Agencies | Governor
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 Ends 8/7/2019
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8/7/19  10:15 pm
Commenter: Nicole Gibson, American Foundation for Suicide Prevention (AFSP)

AFSP Supports the NOIRA re: regulations 18VAC115-20, -30, -50, and -60

Dear Members of the Virginia Board of Counseling,

The American Foundation for Suicide Prevention (AFSP) supports the NOIRA regarding regulations 18VAC115-20, -30, -50, and -60, which would prohibit the practice of conversion therapy or sexual orientation change efforts with minors.

AFSP is dedicated to saving lives and bringing hope to those affected by suicide.  As the nation’s largest private funder of suicide prevention research, we know that suicide is a leading yet preventable public health problem.  In Virginia, suicide ranks as the 11th leading cause of death overall and the 2nd leading cause of death for youth and young adults ages 10-24.

Lesbian, gay, bisexual, transgender, and queer youth, and those who are questioning their sexual orientation or gender identity (LGBTQ) struggle with suicidality statistically more than individuals who identify as heterosexual. Research has shown that LGBT people have much higher rates of having attempted suicide in their lifetimes as compared to their non-LGBT peers. LGB youth are approximately three times more likely to contemplate suicide and about five times as likely to attempt suicide in comparison to heterosexual youth. For those who identify as transgender, about 40% have attempted suicide, which is 9 times higher than general rate of the U.S. population. Among students in grades nine through twelve, almost 50% of gay, lesbian, and bisexual students have seriously considered attempting suicide, while the percentage among heterosexual students is about 13%.

Researchers largely agree that at least part of the reason for the elevated rates of suicide attempts and mental health conditions found in LGB people is the social stigma, prejudice and discrimination associated with minority sexual orientation. There is ample evidence that shows across the lifespan, LGB people commonly experience individual discrimination in the form of personal rejection, hostility, harassment, bullying, and physical violence. For LGB youth, a common and powerful stressor is rejection by parents and other family members. LGB people also experience institutional discrimination resulting from laws and public policies that create inequities or fail to provide protections against sexual orientation-based discrimination.

Conversion therapy is based on the belief that homosexuality is a mental illness that needs to be cured, a belief that has been rejected as scientifically invalid by the American Psychiatric Association and all other major mental health organizations. Conversion therapy has not been proven to change a person’s sexual orientation, gender identity or expression. Conversion therapy can, however, invoke feelings of rejection, guilt, confusion, and shame and can lead to decreased self-esteem, substance abuse, social withdrawal, depression, anxiety, and increased risk for suicidal behavior.  Conversion therapy can also interrupt healthy identity development, create mistrust of mental health professionals, and deteriorate relationships with family. 

These damaging effects can last well into adulthood.  A recent (2018) study examined young adults’ reports of parent-initiated efforts to change their sexual orientation during adolescence, and the associations between those experiences and young adult mental health and adjustment. The study found that parent-initiated attempts to change their child’s sexual orientation during adolescence was associated with more negative mental health problems for young adults, and that those who experienced conversion therapy were more likely to have suicidal thoughts, report suicide attempts, and have higher levels of depression. Furthermore, those subjected to conversion therapy had lower life satisfaction, less social support in young adulthood, and lower young adult socio-economic status including less educational attainment and less weekly income.

In conclusion, the practice of conversion therapy dehumanizes LGBTQ people and tells them they have a pathology that requires medical treatment when they do not. The proposed regulation changes to ban conversion therapy will protect LGBTQ youth and have the potential to reduce suicide risk and save young lives. It is vital to hold licensed health providers accountable by requiring them to follow professional standards and a code of ethics and prohibiting harmful and fraudulent services with no scientific basis. Thank you for the opportunity to provide comment and we urge the board to move forward with prohibiting conversion therapy practices in the Commonwealth.


Nicole A. Gibson, MSW

Senior Director, State Policy & Grassroots Advocacy

American Foundation for Suicide Prevention

CommentID: 75648