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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7/25/19  9:49 am
Commenter: Jeff Caruso, Virginia Catholic Conference

Oppose Amending 18VAC115-20,-30,-50,-60

Dear Virginia Board of Counseling,

On March 28, 2019, the Virginia Catholic Conference -- the public policy agency representing Virginia’s Catholic bishops and their two dioceses -- submitted comments opposing a vague and broadly-worded Guidance Document (115-10) that seeks to prohibit, for minors, “any practice or treatment that seeks to change an individual’s sexual orientation or gender identity, including efforts to change behaviors or gender expressions or to eliminate or reduce sexual or romantic attractions or feelings toward individuals of any gender.”

As we noted in our comments, such a ban would infringe:

  • the fundamental rights of parents to care for their children;
  • Freedom of Speech and Free Exercise of Religion under the First Amendment; and
  • Limits on regulatory authority that ensure consistency with the General Assembly’s decisions.

None of these concerns were rectified or even addressed in the final version of Guidance Document 115-10. In fact, the Board did not make any changes to the proposed Guidance Document based on concerns raised by any member of the public, even though it received 371 comments against the Guidance Document and only 198 for it. Moreover, the Board merely adopted the original version without any amendments. Because the Board is now seeking to amend Virginia’s regulations to conform them to the sweeping provisions of this Guidance Document, we reiterate these concerns.

When minors have unwanted same-sex or mixed-sex attractions, they and their families should be free to seek counseling toward the resolutions they desire. Licensed professionals with years of education and experience should not be removed from the process of helping children work through these sensitive and deeply personal issues.

The Conference, therefore, opposes adding the provisions of Guidance Document 115-10 to 18VAC115-20,-30,-50,-60.



Jeffrey F. Caruso

Executive Director, Virginia Catholic Conference

CommentID: 74145