I urge the Advisory Board on Genetic Counseling to promulgate rules directing that the scope of practice of genetic counselors be consistent with standards articulated by the American Board of Genetic Counseling. We at Falls Church Healthcare Center (FCHC), a faith based, community women’s center, often as part of our pre-conception or post-miscarriage healthcare, refer our patients for genetic testing or to genetic counselors. So we are following the current rulemaking for the licensure of genetic counselors that is before you now. As a result of the enabling legislation, a state-licensed genetic counselor will be able to deny counseling to any patient simply because the patient may want to take an action with which the counselor doesn’t personally agree; is of a different religious faith; is unmarried and pregnant or is lesbian or gay, etc. This legislation is so extreme that it will shield a genetic counselor from damages even if the counselor took purposeful action based on his or her personal beliefs and it resulted in the patient’s physical harm or death. Only your rulemaking can ensure the legislation is implemented in a way that ensures patients safety and health and ensures patients can trust and rely on genetic counselors to provide ALL the information they need. Do not enable terrible legislation.

The Board of Medicine and Department of Health Professions and we at FCHC recognize that patients rely on genetic counselors’ counseling and referrals to help patients cope with difficult implications related to genetic testing. Many of these decisions may be related to controversial political and moral issues. Patients must be able to rely on genetic counselors to provide medically sound and unbiased options and to protect patient privacy.

The Advisory Board and the rules you promulgate should include:

• Rules based on the highest standards of professional competence, and on the values of care and respect for the patient’s autonomy, individuality, welfare, and freedom
• Incorporate the Code of Ethics of the National Society of Genetic Counselors in its rules for the standards of professional conduct for genetic counselors.
• Recognize that time is of the essence in genetic counseling and testing services thus:
  1. Articulate with specificity what constitutes a reasonable time period for the genetic counselor to inform the patient of the counselor’s refusal to discuss certain options of genetic counseling
  2. Articulate what constitutes a reasonable time period for the genetic counselor to inform the prospective client and patient of the counselor’s refusal.
  3. Articulate what constitutes a genetic counselor’s limits on scope of practice due to moral or religious reason
  4. Articulate the time period for referral to the online directory of genetic counselors maintained by the Board
  5. Articulate how the genetic counselor will accommodate the legal requirement for referral when the patient cannot reasonably obtain access to the online directory

Thank you for your attention and your service to the public health and patient care of Virginians.