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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8/6/19  3:43 pm
Commenter: Sarah Warbelow, Human Rights Campaign

SUPPORT for the NOIRA regarding 18VAC115-20, 18VAC115-30, 18VAC115-50, and 18VAC115-60

Dear Virginia Board of Counseling,

The Human Rights Campaign (HRC), on behalf of its more than 151,000 members and supporters in Virginia, thanks you for the opportunity to affirm support for the Notice of Intended Regulatory Action (NOIRA) regarding 18VAC115-20, 18VAC115-30, 18VAC115-50, and 18VAC115-60, important steps in the effort to protect minors in Virginia from the dangerous and discredited practices that falsely claim to change their sexual orientation or gender identity.

The Human Rights Campaign is America's largest civil rights organization working to achieve lesbian, gay, bisexual, transgender and queer (LGBTQ) equality. By inspiring and engaging all Americans, HRC strives to end discrimination against LGBTQ people and realize a world that achieves fundamental fairness and equality for all. As an advocate for LGBTQ young people, HRC believes that no young person should be subjected to dangerous practices that lack legitimate medical purpose, such as conversion therapy.

Conversion therapy, sometimes referred to as “reparative therapy” or “sexual orientation change efforts,” are practices that seek to change a person’s sexual orientation or gender identity. These practices are based on the false idea that being LGBTQ is a mental illness that needs to be cured—an idea which has been rejected by every major medical and mental health group. Importantly, conversion therapy does not include legitimate therapies that provide acceptance, support, or understanding of LGBTQ identities; that facilitate coping, social support, or identity exploration; or that address unlawful conduct or unsafe sexual practices. This proposed regulatory action would prohibit state-licensed counselors from engaging in conversion therapy with minors.

There is no credible evidence that conversion therapy can change a person’s sexual orientation or gender identity, and it is abundantly clear that conversion therapy poses devastating health risks for LGBTQ youth including depression, decreased self-esteem, substance abuse, homelessness, and even suicidal behavior. This is why the nation’s leading mental health organizations have ubiquitously decried these unscientific practices. Unfortunately, due to discrimination against LGBTQ people and the fact that professional rules have not kept up with this widespread understanding, some licensed mental health professionals continue to engage in conversion therapy. A recent Williams Institute at UCLA School of Law report revealed that an estimated 20,000 LGBTQ minors in states without protections will be subjected to conversion therapy by a licensed healthcare professional if state officials fail to act. Additionally, a 2018 study from the Family Acceptance Project at San Francisco State University found that suicide attempts nearly tripled for LGBTQ youth who reported both home-based efforts and outside-the-home efforts to change their sexual orientation (compared to LGBTQ youth who did not experience such change efforts).

Providers who engage in conversion therapy under state license mislead families about the risks involved, leading to negative psychological outcomes, irreparable damage to family cohesiveness, and lasting personal and social harms. This regulatory action is needed to protect families from these damaging practices.

Thank you for the opportunity to comment in favor of this vital proposed regulatory action.

Sarah Warbelow
Legal Director, Human Rights Campaign

CommentID: 75103