During my training as a reproductive biologist at the Johns Hopkins Bloomberg School of Public Health, I collaborated with a team of genetic counselors at the Berman Institute Bioethics to explore a multitude of ethical challenges that we face as public health practitioners. A common theme of our discussions was the necessity for oversight and guidelines to ensure responsible practice.  
 
As an OB/GYN in training, I continue to work alongside genetic counselors and acknowledge the benefits of a licensure protocol that is 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. However, a “refusal clause” written into an otherwise harmless legislation to license genetic counselors will allow genetic counselors to refuse service to patients based on “deeply held moral or religious beliefs” and will shield those same counselors from damages. As a direct result of this legislation, a state-licensed genetic counselor will be able to deny counseling to any patient simply because: the patient is lesbian or gay, is of a different religious faith, is unmarried and pregnant or the person may want to take an action with which the counselor doesn’t personally agree, as some examples. Moreover, 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 that results in actual physical harm or death to the patient.
 
In obstetrics & gynecology, I realize that many of my colleagues will make the personal decision to not provide abortions to patients in need. And while these conscientious objectors are not unfamiliar to the field of medicine, it is paramount to the safety and well being of our patients that protective measure and oversight are in place. In the case of fetal anomalies, individuals are often faced with serious and time sensitive decisions. In order to maintain the ethical responsibility to our patients, conscientious objection can only take place when adequate referrals systems are in place or another counselor is readily available. A blanket statement that genetic counselors can refuse to counsel a patient without appropriate guidelines is tantamount to malpractice.  
 
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. Moreover, I urge the Advisory Board to incorporate the Code of Ethics of the National Society of Genetic Counselors in its rules for the standards of professional conduct for genetic counselors. In addition, the Advisory Board should articulate with specificity: what constitutes a reasonable time period for the genetic counselor to inform his or her prospective and existing client of his or her refusal to participate in certain genetic counseling; what constitutes a reasonable time period by which the genetic counselor, upon refusal to counsel his or her patient due to moral or religious reasons, will refer his or her patient to the online directory of genetic counselors maintained by the Board; and finally, how the genetic counselor will accommodate the legal requirement for referral when the patient does not have, or cannot reasonably obtain, access to the online directory of genetic counselors maintained by the Board.  
 
Respectfully submitted,
Brent Monseur Sc.M.
Medical Students for Choice, Board of Directors
VCU School of Medicine M.D. Candidate ‘16