Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Unprofessional conduct - conversion therapy
Comment Period Ended on 8/7/2019
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8/1/19  10:23 pm
Commenter: Amanda Darvill, American Foundation for Suicide Prevention, NCAC

Support for the NOIRA regarding regulations on the Practice of Conv

Dear Virginia Board of Counseling,

Hello, my name is Amanda Darvill and I am writing in support of the NOIRA regarding
regulations 18VAC115-20, -30, -50, and -60, on the Practice of Conversion Therapy,
which would protect youth under the age of 18 from so-called “conversion therapy” at the
hands of licensed counselors in Virginia.

No one should ever be told that they were made anything but perfect. Yet, young
lesbian, gay, bisexual, transgender, and queer people are often told that they
need to change who they are—or face a life full of rejection by their family, their
faith, and God. We need to embrace all people, and that means not turning our
backs when we see one of our own being singled out and targeted. As caring
Christians, it is our responsibility to ensure the safety of our children. We cannot
lose one more of our own to the depression and suicide these discredited and
damaging practices so often lead to.

Conversion therapy, sometimes referred to as “reparative therapy,” “ex-gay therapy,” or
“sexual orientation change efforts,” is a set of practices by mental health providers that
seek to change an individual’s sexual orientation or gender identity. This includes efforts
to change behaviors or to eliminate or reduce sexual or romantic attractions or feelings
toward individuals of the same sex. Conversion therapy does not include psychotherapy
that aims to provide acceptance, support, and understanding of clients or the facilitation
of clients’ coping, social support, and identity exploration and development, including
sexual orientation-neutral interventions to prevent or address unlawful conduct or unsafe
sexual practices. Nor does it include counseling for a person seeking to transition from
one gender to another.

There is no credible evidence that any type of psychotherapy can change a person’s
sexual orientation or gender identity. In fact, conversion therapy poses critical health
risks to lesbian, gay, bisexual, transgender, and queer young people, including
depression, shame, decreased self-esteem, social withdrawal, substance abuse, risky
behavior, and even suicide. Nearly all the nation’s leading mental health associations,
including the American Psychiatric Association, the American Psychological
Association, the American Counseling Association, the National Association of Social
Workers, and the American Academy of Pediatrics, and the American Association for
Marriage and Family Therapy have examined conversion therapy and issued cautionary
position statements on these practices.

Research shows that lesbian, gay, and bisexual (LGB) youth are 4 times more likely, and
questioning youth are 3 times more likely to attempt suicide as their straight peers.
Nearly half of young transgender people have seriously thought about taking their lives
and one quarter report having made a suicide attempt. Young people who experience
family rejection based on their sexual orientation, including being subjected to
conversion therapy, face especially serious health risks.

The Trevor Project’s 2019 National Survey on LGBTQ Mental Health, a cross-sectional
national survey of LGBTQ youth across the United States, surveyed over 34,000
respondents, making it is the largest survey of LGBTQ youth mental health ever
conducted. This survey found that five percent of LGBTQ youth reported being subjected
to conversion therapy (with approximately 2/3rds of LGBTQ youth reporting experiencing some effort to change their sexual orientation or gender identity). Given the
frequency with which youth will not know to identify their experience of such pressure
coming from a licensed professional as "conversion therapy," that five percent number should be viewed as a floor. The same survey found 42 percent of LGBTQ youth who underwent conversion therapy reported a suicide attempt in the past year. These
individuals reported attempting suicide in the past 12 months more than twice the rate of
their LGBTQ peers who did not report undergoing conversion therapy. 57 percent of
transgender and nonbinary youth who have undergone conversion therapy reported a
suicide attempt in the last year.

These findings echo that of a recent study by Caitlyn Ryan of the Family Acceptance
Project. Research reveals that LGB young adults who report higher levels of family
rejection during adolescence are 8.4 times more likely to report having attempted suicide,
5.9 times more likely to report high levels of depression, 3.4 times more likely to use
illegal drugs, and 3.4 times more likely to report having engaged in unprotected sexual
intercourse compared with peers from families that reported no or low levels of family

Existing law provides for licensing and regulation of various mental health professionals,
including physicians and surgeons, psychologists, marriage and family therapists, clinical
social workers, and licensed professional counselors.
This regulation would prevent licensed mental health providers in Virginia from
performing conversion therapy with a patient under 18 years of age, regardless of the
willingness of a parent or guardian to authorize such efforts. The regulation will curb
harmful practices known to produce lifelong damage to those who are subjected to them
and help ensure the health and safety of LGBTQ youth. We thank you for proposing this
important regulation.

Amanda Darvill

CommentID: 74779