called “conversion therapy” is a dangerous and discredited practice that has no legitimate purpose. These regulations serve to protect parents from being taken advantage of by practitioners of conversion therapy who would attempt to cloak their actions with the legitimacy and authority of a state-issued license. 

Virginia law already prohibits discredited and unsafe practices by licensed therapists. This regulation would prevent licensed mental health providers in Virginia from performing conversion therapy with a patient under 18 years of age – nothing more, nothing less. The regulation will curb harmful practices known to produce lifelong damage to those who are subjected to them and help ensure the health and safety of LGBTQ youth.

For these reasons and on behalf of the youth who depend upon our services, The Trevor Project strongly supports the NOIRA regarding regulations 18VAC115-20, -30, -50, and -60. Thank you for your consideration of this importance regulation.

Sincerely,

Casey Pick
Senior Fellow for Advocacy & Government Affairs
The Trevor Project

Pseudoscience peddled by homophobes has no place in a licensed practitioner’s office. 

Conversion "therapy" is completely unacceptable and should be outlawed. Ban it now.

Conversion therapy, which seeks to change a person's sexual orientation, is an abusive, dangerous practice that must be banned in Virginia. Studies consistently show that the practice is harmful and entirely ignores legitimate medical practice, science and research. The only consistent outcome appears to be an increased risk of depression, anxiety and suicide in the patients subjected to it. The government of Virginia must act swiftly and decisively to ban this dangerous so-called therapy.

Conversion Therapy is a horrible practice and should be banned from all states.  It is nothing but a form of mental torture and abuse.  Time and again studies have proven that it is not only ineffective in its purpose, but that it is also harmful and leads to mental distress, depression, drug use, increased risk of STDs, and suicide attempts.  Being LGBTQ is not a disease that needs to be cured.  It is a natural state of being just as is being heterosexual and people should not be forced into torture for being one or the other.

Conversion therapy needs to be banned.  It is a dangerous practice that only serves to send people back into the closet.  It causes psychological damage that may take years to overcome. As the mother of 6, two of whom are LGBT+, I wholeheartedly support my kids and support the banning of conversion therapy. 

Dear Virginia Board of Counseling,

As a practicing Licensed Professional Counselor in the state of Virginia who has extensive experience in working with LGBT clients across the life span, I am writing to provide my strong support for the proposed NOIRA regulations 18VAC115-20, -30, -50, and -60 as essential to the protection of harm and in keeping with a practitioner’s ethical responsibility in best serving young clients in danger of potentially irreparable damage that often occurs when forced to undergo such ‘therapy.’

Conversion ‘therapy,’ sometimes referred to as “reparative therapy,” has no basis in the literature, and is in fact at odds with helpful and/or therapeutic practice. What is much more critical to the needs of those working to best understand their identity is affirming and accepting support in a non-directive [and non-coercive] manner that provides developmentally appropriate guidance and exploration of an individual’s understanding of sexuality and gender. ‘Conversion therapy’ does not support healthy growth and development, but instead as been shown to increase shame, depression, anxiety, social withdrawal, and suicidal thoughts, and is grounded in stigma, religious ideology, and misinformation. The American Counseling Association, the American Psychiatric Association, the American Psychological Association, the American Academy of Pediatrics, the American Association for Marriage and Family Therapy, and the National Association of Social Workers have all issued statements regarding the detrimental impact of such ‘therapeutic’ practice.

These guidelines provide further support and are upheld by current Virginia law prohibiting discredited and unsafe practices by licensed therapists. Minors, particularly LGBTQ+ minors, rely on the oversight of responsible, trained, licensed, and ethical practitioners in ensuring their safety and protecting them exposure to therapeutic practices that are damaging to their growth. These guidelines serve to fortify the existing laws and protections in place, and if anything, protect the ‘freedom’ of these clients and children that those opposed falsely accuse the guidelines of denying. In consulting with current clients, my statement here is not only grounded in professional knowledge and experience, but in the voices and stories of clients who have suffered due to a lack of such protections in the past. Thus, I wholeheartedly thank you for these guidelines and urge their adoption and implementation as soon as possible.

Sincerely,

Carrie Lynn Bailey, PhD, NCC, LPC

~~~~

Reference for Appropriate Therapeutic Responses to Sexual Orientation (APA, 2009):

https://www.apa.org/pi/lgbt/resources/therapeutic-response.pdf

Reference regarding Reparative Therapy/Conversion Therapy as a Significant and Serious Ethical Violation by the ACA Code of Ethics [2017]:

https://www.counseling.org/docs/default-source/resolutions/reparative-therapy-resoltution-letter--final.pdf?sfvrsn=d7ad512c_4

Position Statement from the National Association of Social Workers on Sexual Orientation Change Efforts and Conversion Therapy [2015]:

https://www.socialworkers.org/LinkClick.aspx?fileticket=IQYALknHU6s%3D&portalid=0

Report from the Substance Abuse and Mental Health Services Administration [SAMHSA] on Ending Conversion Therapy: Supporting and Affirming LGBTQ Youth [2015]:

https://www.socialworkers.org/LinkClick.aspx?fileticket=IQYALknHU6s%3D&portalid=0

Dear Virginia Board of Counseling,

Equality Virginia is pleased to support the NOIRA regarding regulations 18VAC115-20, -30, -50, and -60, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed counselors in Virginia. Equality Virginia is the leading advocacy organization in Virginia seeking equality for lesbian, gay, bisexual, and transgender people.

Conversion therapy, sometimes referred to as “reparative therapy,” “ex-gay therapy,” or “sexual orientation change efforts,” is a set of practices by mental health providers that seek to change an individual’s sexual orientation or gender identity. This includes efforts to change behaviors or to eliminate or reduce sexual or romantic attractions or feelings toward individuals of the same sex. Conversion therapy does not include psychotherapy that aims to provide acceptance, support, and understanding of clients or the facilitation of clients’ coping, social support, and identity exploration and development, including sexual orientation-neutral interventions to prevent or address unlawful conduct or unsafe sexual practices. Nor does it include counseling for a person seeking to transition from one gender to another.

There is no credible evidence that any type of psychotherapy can change a person’s sexual orientation or gender identity.  In fact, conversion therapy poses critical health risks to lesbian, gay, bisexual, transgender, and queer young people, including depression, shame, decreased self-esteem, social withdrawal, substance abuse, risky behavior, and even suicide. Nearly all the nation’s leading mental health associations, including the American Psychiatric Association, the American Psychological Association, the American Counseling Association, the National Association of Social Workers, and the American Academy of Pediatrics, and the American Association for Marriage and Family Therapy have examined conversion therapy and issued cautionary position statements on these practices.

Research shows that lesbian, gay, and bisexual (LGB) youth are 4 times more likely, and questioning youth are 3 times more likely to attempt suicide as their straight peers.^[1] Nearly half of young transgender people have seriously thought about taking their lives and one quarter report having made a suicide attempt.^[2]

The Trevor Project’s 2019 National Survey on LGBTQ Mental Health, a cross-sectional national survey of LGBTQ youth across the United States, surveyed over 34,000 respondents, making it is the largest survey of LGBTQ youth mental health ever conducted. This survey found that five percent of LGBTQ youth reported being subjected to conversion therapy (with approximately 2/3rds of LGBTQ youth reporting experiencing some effort to change their sexual orientation or gender identity). Given the frequency with which youth will not know to identify their experience of such pressure coming from a licensed professional as "conversion therapy," that five percent number should be viewed as a floor. The same survey found 42 percent of LGBTQ youth who underwent conversion therapy reported a suicide attempt in the past year. These individuals reported attempting suicide in the past 12 months more than twice the rate of their LGBTQ peers who did not report undergoing conversion therapy. 57 percent of transgender and nonbinary youth who have undergone conversion therapy reported a suicide attempt in the last year.

These findings echo that of a recent study by Caitlyn Ryan of the Family Acceptance Project. Young people who experience family rejection based on their sexual orientation, including being subjected to conversion therapy, face especially serious health risks. Research reveals that LGB young adults who report higher levels of family rejection during adolescence are 8.4 times more likely to report having attempted suicide, 5.9 times more likely to report high levels of depression, 3.4 times more likely to use illegal drugs, and 3.4 times more likely to report having engaged in unprotected sexual intercourse compared with peers from families that reported no or low levels of family rejection.^[3] 

Existing law provides for licensing and regulation of various mental health professionals, including physicians and surgeons, psychologists, marriage and family therapists, clinical social workers, and licensed professional counselors.^[4]

Virginia law already prohibits discredited and unsafe practices by licensed therapists.

This regulation would prevent licensed mental health providers in Virginia from performing conversion therapy with a patient under 18 years of age, regardless of the willingness of a parent or guardian to authorize such efforts. The regulation will curb harmful practices known to produce lifelong damage to those who are subjected to them and help ensure the health and safety of LGBTQ youth. We thank you for proposing this important regulation.

Sincerely,

Equality Virginia

Please ban conversion therapy. As a sister of a LBGQT sibling, ( who is living their best life) I fully support the banning of this unethical treatment modality. 

The Southeastern Virginia Atheists, Skeptics, & Humanists (SEVASH) are pleased to support the NOIRA regarding regulation 18VAC140-20, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed social workers in Virginia.

Conversion therapy, sometimes referred to as “reparative therapy,” “ex-gay therapy,” or “sexual orientation change efforts,” is a set of practices by mental health providers that seek to change an individual’s sexual orientation or gender identity. This includes efforts to change behaviors or to eliminate or reduce sexual or romantic attractions or feelings toward individuals of the same sex. Conversion therapy does not include psychotherapy that aims to provide acceptance, support, and understanding of clients or the facilitation of clients’ coping, social support, and identity exploration and development, including sexual orientation-neutral interventions to prevent or address unlawful conduct or unsafe sexual practices. Nor does it include counseling for a person seeking to transition from one gender to another.

There is no credible evidence that any type of psychotherapy can change a person’s sexual orientation or gender identity. In fact, conversion therapy poses critical health risks to lesbian, gay, bisexual, transgender, and queer young people, including depression, shame, decreased self-esteem, social withdrawal, substance abuse, risky behavior, and even suicide. Nearly all the nation’s leading mental health associations, including the American Psychiatric Association, the American Psychological Association, the American Counseling Association, the National Association of Social Workers, and the American Academy of Pediatrics, and the American Association for Marriage and Family Therapy have examined conversion therapy and issued cautionary position statements on these practices.

Research shows that lesbian, gay, and bisexual (LGB) youth are 4 times more likely, and questioning youth are 3 times more likely to attempt suicide as their straight peers. Nearly half of young transgender people have seriously thought about taking their lives and one quarter report having made a suicide attempt. Young people who experience family rejection based on their sexual orientation, including being subjected to conversion therapy, face especially serious health risks.

The Trevor Project’s 2019 National Survey on LGBTQ Mental Health, a cross-sectional national survey of LGBTQ youth across the United States, surveyed over 34,000 respondents, making it is the largest survey of LGBTQ youth mental health ever conducted. This survey found that five percent of LGBTQ youth reported being subjected to conversion therapy (with approximately 2/3rds of LGBTQ youth reporting experiencing some effort to change their sexual orientation or gender identity). Given the frequency with which youth will not know to identify their experience of such pressure coming from a licensed professional as "conversion therapy," that five percent number should be viewed as a floor. The same survey found42percentof LGBTQ youth who underwent conversion therapy reported a suicide attempt in the past year. These individuals reported attempting suicide in the past 12 months more than twice the rate of their LGBTQ peers who did not report undergoing conversion therapy. 57percentof transgender and non-binary youth who have undergone conversion therapy reported a suicide attempt in the last year.

These findings echo that of a recent study by Caitlyn Ryan of the Family Acceptance Project. Research reveals that LGB young adults who report higher levels of family rejection during adolescence are 8.4 times more likely to report having attempted suicide, 5.9 times more likely to report high levels of depression, 3.4 times more likely to use illegal drugs, and 3.4 times more likely to report having engaged in unprotected sexual intercourse compared with peers from families that reported no or low levels of family rejection.

Existing law provides for licensing and regulation of various mental health professionals, including physicians and surgeons, psychologists, marriage and family therapists, clinical social workers, and licensed professional counselors.

This regulation would prevent licensed mental health providers in Virginia from performing conversion therapy with a patient under 18 years of age, regardless of the willingness of a parent or guardian to authorize such efforts. The regulation will curb harmful practices known to produce lifelong damage to those who are subjected to them and help ensure the health and safety of LGBTQ youth. We thank you for proposing this important regulation.

Conversion Therapy is a horrible practice and should be banned from all states.  It is nothing but a form of mental torture and abuse.  Time and again studies have proven that it is not only ineffective in its purpose, but that it is also harmful and leads to mental distress, depression, drug use, increased risk of STDs, and suicide attempts.  Being LGBTQ is not a disease that needs to be cured.  It is a natural state of being just as is being heterosexual and people should not be forced into torture for being one or the other..

Conversion therapy is not really therapy and needs to be banned in all states.  It is not only not therapy, it is abusive and based on ignorance and hatred. This has no place in the therapeutic relationship. LGBTQ individuals have a higher rate of suicide and higher rate of suicidal ideation than their straight peer groups. This is so dangerous and needs to be banned.

I support the Board banning Conversion Therapy.  

I have worked with the LGBT community as a therapist on and off for the past 20 years, mainly helping trans men women make the transition. I have heard rumors of licensed counselors doing conversion therapy but have never been able to find one. In any event, there is enough damage that non-licensed individuals are doing to LGBT youth without having licensed counselors making it worse We need a clear statement banning the use of CT..

The current regulation presented by the board for consideration is unlike any other regulation issued by this board in both its scope and specificity.  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 the two primary ways.

1. The Board of Counseling Regulations do not forbid any other type of therapy.
2. The Board of Counseling Regulations do not prescribe a treatment approach for any other situation for which a person may come to counseling.

The regulations do not forbid Recovered Memory Therapy or Re-Birthing therapy even though these are universally established as harmful.  The board does not identify any other conditions in which it gives the direction of treatment to a therapist without allowing for individual professional judgement.  Furthermore, choosing the direction a clinician takes with a client is not within the scope of authority of the board.  The board is empowered to regulate the “manner” of practice not prescribe the interventions and direction of therapy.

The regulation is not consistent with the Code of Virginia.  Please refer to Code of Virginia.  (See below with intervening sections removed.)

§ 54.1-2969. Authority to consent to surgical and medical treatment of certain minors.  

E. A minor shall be deemed an adult for the purpose of consenting to:

4. Medical or health services needed in the case of outpatient care, treatment or rehabilitation for mental illness or emotional disturbance.

Minors are allowed to consent to mental health treatment.  This regulation would run counter to the Code of Virginia which has allowed that minors can consent to the mental health treatment they desire.  Under the proposed regulation a youth who was experiencing suicidal ideation due to transgender or homosexual thoughts could only be encouraged to act on them.  This completely disavows the right of the youth to seek and consent to treatment.  It also violates the principle of client directed therapy.  The regulation itself poses a danger to the life health and safety of children in Virginia.  Since the board is presuming to dictate a treatment approach, will the board be liable for negative outcomes such as suicide by those seeking help that were turned away?

            This regulation ignores significant evidence regarding gender identity and sexual orientation.  Transgender identification is documented as being unstable.  Experts have reported that the majority of youth that identify as transgender as teens will identify as their birth gender as adults.  However, not only does this regulation choose the direction of therapy, it mandates a direction opposite to the most likely trajectory. 

            The statement by the board references HB 363.  The statement fails to mention that the bill did not pass.  While an individual may have suggested regulation, the general assembly did not.  The general assembly chose not to legislate this.  This appears to be a flagrant work around to pass a restriction that the general assembly considered and rejected. 

            If the board is concerned about youth being forced into conversion therapy against their will, the board should pass regulations that prohibit treatment against the will of a client unless ordered by judicial order as already allowed in the Code of Virginia.  This would allow for protection from forced treatment while still upholding the rights of children in Virginia to seek the treatment they choose as already established in the Code of Virginia. 

§ 54.1-2969. Authority to consent to surgical and medical treatment of certain minors.  

E. A minor shall be deemed an adult for the purpose of consenting to:

4. Medical or health services needed in the case of outpatient care, treatment or rehabilitation for mental illness or emotional disturbance.

First off, please ignore the other comment with my name on it, I accidentally hit post before I was done typing.

 The NOIRA regarding regulation 18VAC125-20 is not something Virginians should support.  According to the Code of Virginia (see below) a minor can consent to mental health treatment if he or she wishes.

§ 54.1-2969. Authority to consent to surgical and medical treatment of certain minors.  

E. A minor shall be deemed an adult for the purpose of consenting to:

4. Medical or health services needed in the case of outpatient care, treatment or rehabilitation for mental illness or emotional disturbance.

Why is supposed "conversion therapy" the only type of therapy that the State wants to regulate? If the concern is for the safety of children who may be forced against their will into unwanted therapy, then that should be made illegal. This regulation, however, seeks to prevent "conversion therapy" even if it is sought after by the child.

If gender is indeed fluid, as supporters of this regulation purport, then why should homosexual and transgender people not be allowed to align their thoughts and feelings with their natural gender? I believe this is simply a ruse of LGBTQ+ supporters to ram affirmation, not just tolerance, down the throats of Virginians.

Under this proposed regulation, it would not help youth. You should bring a group of experience counselors together to help the committee understand the danger of this regulation. This regulation will violate the principle of patient therapy. This regulation will only put high risk youth at the center for suicidal ideation. This regulation has no place in patient direct therapy. 

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. 

Dear Virginia Board of Counseling,

Hello, my name is Carol Schall and I am writing in support of the NOIRA regarding regulation 18VAC125-20, on the Practice of Conversion Therapy, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed psychologists in Virginia.

As the mother of a young woman who struggles with anxiety, I know personally how debilitating dealing with mental health challenges can be. I also know that counselors should offer therapy to their patients that will reduce their suffering and certainly improve their overall mental health. Finally, I expect all counselors across Virginia to use research based practices that have evidence of providing help, not harm. These common sense requirements are not met when considering the practice of "so-called conversion therapy."

Conversion therapy, sometimes referred to as “reparative therapy,” “ex-gay therapy,” or “sexual orientation change efforts,” is a set of practices by mental health providers that seek to change an individual’s sexual orientation or gender identity. This includes efforts to change behaviors or to eliminate or reduce sexual or romantic attractions or feelings toward individuals of the same sex. Conversion therapy does not include psychotherapy that aims to provide acceptance, support, and understanding of clients or the facilitation of clients’ coping, social support, and identity exploration and development, including sexual orientation-neutral interventions to prevent or address unlawful conduct or unsafe sexual practices. Nor does it include counseling for a person seeking to transition from one gender to another.

There is no credible evidence that any type of psychotherapy can change a person’s sexual orientation or gender identity. In fact, conversion therapy poses critical health risks to lesbian, gay, bisexual, transgender, and queer young people, including depression, shame, decreased self-esteem, social withdrawal, substance abuse, risky behavior, and even suicide. Nearly all the nation’s leading mental health associations, including the American Psychiatric Association, the American Psychological Association, the American Counseling Association, the National Association of Social Workers, and the American Academy of Pediatrics, and the American Association for Marriage and Family Therapy have examined conversion therapy and issued cautionary position statements on these practices.

Research shows that lesbian, gay, and bisexual (LGB) youth are 4 times more likely, and questioning youth are 3 times more likely to attempt suicide as their straight peers. Nearly half of young transgender people have seriously thought about taking their lives and one quarter report having made a suicide attempt. Young people who experience family rejection based on their sexual orientation, including being subjected to conversion therapy, face especially serious health risks.

The Trevor Project’s 2019 National Survey on LGBTQ Mental Health, a cross-sectional national survey of LGBTQ youth across the United States, surveyed over 34,000 respondents, making it is the largest survey of LGBTQ youth mental health ever conducted. This survey found that five percent of LGBTQ youth reported being subjected to conversion therapy (with approximately 2/3rds of LGBTQ youth reporting experiencing some effort to change their sexual orientation or gender identity). Given the frequency with which youth will not know to identify their experience of such pressure coming from a licensed professional as "conversion therapy," that five percent number should be viewed as a floor. The same survey found 42 percent of LGBTQ youth who underwent conversion therapy reported a suicide attempt in the past year. These individuals reported attempting suicide in the past 12 months more than twice the rate of their LGBTQ peers who did not report undergoing conversion therapy. 57 percent of transgender and nonbinary youth who have undergone conversion therapy reported a suicide attempt in the last year.

These findings echo that of a recent study by Caitlyn Ryan of the Family Acceptance Project. Research reveals that LGB young adults who report higher levels of family rejection during adolescence are 8.4 times more likely to report having attempted suicide, 5.9 times more likely to report high levels of depression, 3.4 times more likely to use illegal drugs, and 3.4 times more likely to report having engaged in unprotected sexual intercourse compared with peers from families that reported no or low levels of family rejection.

Existing law provides for licensing and regulation of various mental health professionals, including physicians and surgeons, psychologists, marriage and family therapists, clinical social workers, and licensed professional counselors.

This regulation would prevent licensed mental health providers in Virginia from performing conversion therapy with a patient under 18 years of age, regardless of the willingness of a parent or guardian to authorize such efforts. The regulation will curb harmful practices known to produce lifelong damage to those who are subjected to them and help ensure the health and safety of LGBTQ youth. We thank you for proposing this important regulation.

Sincerely,

Carol M. Schall Ph. D.

Dear Virginia Board of Counseling,

On March 28, 2019, the Virginia Catholic Conference -- the public policy agency representing Virginia’s Catholic bishops and their two dioceses -- submitted comments opposing a vague and broadly-worded Guidance Document (115-10) that seeks to prohibit, for minors, “any practice or treatment that seeks to change an individual’s sexual orientation or gender identity, including efforts to change behaviors or gender expressions or to eliminate or reduce sexual or romantic attractions or feelings toward individuals of any gender.”

As we noted in our comments, such a ban would infringe:

• the fundamental rights of parents to care for their children;
• Freedom of Speech and Free Exercise of Religion under the First Amendment; and
• Limits on regulatory authority that ensure consistency with the General Assembly’s decisions.

None of these concerns were rectified or even addressed in the final version of Guidance Document 115-10. In fact, the Board did not make any changes to the proposed Guidance Document based on concerns raised by any member of the public, even though it received 371 comments against the Guidance Document and only 198 for it. Moreover, the Board merely adopted the original version without any amendments. Because the Board is now seeking to amend Virginia’s regulations to conform them to the sweeping provisions of this Guidance Document, we reiterate these concerns.

When minors have unwanted same-sex or mixed-sex attractions, they and their families should be free to seek counseling toward the resolutions they desire. Licensed professionals with years of education and experience should not be removed from the process of helping children work through these sensitive and deeply personal issues.

The Conference, therefore, opposes adding the provisions of Guidance Document 115-10 to 18VAC115-20,-30,-50,-60.

Sincerely,

Jeffrey F. Caruso

Executive Director, Virginia Catholic Conference

I am absolutely opposed to this regulation.  The Board of Professional Counseling should never be allowed to dictate the course of action that a counselor should take for the best interest of their client, no matter what age.  Why is the board specifically targeting this kind of treatment?????

Dear Sir/Madam: I understand you are moving forward with a proposal to ban, for minors, “any practice or treatment that seeks to change an individual’s sexual orientation or gender identity, including efforts to change behaviors or gender expressions or to… reduce sexual or romantic attractions or feelings toward individuals of any gender.”  As a parent, this concerns me regarding advice I may give to my child and our religious liberty to teach our children according to the sexual ethics of the Catholic Church, which we whole-heartedly believe in and believe ultimately allows for the greatest human flourishing and happiness. 

In addition, I think it is only fair to children, since most who experience gender dysphoria experience it only temporarily, to not prohibit counselors and therapists from working with a child in keeping with his/her values and religious beliefs. Allowing professionals to counsel a child in the direction that seems best for this child, even if that is not acting on sexual impulses or not altering their gender identity from biological identity - advice cannot reasonably be mandated to only advise in one direction, how can one answer be best for every child that comes in for therapy or counseling? 

Finally, I deeply believe all persons who identify as LGBTQ are entitled to our respect and equal treatment under the law and in practice, my views here are not in any way meant to make someone feel belittled or unwanted. Rather, I disagree that banning professionals and parents from being able to discuss sexual behaviors and ethics in keeping with Christian ethics is inherently bad for children. In fact, I think the opposite provided it is done respectfully and in love. I hope you will reconsider pushing this ban through and that all of us can continue dialoguing on these issues respectfully. 

Sincerely,

Melissa Swearingen 

This ban is misguided and unconstitutional.

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
   
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• Licensed professionals with years of education and experience should not be removed from the process of helping children work through these sensitive and deeply personal issues. 

This regulatory action is misguided and unnecessary.  In Virginia, parents have the right to select the counseling and moral direction that they want for their children, not some anonymous board somewhere.  Many families want to guide their children in the direction of their Faith of choice, so do not Remove this right from parents.  This is morally wrong.

Let parents have the freedom to raise their children in the best way they can.  The government should not be interfering.  

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• Licensed professionals with years of education and experience should not be removed from the process of helping children work through these sensitive and deeply personal issues. 

Parents are the primary educators and care givers of their children, responsible for their upbringing and instilling moral values in them according to their religious beliefs.  Please oppose the imposition of regulations over what counselors may discuss with children.  Unelected government officials and outsiders with a political agenda should not be able to regulate the content and conduct of counseling, or decide what parents may or may not do regarding their children.

I agree with the comments made by the Virginia Catholic Conference opposing the proposed amendment of 18VAC125-20 regulations governing the practice of psychology. 

I am a mother and grandmother.  I know how fluid sexual identity can be at various points in a young person's life.  A ban of so-called  "Conversion therapy" denies young people access to all points of view and credible adult voices that help to guide them in their difficult journey.  This proposal is unconstitutional--Virginia cannot prevent anyone from offering advice that is pro-gay or pro-trans and should not also attempt to ban counselors, educators, parents or other people from offering sane and judicious advice to any person who believes he or she is gay or transsexual.  Parents and families, friends and helpful professionals not the overarching state government are the ones who should decide what type of care any minor child needs to grow into a happy and healthy adult.  No law, no regulation to prevent this--period! 

• 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 

Oppose proposed amendment of 18 VAC 125-20

It is in the best interest of children to be cared for and guided by their parents. The family is the most critical part of a society. Government should not interfere with a parents guidance of their children. Children are particularly vulnerable in our over-sexed society and need the loving guidance of their parents to help them understand love and dignity of their sexuality.

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
   
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• Licensed professionals with years of education and experience should not be removed from the process of helping children work through these sensitive and deeply personal issues. 

We the people have the God-given right to determine what laws and regulations control our behavior as law-abiding citizens, including parental rights to teach the truth to our children and grandchildren. The regulatory action being considered violates these rights and is opposed to common sense for the following reasons:

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the well being of their child.
   
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• Licensed professionals with years of education and experience should not be removed from the process of helping children work through these sensitive and deeply personal issues. 

For these reasons, the subject regulatory actions are illegal and unconstitutional.

Please listen to the will of the people and desist from these actions.

Respectfully,

John and Joan Fittz

Parents have the fundamental right to make decisions for their children until they become adults in their own right. The proposed ban would deny families the freedom to seek counseling aligned with their faith.

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
• Licensed professionals with years of education and experience should not be removed from the process of helping children work through these sensitive and deeply personal issues. 

.

Parental rights are mine - not those of an unelected individual or group.

Parents are closest to their children's challenges, we are in the best position to make healthcare decision involving the well-being of our children.

By Virginia law parents have the fundamental right to make decisions regarding the upbringing, education and care of our children.

Licensed professionals with years of experience should not be removed from the process of helping children work through these deeply personal and sensitive issues.

Stop the ban and defend the freedom and rights of parenthood.

Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the well-being of their child.
Parents have the fundamental right to make decisions regarding the upbringing, education and care of their children.  This must not be changed; if it is tampered with, where/when will it stop.  Being a preteen and teenager has always been a confusing time, but they are not adults yet; they need unhindered, loving guidance from their parents. 

Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. The proposed ban would deny families the freedom to seek counseling aligned with their values and/or faith.

I am absolutely opposed to any attempt to limit or ban parental involvement with respect to their minor's sexual identity or conversion therapy.

Parents are closest to their child's challenges.  They are in the best position to make healthcare decisions involving the wellbeing of their child.

Under Virginia law parents have the fundamental right to make decisions regarding the upbringing, education, and care of their children.

Some young people may have attractions they may desire to change or moderate.  Others may simply desire guidance from a counselor to live a chaste life.  In either instance, there should be options for families to make informed decisions.

The proposed ban would deny families the freedom to seek counseling aligned with their faith.

Licensed professionals with years of experience should not be removed from the process of helping children working through these sensitive and deeply personal issues.

I ask that you not impose a policy that is contrary to the specific wishes of the Virginia legislature in these areas.  Support the involvement of parents over their children.

The rights of parents to make decisions on behalf of their children must never be sabotaged by a Planned Parenthood agenda or by radical transgender politics. We must keep Governor appointed state regulators out of the business of destroying families and undermining parental rights by forcing an immoral, radical and unscientific ideology on the sacred family unit.

Parents are closes to their child's challenges, they are in the best position to make health care decisions involving the well being of their child

The parents' rights and responsibilities for their children should not be usurped by the state.  What we nee in this day and age is stronger family morals.

Oppose adding the provisions of Guidance Document 115-10 to 18VAC115-20,-30,-50,-60.

I oppose adding the provisions of Guidance Document 115-10 to 18 VAC 115-20, -30, -50, -60 and respectfully ask you to reject it too.

This proposal would infringe the fundamental right of parents to care for their children and violate their freedom of speech and free exercise of religion.

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
   
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• Licensed professionals with years of education and experience should not be removed from the process of helping children work through these sensitive and deeply personal issues.