The Virginia Academy of Clinical Psychologists (VACP) respectfully opposes this petition for rulemaking.  There are already ample safeguards and procedures available through the legal and Judicial system such as subpoena duces tecum, sworn testimony, etc.   

The Courts cannot  be relied upon to grant discovery nor can the professional be relied upon to disclose the truth at trial. I have witnessed a professional who testifies quite often in various counties, be somewhat dishonest on the stand uder oath.  I have the transcripts to validate my point.

The public needs to be protected , more importantly children , need to be protected from unscrupulous professionals.

I respectfully disagree with Mr. Keeney. As a clinical psychologist, I think it appropriate to report recantations of abuse directly to DFS and to the court.  I do not take issue with incorporating additional safeguards.