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  6:26 am
Commenter: Silvia Park, American Atheists

Support for the NOIRA regarding regulation 18VAC1 25 - 20 , on the Practice of Conversion Therapy
Dear Virginia Board of Counseling,

American Atheists is pleased to support the NOIRA regarding regulation 18VAC125-20, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed psychologists in Virginia.  American Atheists is a national organization dedicated to the separation of church and state, the normalization of atheists, science based policies, and supporter and ally of the LGBTQ community.  We believe that science and empirical based evidence must be used to drive policy, not religious ideology.  We stand as allies with the LGBTQ community in abolishing conversion therapy altogether, especially in regards to our youth. 

As the parent of a transgender son who is also gay, I feel this very personally.

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.[1] Nearly half of young transgender people have seriously thought about taking their lives and one quarter report having made a suicide attempt.[2]

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. Young people who experience family rejection based on their sexual orientation, including being subjected to conversion therapy, face especially serious health risks. 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 rejection.[3] 

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.[4]

Virginia law already prohibits discredited and unsafe practices by licensed therapists.

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.


Silvia Park
Virginia Assistant State Director
American Atheists

[1] 2011 CDC, “Sexual Identity, Sex of Sexual Contacts, and Health-Risk Behaviors Among Students in Grades 9-12.”

[2]  Arnold H. Grossman & Anthony R. D’Augelli, “Transgender Youth and Life-Threatening Behaviors,” 37(5) Suicide Life Threat Behav. 527 (2007).

[3] Caitlyn Ryan et al., “Family Rejection as a Predictor of Negative Health Outcomes in White and Latino Lesbian, Gay, and Bisexual Young Adults,” 123 Pediatrics 346 (2009).

[4] This list may need to be modified depending upon your state law and the types of mental health professionals covered by the regulation.

CommentID: 75211