Virginia Regulatory Town Hall
Department of Education
State Board of Education
Guidance Document Change: The Model Policies for the Treatment of Transgender Students in Virginia’s Public Schools guidance document was developed in response to House Bill 145 and Senate Bill 161, enacted by the 2020 Virginia General Assembly, which directed the Virginia Department of Education to develop and make available to each school board model policies concerning the treatment of transgender students in public elementary and secondary schools. These guidelines address common issues regarding transgender students in accordance with evidence-based best practices and include information, guidance, procedures, and standards relating to: compliance with applicable nondiscrimination laws; maintenance of a safe and supportive learning environment free from discrimination and harassment for all students; prevention of and response to bullying and harassment; maintenance of student records; identification of students; protection of student privacy and the confidentiality of sensitive information; enforcement of sex-based dress codes; and student participation in sex-specific school activities, events, and use of school facilities.
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2/3/21  5:16 pm
Commenter: Dr. Paul S. Julienne (retired)

Concerns about scientific accuracy

While I surely support compassion and appropriate care for children who experience various kinds of gender dysphoria (e.g.,, I wish to register concern about the proposed model policy document.  It strikes me as a well-intentioned but misguided overreaction.  As a professional scientist, I would hope that before taking actions that seem to defy common sense (such as allowing boys and girls of school age to mix in bathrooms or even overnight accommodations according to self-selection criteria that can not be criticized), one would at least seek to have a model policy based on sound and noncontroversial science.  We are not at that point yet.  

Why do I say that this document and part of its reasoning are based on statements or principles that are not scientifically proven?  For example, the document asserts “Gender identity is considered an innate characteristic that most children declare by age five to six.”  This is not an uncontroversial scientific fact.  Rather, studies show that children who exhibit gender dysphoria will normally resolve that according to their sex assigned at birth in the majority of cases by the time of puberty.  This is stated, for example,  by Dr. Stephen Stathis, Child and Adolescent Psychiatrist, Children’s Health Hospital, Queensland, Australia, in this article,  The approach explained by Dr. Stathis and used in Queensland recognizes both the seriousness and the complexity of the problem and the need for a compassionate and scientifically and practically sound response to children who are affected by various gender-related situations.  No one solution suits all.

Furthermore, a 2018 article [Littman L (2018) Parent reports of adolescents and young adults perceived to show signs of a rapid onset of gender dysphoria. PLoS ONE 13(8): e0202330. doi:10.1371/journal.pone.0202330,] speaks of “… the possibility of a potential new subcategory of gender dysphoria (referred to as rapid-onset gender dysphoria) that has not yet been clinically validated and the possibility of social influences and maladaptive coping mechanisms. Parent-child conflict may also explain some of the findings. More research that includes data collection from AYAs, parents, clinicians, and third party informants is needed to further explore the roles of social influence, maladaptive coping mechanisms, parental approaches, and family dynamics in the development and duration of gender dysphoria in adolescents and young adults.”

Another 2018 article states “virtually nothing is known regarding adolescent-onset GD [gender dysphoria], its progression and factors that influence the completion of the developmental tasks of adolescence among young people with GD and/or transgender identity.” (Kaltiala-Heino R, Bergman H, Työläjärvi M, Frisén L. Gender dysphoria in adolescence: current perspectives. Adolesc Health Med Ther. 2018;9:31-41.  Published 2018 Mar 2. doi:10.2147/AHMT.S135432, available at

Gender and its dysphoria are very complex matters about which the science is not yet settled (the science in any case can not settle the inevitable philosophical questions concerning the very meaning of the terms themselves).  In particular, it is not clear to me that it is wisest that the child should be the one allowed to make the determination about gender identity.  Children are continually interacting in a variety of ways with other children, adults, family, teachers, and professionals.  This is a complex matrix in which children are situated, and identity is an emergent phenomenon arising from such a complex set of interactions. More than the child is involved in making this determination.

If I were to try to identify the most significant problem with the present document, it focuses too much on the particular child who has special needs with respect to gender issues and fails to account for the ways others need to be taken into account in dealing with that child’s issues.  I for one would have a problem in Virginia being a teacher in a public school under these guidelines since they defy common sense and I would have to be very critical of them, as stated above (but I have never been such a teacher).  I see these policies as potentially quite harmful to other children or to parents who do not agree with the principle of “fixing” a complex problem by an educational policy.  Yes, I do support the need for special care and compassionate treatment of children who experience any kind of gender dysphoria.  But the “cure” may be worse than the “problem.”  Consequently, I hope the Virginia Department of Education will truly listen to voices that do not share their perspective on these matters and revise this policy document accordingly.

CommentID: 95946