Conversion "therapy" is a blatant violation of the bioethical maxim primum non nocere ("first, do no harm"). Therapists and counselors are often called upon to apply reason analogous to the Hippocratic Oath in their practice, and scientific schemata involve: 1) self-reflection/suspension of implicit biases while examining existing empirical, peer-reviewed research for causative (v. correlative) statistical significance, then 2) establishing a professional opinion and courses of action guided by those study findings, standards of professional ethics, regulatory requirements, and statutory law. In this instance, we must demand that the VA Board of Counseling hold counselors and therapists to an objective regulatory standard which protects the health of their charges and adheres to scientific research findings: that conversion "therapy" does significant harm by subjecting its sufferers to unfounded condemnations meant to undermine esteem, impede self-realization, and incite self-harm. Who are the individuals advocating for such misapprehension and mistreatment of LGBTQIA+-identifying people by the counselors and therapists they have entrusted with their care? What is the goal of such LGBTQIA+ stigma? There is absolutely no credible research - experimental, observational, or otherwise - to support the insidious belief among endorsers of gendered oppression that an LGBTQIA+ "lifestyle" falls outside the realm of social "normality," nor that such personal identities hinder self-actualization. One might wonder if conversion cruelty proponents commenting on this forum who base their bigoted pluralistic ignorance on religious and political bias lack the necessary self-awareness to question or condemn many of the vile cruelties that blighted historic psychological diagnosis and medical treatment, such as forced assimilation, sterilization, or lobotomy. Pragmatically, omissions in regulatory language make room for ambiguity, misinterpretation, and misapplication. Eliminate ambiguity from regulatory language, ally with protective justice, and support 18 VAC 115-20, -30, -50, and -60.