Re: Support for the NOIRA regarding regulation 18VAC125-20, on the Practice of Conversion Therapy

Dear Virginia Board of Psychology,

The Trevor Project is proud 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.

The Trevor Project is the world’s largest suicide prevention and crisis intervention organization for LGBTQ (Lesbian, Gay, Bisexual, Transgender, Queer, and Questioning) young people. We work every day to save young lives by providing support through free and confidential suicide prevention and crisis intervention programs on platforms where young people spend their time: our 24/7 phone lifeline, chat, text, and soon-to-come integrations with social media platforms. We also run TrevorSpace, the world’s largest safe space social networking site for LGBTQ youth, and operate innovative education, research, and advocacy programs.

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 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.

Far from being a relic of history, the practice of conversion therapy is active and ongoing in Virginia today. A 2018 study by the Williams Institute at the University of California, Los Angeles School of Law shows that nearly 700,000 LGBTQ adults have been subjected to conversion therapy, with 350,000 of them receiving the dangerous and discredited treatment as youth. That number grows by thousands each year as the Williams Institute estimates that nearly 57,000 LGBTQ youth will be subjected to conversion therapy in the next few years by either a religious or spiritual advisor. An estimated 20,000 LGBT youth currently ages 13 to 17 will undergo conversion therapy from a licensed healthcare professional before the age of 18. These are the youth this regulation would protect.

In the past year alone, The Trevor Project has been contacted by more than 2,500 young Virginians. Nationally, many of the young people that we serve are survivors of conversion therapy or have a credible fear that their family members will compel them to go through conversion therapy. Supervisors for The Trevor Project’s crisis services report that these issues come up regularly in conversation with youth coming to us for help, and as often as weekly. These impressions are borne out by data collected on TrevorLifeline, TrevorText, and TrevorChat, as our records show that since 2010 hundreds of contacts have reached out to The Trevor Project with specific concerns around this practice and terms like “conversion therapy,” “reparative therapy,” and “ex-gay” have appeared on our text-based platforms with disturbing frequency.

Some of these LGBTQ youth contact us because their parents are threatening to send them to conversion therapy. Others call us because they are in conversion therapy, it is not working, and their feelings of isolation and failure contribute to suicidal thoughts and behaviors. We’ve had youth reach out because friends or loved ones are being subjected to conversion therapy. And finally, young people have come to The Trevor Project in a state of profound distress because a someone they know has died by suicide during or after being subjected to conversion therapy.

As to questions raised by conversion therapy proponents about the constitutionality of protections for youth from these practices, policymakers can be assured that multiple federal courts—including the Third and Ninth U.S. Circuit Courts of Appeals—have upheld similar laws protecting youth from conversion therapy. The U.S. Supreme Court has also twice declined to hear appeals to positive federal court rulings upholding laws restricting conversion therapy. The power of states to regulate medical treatments, including professional therapy, to ensure the public’s health and safety is long established in Supreme Court precedent; indeed, it is a core purpose of professional licensing boards to regulate potentially dangerous medical treatments. Conversion therapy is no exception.

This policy does not restrict any protected First Amendment speech. It prohibits discredited treatments by state-licensed mental health care professionals. It does not apply to clergy or to individuals who provide religious instruction not selling these discredited practices in the public marketplace. It also does not prevent anyone from publishing, discussing, or advocating any viewpoints or beliefs regarding sexual orientation, gender identity, or anything else.

Despite these facts, conversion therapy proponents have suggested that dicta from NIFLA v. Becerra supports their oft-repeated and rejected claim that protecting youth from conversion therapy violates the free speech rights of licensed professionals. This is not the case, as NIFLA’s discussion of the professional speech doctrine has no effect on the constitutionality of conversion therapy bills. NIFLA concerned a California law that required licensed and unlicensed crisis pregnancy centers to post certain notices. By contrast, anti-conversion therapy policies regulate professional conduct, not professional speech, so the NIFLA case is inapplicable. In fact, in his opinion in NIFLA, Justice Thomas reaffirmed a distinction between professional speech and professional conduct, by explicitly stating that “under [the Supreme Court’s] precedents, States may regulate professional conduct, even though that conduct incidentally involves speech.”

Likewise, it is long established that the fundamental rights of parents do not include endangering their children by forcing them to undergo medical practices that have been rejected by the scientific community as discredited and harmful. The law already protects against other forms of child endangerment, and legal protections and professional guidance make it clear to parents that so-called “conversion therapy” is a dangerous and discredited practice that has no legitimate purpose. These regulations serve to protect parents from being taken advantage of by practitioners of conversion therapy who would attempt to cloak their actions with the legitimacy and authority of a state-issued license. 

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 – nothing more, nothing less. 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.

For these reasons and on behalf of the youth who depend upon our services, The Trevor Project strongly supports the NOIRA regarding regulation 18VAC125-20. Thank you for your consideration of this importance regulation.

Sincerely,

Casey Pick
Senior Fellow for Advocacy & Government Affairs
The Trevor Project

I support a regulatory ban on conversion therapy. Pseudoscientific claims made by homophobes have no place in the practice of licensed practitioners.

Conversion therapy” refers to any form of interventions which attempt to change an individual’s sexual orientation, sexual behaviors or gender identity. Underlying these ‘therapies’ is the assumption that homosexuality and gender nonconformity are mental disorders and that sexual orientation and gender identity can be changed. This assumption is not based on medical or scientific evidence. Professional consensus rejects pathologizing homosexuality and gender nonconformity and evidence does not support the efficacy of changing sexual orientation.

 “Conversion therapy” often includes unethical techniques including electric shock, deprivation of food and liquid, chemically induced nausea and masturbation reconditioning. These practices may increase suicidal behaviors and cause significant psychological distress, anxiety, lowered self-esteem, internalized homophobia, self-blame, intrusive imagery and sexual dysfunction.

The AMA opposes the use of “conversion therapy” for sexual orientation or gender identity.

Conversion Therapy needs to be banned now! It is completely unacceptable.

Conversion therapy, which seeks to change a person's sexual orientation, is an abusive, dangerous practice that must be banned in Virginia. Studies consistently show that the practice is harmful and entirely ignores legitimate medical practice, science and research. The only consistent outcome appears to be an increased risk of depression, anxiety and suicide in the patients subjected to it. The government of Virginia must act swiftly and decisively to ban this dangerous so-called therapy.

Conversion Therapy is a horrible practice and should be banned from all states.  It is nothing but a form of mental torture and abuse.  Time and again studies have proven that it is not only ineffective in its purpose, but that it is also harmful and leads to mental distress, depression, drug use, increased risk of STDs, and suicide attempts.  Being LGBTQ is not a disease that needs to be cured.  It is a natural state of being just as is being heterosexual and people should not be forced into torture for being one or the other.

Conversion Therapy is a horrible practice and should be banned from all states.  It is nothing but a form of mental torture and abuse.  Time and again studies have proven that it is not only ineffective in its purpose, but that it is also harmful and leads to mental distress, depression, drug use, increased risk of STDs, and suicide attempts.  Being LGBTQ is not a disease that needs to be cured.  It is a natural state of being just as is being heterosexual and people should not be forced into torture for being one or the other.

The practice of conversion therapy has been unequivocally and officially opposed for at least two decades by the American Psychiatric Association, first in their 1998 position statement: "APA opposes any psychiatric treatment, such as “reparative” or “conversion” therapy, that is based on the assumption that homosexuality per se is a mental disorder or is based on the a priori assumption that the patient should change his or her homosexual orientation”, and again in 2013: "The American Psychiatric Association does not believe that same-sex orientation should or needs to be changed, and efforts to do so represent a significant risk of harm by subjecting individuals to forms of treatment which have not been scientifically validated and by undermining self-esteem when sexual orientation fails to change. No credible evidence exists that any mental health intervention can reliably and safely change sexual orientation; nor, from a mental health perspective does sexual orientation need to be changed” (American Psychiatric Association, 2018).  

Additionally, the American Psychological Association opposes the use of conversion or reparative therapies - “So-called reparative therapies are aimed at ‘fixing’ something that is not a mental illness and therefore does not require therapy. There is insufficient scientific evidence that they work, and they have the potential to harm the client,” said APA 2015 President Barry S. Anton, PhD. “APA has and will continue to call on mental health professionals to work to reduce misunderstanding about and prejudice toward gay and transgender people” (American Psychological Association, 2015).

The job of a professional therapist, psychiatrist, or psychologist is to provide the best evidence-based treatment for their patients, regardless of the personal, religious, or moral feelings of the patient, their family, or the therapist themselves.  There is no evidence to support the incorrect and damaging idea that a person's sexual orientation can be, much less needs to be "fixed", but there is ample evidence that such therapies are damaging, dangerous, and even potentially deadly.  A November 2018 study in Journal of Homosexuality found strong evidence that adolescent experience with conversion therapy leads to a unfavorable mental health outcomes as adults, stating "Attempts by parents/caregivers and being sent to therapists and religious leaders for conversion interventions were associated with depression, suicidal thoughts, suicidal attempts, less educational attainment, and less weekly income" (Ryan, Toomey, Diaz, & Russell, 2018).

Conversion therapy intended to change a person's sexual orientation or gender identity must be banned outright throughout the Commonwealth of Virginia, and any therapist, psychiatrist, or psychologist who promotes or suggests conversion or reparative therapy as a treatment option, especially when dealing with children or adolescents, should not be allowed to continue treating patients.

Reference

American Psychiatric Association. (2018). APA reiterates strong opposition to conversion therapy. Retrieved from https://www.psychiatry.org/newsroom/news-releases/apa-reiterates-strong-opposition-to-conversion-therapy

American Psychological Association. (2015). American Psychological Association applauds President Obama's call to end use of therapies intended to change sexual orientation. Retrieved from https://www.apa.org/news/press/releases/2015/04/therapies-sexual-orientation

Ryan, C., Toomey, R.B., Diaz, R.M., & Russell, S.T. (2018). Parent-initiated sexual orientation change efforts with LGBT adolescents: Implications for youn adult mental health and adjustment. Journal of Homosexuality, 1-15. doi: 10.1080/00918369.2018.

Conversion therapy needs to be banned.  This dangerous process does not serve to change any one except to cause them to go deeper into the closet. It causes more depression and suicidal ideations and can lead to actual suicide.  

Dear Virginia Board of Psychology,

As a practicing Licensed Professional Counselor in the state of Virginia who has extensive experience in working with LGBT clients across the life span, I am writing to provide my strong support for the proposed NOIRA regulations 18VAC115-20, -30, -50, and -60 as essential to the protection of harm and in keeping with a practitioner’s ethical responsibility in best serving young clients in danger of potentially irreparable damage that often occurs when forced to undergo such ‘therapy.’

Conversion ‘therapy,’ sometimes referred to as “reparative therapy,” has no basis in the literature, and is in fact at odds with helpful and/or therapeutic practice. What is much more critical to the needs of those working to best understand their identity is affirming and accepting support in a non-directive [and non-coercive] manner that provides developmentally appropriate guidance and exploration of an individual’s understanding of sexuality and gender. ‘Conversion therapy’ does not support healthy growth and development, but instead as been shown to increase shame, depression, anxiety, social withdrawal, and suicidal thoughts, and is grounded in stigma, religious ideology, and misinformation. The American Counseling Association, the American Psychiatric Association, the American Psychological Association, the American Academy of Pediatrics, the American Association for Marriage and Family Therapy, and the National Association of Social Workers have all issued statements regarding the detrimental impact of such ‘therapeutic’ practice.

These guidelines provide further support and are upheld by current Virginia law prohibiting discredited and unsafe practices by licensed therapists. Minors, particularly LGBTQ+ minors, rely on the oversight of responsible, trained, licensed, and ethical practitioners in ensuring their safety and protecting them exposure to therapeutic practices that are damaging to their growth. These guidelines serve to fortify the existing laws and protections in place, and if anything, protect the ‘freedom’ of these clients and children that those opposed falsely accuse the guidelines of denying. In consulting with current clients, my statement here is not only grounded in professional knowledge and experience, but in the voices and stories of clients who have suffered due to a lack of such protections in the past. Thus, I wholeheartedly thank you for these guidelines and urge their adoption and implementation as soon as possible.

Sincerely,

Carrie Lynn Bailey, PhD, NCC, LPC

~~~~

Reference for Appropriate Therapeutic Responses to Sexual Orientation (APA, 2009):

https://www.apa.org/pi/lgbt/resources/therapeutic-response.pdf

Reference regarding Reparative Therapy/Conversion Therapy as a Significant and Serious Ethical Violation by the ACA Code of Ethics [2017]:

https://www.counseling.org/docs/default-source/resolutions/reparative-therapy-resoltution-letter--final.pdf?sfvrsn=d7ad512c_4

Position Statement from the National Association of Social Workers on Sexual Orientation Change Efforts and Conversion Therapy [2015]:

https://www.socialworkers.org/LinkClick.aspx?fileticket=IQYALknHU6s%3D&portalid=0

Report from the Substance Abuse and Mental Health Services Administration [SAMHSA] on Ending Conversion Therapy: Supporting and Affirming LGBTQ Youth [2015]:

https://www.socialworkers.org/LinkClick.aspx?fileticket=IQYALknHU6s%3D&portalid=0

Please ban conversion therapy. As a sister of a LBGQT sibling, ( who is living their best life) I fully support the banning of this unethical treatment modality. 

Re:      Support for the NOIRA regarding regulation 18VAC125-20, on the Practice of Conversion Therapy

Dear Virginia Board of Psychology,

Equality Virginia 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. Equality Virginia is the leading advocacy organization in Virginia seeking equality for lesbian, gay, bisexual, and transgender people.

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.

Sincerely,

Equality Virginia

The Southeastern Virginia Atheists, Skeptics, & Humanists (SEVASH) are pleased to support the NOIRA regarding regulation 18VAC140-20, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed psychologists in Virginia.

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. Nearly half of young transgender people have seriously thought about taking their lives and one quarter report having made a suicide attempt. Young people who experience family rejection based on their sexual orientation, including being subjected to conversion therapy, face especially serious health risks.

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 found42percentof 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 non-binary 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. 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.

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.

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.

V/R,

Aiden Barnes
Organizer | Southeastern Virginia Atheists, Skeptics, & Humanists (SEVASH)
sevaskeptics@gmail.com

I was always taught to treat other the way I wanted to be treated. I am appalled that in the land of the free LGBTQ+ youth are targeted for "conversion therapy" that tells them that they are bad because of who they are. These dangerous and discredited practices include the use of shame, pornography, psychological abuse, and even aversive conditioning. These "treatments" lead to devastating and lifelong problems including depression, anxiety, substance abuse, and suicide. I am gay and it sickens me to know that some LGBTQ+ youth are being told they are inherently wrong or shameful. 

Dear Virginia Board of Psychology, Hello, my name is Jonathan Russell and I am writing in support of the NOIRA regarding regulation 18VAC125-20, on the Practice of Conversion Therapy, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed psychologists in Virginia. As a gay man, I have read many studies on research concerning conversion therapy, and have read many stories and seen many movies depicting conversion therapy, and I can, without a doubt, testify that this is neither effective nor is it just and right to do something to an individual. Just as I am a man, I am gay. It is part of who I am, and it is not something I should be punished because of, nor should it be treated as something that needs to change, or something wrong with me. I am an incredible person that adds so much to those around me, and my impact is irreplaceable and it is because of every different part of me that I am the way I am. 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. Nearly half of young transgender people have seriously thought about taking their lives and one quarter report having made a suicide attempt. Young people who experience family rejection based on their sexual orientation, including being subjected to conversion therapy, face especially serious health risks. 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. 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. 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. 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. Sincerely, Jonathan Russell

Conversion therapy is inhumane. Please take steps towards ending this awful practice.

The AMA opposes Conversion Therapy and so should VA

Conversion therapy traumatizes (or retraumatizes, depending on what they may already have endured at the hands of their friends, family, and school community) the recipients and is an unethical practice for any individual working in the field of behavioral health or medicine to implement. It flies in the face of the commitment to "do no harm" and is contrary to the ideals of behavioral health professions. Professionals who continue to offer or implement conversation therapy ought to lose their license (or face significant consequents from the board) for failing to prioritize their client's wellbeing and potential to be empowered as a whole person. I am a resident in counseling with a background in public health (so I am well aware that professional groups such as the American College of Physicians have already recommended against this practice, based on its traumatizing qualities) - I am also a practicing Christian who views conversion therapy as additionally counter to the two commandments Jesus highlighted as most important: loving one's neighbor as one's self, and loving God above all else. Instead, this practice bluntly states that the practitioner does not unconditionally accept the client for who they are (and so is unable to fully embrace the client as a beloved neighbor in this life), and further more (from the Christian view) is questioning God's plan for the individual in front of them.  I do not believe that this practice should even be considered appropriate in any way within a faith-based behavioral health setting. Finally, allowing the practice of conversion therapy by respected behavioral health professionals subtly aides and abets the homophobia present in the broader society which continues to lead to suicide, self-harm, trauma, and the experience of verbal and physical violence among members of the LGBTQ+ community. As an ally to that community, it is my greatest hope that you are able to ban conversion therapy in the interests of a more merciful and loving society.

Conversion therapy is harmful to members of the LGBTQ community and should not be permissible. As clinicians and psychologists, our ethics code dictates that we follow principles of beneficence and nonmaleficence. Accordingly, any clinician engaging in this practice should have their license revoked.

I support banning conversion therapy in Virginia. It is harmful to all LGBTQ people and especially youth. There is no reason to sanction a modality predicated on narrow ideas of what is acceptable behavior. It is 2019 and LGBTQ people deserve nothing less than acceptance and support. If you believe that all people have a right to exist as they are rather than be subject to harmful practices that tell them they need to change to comply with other people's ideas of socially acceptable was to be, you will do the right thing. Please ensure that Virginia not be a place to allow such detrimental practices as conversion therapy. Listen to doctors who are not funded or supported by religious ideological organizations; stand for mental health and a tolerant society.

There is no scientific evidence backing conversion therapy as a credible or useful form of psychological treatment. Instead, the evidence suggests that conversion therapy poses a huge risk to LGBTQ+ individuals, including increasing symptoms of depression, substance abuse, risky behavior, social withdrawal, and suicidal behavior, and decreasing self esteem. Nearly all of 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 found this practice to be incredible harmful and dangerous. At this time, 18 states have laws banning conversion therapy, and as a future clinical psychologist, I urge the Virginia legislature to follow suit in banning conversion therapy. 

Dear Virginia Board of Psychology,

Hello, my name is Lee Williams and I am writing in support of the NOIRA regarding regulation 18VAC140-20, on the Practice of Conversion Therapy, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed psychologists in Virginia.

As a graduate student in Psychology, I am frankly aghast at the continuation of this practice. Considering the lack of any credible empirical support for conversion therapy, as well as the growing evidence of its deleterious consequences, it ought to be banned as soon as possible.  

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. Nearly half of young transgender people have seriously thought about taking their lives and one quarter report having made a suicide attempt. Young people who experience family rejection based on their sexual orientation, including being subjected to conversion therapy, face especially serious health risks.

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. 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.

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.

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.

Sincerely,

Lee Williams

I am writing to urge the Virginia legislature to pass regulations banning conversion therapy in the state of Virginia. Numerous influential professional organizations oppose and have denounced conversion therapy, given that it is incredibly harmful to the LGBTQ+ community and is not credible, ethical, or evidence-based.

Hello, my name is Carol Schall and I am writing in support of the NOIRA regarding regulation 18VAC125-20, on the Practice of Conversion Therapy, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed psychologists in Virginia.

As the mother of a young woman who struggles with anxiety, I know personally how debilitating dealing with mental health challenges can be. I also know that psychologists should offer therapy to their patients that will reduce their suffering and certainly improve their overall mental health. Finally, I expect all psychologists across Virginia to use research based practices that have evidence of providing help, not harm. These common sense requirements are not met when considering the practice of "so-called conversion therapy."

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. Nearly half of young transgender people have seriously thought about taking their lives and one quarter report having made a suicide attempt. Young people who experience family rejection based on their sexual orientation, including being subjected to conversion therapy, face especially serious health risks.

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. 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.

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.

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.

Sincerely,

Carol M. Schall, PhD.

Dear Virginia Board of Psychology,

On March 20, 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 (125-9) 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 125-9. In fact, the Board did not make any changes to the proposed Guidance Document based on concerns raised by any member of the public; it 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 125-9 to 18VAC125-20.

 Sincerely,

Jeffrey F. Caruso

Executive Director, Virginia Catholic Conference

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
   
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• 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. 

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
   
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• 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. 

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
   
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• 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. 

Never should any governmental or professional organization attempt to remove the parent(s) from the first position when it comes to training teaching and raising their children!

Dear Sir/Madam: I understand you are moving forward with a proposal to ban, 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… reduce sexual or romantic attractions or feelings toward individuals of any gender.”  As a parent, this concerns me regarding advice I may give to my child and our religious liberty to teach our children according to the sexual ethics of the Catholic Church, which we whole-heartedly believe in and believe ultimately allows for the greatest human flourishing and happiness. 

In addition, I think it is only fair to children, since most who experience gender dysphoria experience it only temporarily, to not prohibit counselors and therapists from working with a child in keeping with his/her values and religious beliefs. Allowing professionals to counsel a child in the direction that seems best for this child, even if that is not acting on sexual impulses or not altering their gender identity from biological identity - advice cannot reasonably be mandated to only advise in one direction, how can one answer be best for every child that comes in for therapy or counseling? 

Finally, I deeply believe all persons who identify as LGBTQ are entitled to our respect and equal treatment under the law and in practice, my views here are not in any way meant to make someone feel belittled or unwanted. Rather, I disagree that banning professionals and parents from being able to discuss sexual behaviors and ethics in keeping with Christian ethics is inherently bad for children. In fact, I think the opposite provided it is done respectfully and in love. I hope you will reconsider pushing this ban through and that all of us can continue dialoguing on these issues respectfully. 

Sincerely,

Melissa Swearingen 

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
   
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• 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. 

I am absolutely opposed to any attempt to limit or ban parental involvement with respect to their minor's sexual identity or conversion therapy.

Parents are closest to their child's challenges.  They are in the best position to make healthcare decisions involving the wellbeing of their child.

Under Virginia law parents have the fundamental right to make decisions regarding the upbringing, education, and care of their children.

Some young people may have attractions they may desire to change or moderate.  Others may simply desire guidance from a counselor to live a chaste life.  In either instance, there should be options for families to make informed decisions.

The proposed ban would deny families the freedom to seek counseling aligned with their faith.

Licensed professional with years of experience should not be removed from the process of helping children working through these sensitive and deeply personal issues.

I ask they you not impose a policy that is contrary to the specific wishes of the Virginia legislature in these areas.  Support the involvement of parents over their children.

Parents are the best judges of the sex education and morals for their children, not some regulatory board.  Only the Legislature of Virginia can legislate the laws that must be followed in schools.  Stop exceeding your authority.

Let parents do their job and stop infringing on a family’s rights.

• Parents are closest to their child’s challenges; they are in the best position to make healthcare decisions involving the wellbeing of their child.
   
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options for families to make informed decisions. 
   
• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• 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 best judges of sex education is parents. Stop interfering between a parent and child.

Parents are the best judges of the sex education and morals for their children, not some regulatory board.  Only the Legislature of Virginia can legislate the laws that must be followed in schools.  Stop exceeding your authority.

Parents know their children best and can lovingly provide the guidance that their children need, whether it is via professional counseling, religious advice or through the help of another trusted person.  Virginia has no business limiting or curtailing the right of parents to BE parents and help form their children into mature an responsible adults.  This includes the right to help a child struggling with sexual identity issues.  Virginia should not interfere with this basic right via regulation or legislation.

Parents are responsible for raising and educating their children, and instilling moral values according to their religious faith.  Outside groups, and unelected government officials, should not seek to force their beliefs on others.  Please oppose the regulation of what psycologists can say.

I agree with the comments made by the Virginia Catholic Conference opposing the proposed amendment of 18VAC125-20 regulations governing the practice of psychology.

Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
 

• The proposed ban would deny families the freedom to seek counseling aligned with their faith.
   
• 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. 

• 
   
• Some young people may have attractions they desire to change or moderate. Others may simply desire guidance from a counselor to live a chaste life. In either instance, there should be options families to make informed decisions.
• Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
•  

Oppose proposed amendment of 18 VAC 125-20                                                                     

I support the effort to ban conversion therapy.  This type of therapy is harmful to the child, and parents who request it are misguided.  Thank you for trying to keep children from being subjected to this terrible practice.

No BAN. Parental rights!

It appears that there is a great effort among educators and others to promote the Gay Pride agenda to young impressionable students.  In many cases this may not be in the best interest of the student or the desires of his/her parents.  To counteract this, conversion therapy if done properly, may the only and best course of action.  This is an unnecessary regulation restricting the actions of parents acting in best interest of their children.   

Parents are closest to their child's challenges: they are in the best position to make healthcare decisions involving the well-being of their child.

UNDER VIRGINIA LAW, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children.

If a young person has an attraction or a behavior THEY wish to change uninfluenced by others, then it is their right to seek therapy without unelected officials dictating options.

The proposed ban denies families their FUNDAMENTAL FREEDOM to seek counseling aligned with their faith.  1st Amendment of the Constituition GUARANTEES that RIGHT.

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 (meaning without government interference) issues.

It is in the best interest of children for them to be cared for and guided by their parents. The family is the most critical part of a society. Government should not interfere with parents’ guidance of their children. Children are particularly vulnerable in our over-sexed society and need the loving guidance of their parents to help them understand love and dignity of their sexuality.