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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7/9/19  1:31 pm
Commenter: Carrie Lynn Bailey, 3 Little Birds Counseling LLC

In support of proposed guidelines in ethically and responsibly serving our LGBTQ Youth

Dear Virginia Board of Counseling,

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.


Carrie Lynn Bailey, PhD, NCC, LPC


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

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

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

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

CommentID: 73235