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  2:23 pm
Commenter: Matthew Payne

Please reject this proposed regulation

Please do not adopt this regulation for the following reasons.

First, the concept behind this regulation was considered and rejected by the State Legislature.  If the voice of the people—as represented by the legislature—reject a proposal, the executive should not implement it without the consent of the public.

Second, this type of therapy has been successful in assisting children who are confused about these issues.  Why ban a therapy which has been successful?  Banning the therapy marginalizes those for whom it has been successful.

Third, the parents of the children concerned should be able to be make informed decisions about what is best for their children.  The parents are best positioned to know what their child needs.  Forbidding the parents from a choice of therapies takes away from the rights of the parents and risks the child getting suboptimal care.

Fourth, limiting the options for licensed counselors—especially forbidding them from offering treatments which have been demonstrated to work—forces counselors either to offer sub-standard treatments or violating state regulations.

CommentID: 75388