To the Virginia Board of Medicine and Department of Health Professions,

As a physician, I support legislation for the licensure of genetic counselors within the highest standards of medical responsibility.  The refusal clause, as currently stated, allows a counselor to withhold full/accurate information based on personally held beliefs and while requiring disclosure of counseling refusal, does not explicitly state a reasonable time period for this disclosure or for referral.  This could significantly impact patient care.

For these and other reasons, 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:

1. 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 

2. 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 

3. 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.  

Thank you for your consideration,

Frances Casey, MD, MPH