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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8/7/19  5:09 pm
Commenter: Irene Pruitt, LPC

Opposition to Proposed Changes

As a Licensed Professional Counselor in Virginia, I am writing to express my opposition to the proposed changes to the Board of Counseling’s regulations. First, these changes are inconsistent with crucial aspects of ethical counseling practice. Second, they discriminate against a class of clients. Third, the protections against abuse in therapy that these changes purport to offer are already in place in existing law. Fourth, they are a violation of parental rights in the counseling process.

First, the proposed changes are inconsistent with ethical counseling practice, based on the principles of respect of client autonomy and client values, beliefs, and attitudes. According to the American Counseling Association Code of Ethics, autonomy is a fundamental value in counseling, and refers to, “fostering the right to control the direction of one’s life.” Additionally, the same document states, “Counselors are aware of—and avoid imposing—their own values, attitudes, beliefs, and behaviors.” Based on these principles, it is the client, and neither the counselor nor the state, that should determine the goals for therapy and for their lives.

Second, the proposed regulations would discriminate against clients who, based on their values or religion, would seek to change unwanted sexual thoughts, attractions, or behaviors. These proposed regulations would prohibit counselors from offering the kind of treatment that these clients sought. In this way, these clients would experience systematic discrimination by being excluded from appropriate and ethical counseling, based on their values or religion.

Third, the proposed changes are redundant with existing Virginia law. Some practices in so-called Conversion Therapy have historically been abusive, and should not be used. The use of psychological shaming, aversion therapy, and other harmful practices is clearly unethical, according to existing Virginia law governing Licensed Professional Counselors, and the ACA Code of Ethics. Both of these standards of practice are based on the principle of nonmaleficence, that is, avoiding harm. Because harmful and abusive practices are already banned from the profession of counseling, it is not necessary to amend the regulations for this purpose. The Virginia laws governing counselors should be upheld and maintained, with the appropriate consequences being imposed on those who violate existing laws. 

Fourth, these changes undermine the crucial role of parents in the counseling process. Parents are primary influences in the life of their child, and are in a unique position to understand the child’s developmental needs. According to the ACA Code of Ethics, counselors should foster a “collaborative” relationship with parents, while also respecting the minor client’s confidentiality. The Board of Counseling should not undermine parents’ rights to seek counseling for their minor child that is consistent with their values.

For these reasons, I urge the Board of Counseling not to adopt the proposed changes. 


Irene Pruitt, LPC

CommentID: 75473