Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Social Work
 
chapter
Regulations Governing the Practice of Social Work [18 VAC 140 ‑ 20]
Action Unprofessional conduct/practice of conversion therapy
Stage NOIRA
Comment Period Ended on 8/7/2019
spacer

211 comments

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7/8/19  6:19 pm
Commenter: Elizabeth Florek

Ban conversion therapy.
 

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

CommentID: 73086
 

7/8/19  6:23 pm
Commenter: Casey Pick, The Trevor Project

The Trevor Project Supports the NOIRA regarding regulation 18VAC140-20
 

Re: Support for the NOIRA regarding regulation 18VAC140-20, on the Practice of Conversion Therapy

Dear Virginia Board of Social Work,

The Trevor Project is proud 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.

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 18VAC140-20. Thank you for your consideration of this importance regulation.

Sincerely,

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

CommentID: 73087
 

7/8/19  7:23 pm
Commenter: Elizabeth Harvey

Ban conversion therapy
 

Conversion therapy needs to be banned now. It is completely unacceptable.

CommentID: 73107
 

7/8/19  8:01 pm
Commenter: Mary Mullins

Coversion Therapy is Abusive
 

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.

CommentID: 73121
 

7/9/19  9:15 am
Commenter: Colleen LaClair

Ban Conversion Therapy Now!
 

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.

CommentID: 73188
 

7/9/19  1:08 pm
Commenter: Shirley Carley, Free Mom Hugs, VA

Ban Conversion Therapy
 

As the mother of two LGBT+ individuals, I will be so thankful when this ban passes.  Conversion therapy is dangerous and can lead to irreparable damage. Our LGBT+ community needs to be safe from this misguided practice.  

CommentID: 73229
 

7/9/19  1:33 pm
Commenter: Carrie Lynn Bailey, 3 Little Birds Counseling LLC

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

Dear Virginia Board of Social Work,

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

CommentID: 73236
 

7/9/19  3:04 pm
Commenter: Equality Virginia

Re:      Support for the NOIRA on the Practice of Conversion Therapy
 

Re:      Support for the NOIRA regarding regulation 18VAC140-20, on the Practice of Conversion Therapy

 

Dear Virginia Board of Social Work,

 

Equality Virginia is 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 social workers 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



[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: 73252
 

7/9/19  3:21 pm
Commenter: Aiden Barnes, Southeastern Virginia Atheists, Skeptics, & Humanists

Regarding Support for the NOIRA regarding regulation 18VAC140-20
 

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 social workers 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

CommentID: 73259
 

7/11/19  12:08 pm
Commenter: Larry Mendoza, State Director: American Atheists

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

Dear Virginia Board of Social Work,

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. 

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,

Larry Mendoza
Virginia 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: 73509
 

7/16/19  7:18 pm
Commenter: Peg Ruggiero, MSW

Stop Conversion Therapy
 

Conversion therapy has no basis in research and is, in fact, judgmental of an entire group of people whose gender identity or sexual preference is a trait that is as genetic as eye color or body type. It is as ludicrous to support this treatment modality as it would be to practice putting people on stretchers because they are short. Please ban this practice. It devalues legitimate therapeutic processes.

CommentID: 73565
 

7/24/19  3:30 pm
Commenter: Carol Schall

Support for the NOIRA regarding regulation, on the Practice of Conversion Therapy
 

Dear Virginia Board of Social Workers,

Hello, my name is Carol Schall and I am writing in support of the NOIRA regarding the Practice of Conversion Therapy, which would protect youth under the age of 18 from so-called “conversion therapy” at the hands of licensed social workers 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 social workers should offer therapy to their patients that will reduce their suffering and certainly improve their overall mental health. Finally, I expect all social workers 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 Ph. D.

CommentID: 74044
 

7/24/19  4:14 pm
Commenter: Jeff Caruso, Virginia Catholic Conference

Oppose Amending 18VAC140-20, Regulations Governing the Practice of Social Work
 

Dear Virginia Board of Social Work,

On May 1, 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 (140-12) 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 140-12. 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 140-12 to 18VAC140-20.

Sincerely,

 

Jeffrey F. Caruso

Executive Director, Virginia Catholic Conference

CommentID: 74053
 

7/26/19  12:26 pm
Commenter: Carolynn Nguyen

Parents' involvement in a child's life is crucial
 

Parents need to be involved in a child's up bringing.  Better family structure makes better society.  It does not bold well when the government takes over the roll of parenting by limiting the tools the parents could have to raise an educated well round child.  Since the parents are the "responsible party" in the raising of the child, give them the necessary tools to make an informed decision.  Government intervention to control certain "allowable" information is brainwashing.  Are the government going to be responsible and care for all the children under 18?  Let's hope that's not the government's roll.

CommentID: 74331
 

7/26/19  12:53 pm
Commenter: mike herrick, catholic conference of va

excluding parents is an abomnation of the Childs care and really child ABUSE
 

Dear Virginia Board of Social Work,

On May 1, 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 (140-12) 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 140-12. 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 140-12 to 18VAC140-20.

Sincerely,

 

mike herrick

16555 sparkling brookloop 

dumfries va 22025 

cc to my federal representativefor federal action 

CommentID: 74341
 

7/26/19  1:00 pm
Commenter: Robert Brever Jr

Unprofessional Conduct/Practice of Conversion Therapy
 

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

I ask that 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.

CommentID: 74346
 

7/26/19  1:00 pm
Commenter: Chris Russo

This ban is misguided and unconstitutional
 

This ban is misguided and unconstitutional.  This ban does not respect Virginian parents’ legitimate right to counsel children according to our faiths.

  • 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. 

This ban is misguided and unconstitutional.

CommentID: 74347
 

7/26/19  1:06 pm
Commenter: Dennis Huyck

Regulatory Action is Unconstitutionaland Misguided
 

You are trying to demean the role of the parents in the guidance of a child.  That is unconstitutional and very unwise.  Parents are in the best position to make decisions for their child, not some board imposing their wishes.  These proposals would result in a ban on parents seeking their own counseling for their children.  That is morally wrong.

CommentID: 74349
 

7/26/19  1:26 pm
Commenter: Beth Martini

Parental rights
 

Let parents have the freedom to raise their children in the best way they can.  

  • 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.
     
  •  
CommentID: 74354
 

7/26/19  1:53 pm
Commenter: NL

do not harm parental rights
 

Parents are the primary care-givers and decision makers regarding their children.  Unelected regulators and outside interests should not be allowed to regulate the freedom that parents in getting help for their children, and social workers should not be restricted to following rules that contradict the desires of the parents, and that have not been approved by elected officials.  Regulation is attempting to be used to bypass the will of the people of the state of Virginia, whose elected officials have, each time, rejected these regulations.  Resist the political pressure of the leftists. Stand up for truth, families, and Biblical values.

CommentID: 74361
 

7/26/19  1:59 pm
Commenter: Thomas F. Griffin, Lt. Col., USAF (Ret)

Comments Opposing the Proposed Amendment of 18VAC125-20 Regulations governing the Practice of psych
 

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

CommentID: 74364
 

7/26/19  2:05 pm
Commenter: Kieran Carter

Parental rights to obtain sexual counseling for their minor children
 

Parents, not social workers, teachers or a state entity, know what is best to help their children grow into happy and healthy adults.  The proposed regulations to ban the so-called "conversion therapy"  are a hideous overreach of government power and a blatantly unconstitutional curtailment of free speech.  In recent years there has been a disturbing trend for government and bureaucrats to assume and spread the idea that THEY know better than families what is best. Individual children and teenagers need individualized help, not an agenda-driven push from agenda-driven teachers and social workers.  Parental decision-making is a bedrock right.  NO to any regulations telling people what help they can and cannot provide to a struggling child.

CommentID: 74367
 

7/26/19  2:08 pm
Commenter: Irene Maria DiSanto

Do not ban requested therapy
 
  • 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. 
  • Under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. 
CommentID: 74369
 

7/26/19  2:53 pm
Commenter: Gerald Kuhn

parental right
 

 Oppose proposed amendment of 18 VAC 125-20

CommentID: 74379
 

7/26/19  3:06 pm
Commenter: Thomas J Duncam

Conversion Therapy
 

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.   

CommentID: 74385
 

7/26/19  3:10 pm
Commenter: Karla Taylor

In opposition of ban.
 

Virginia law protects the parents rights to make decisions for their children.  Law also protects children from being intimidated and coerced by therapist who pushed on the lgtb agenda when a child expresses confusion, we are seeing a huge overreach in this last part, and including many changes to the DSM to accommodate disorders as natural. Passing this ban will infringe on the rights of citizens, parental rights, and for some religious freedom. Passing this will also open the door to continued misconduct in the health field by coercing children to make choices they are not matured enough to make.

CommentID: 74388
 

7/26/19  4:36 pm
Commenter: John H Fittz

Social work should be confined to Disfunctional Family Situations
 

We the people have the God-given right to determine what laws and regulations control our behavior as law-abiding citizens, including parental rights to teach the truth to our children and grandchildren. The regulatory action being considered violates these rights and is opposed to common sense for the following reasons:

  • 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. 
     
  • 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. 

For these reasons, the subject regulatory actions are illegal and unconstitutional.

Please listen to the will of the people and desist from these actions.

Respectfully,

John H Fittz

CommentID: 74403
 

7/26/19  4:41 pm
Commenter: Jacqueline Manapsal

Parental 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. The proposed ban would deny families the freedom to seek counseling aligned with their faith. Parents have the fundamental right to care for their children until they become adults in their own right. 

CommentID: 74404
 

7/26/19  6:45 pm
Commenter: John Buczacki

Protect Parental 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. 
CommentID: 74457
 

7/26/19  8:24 pm
Commenter: Rita Poranski

parental Rights.
 

Parental rights are mine -  not those of an unelected group or individual.

CommentID: 74476
 

7/26/19  8:31 pm
Commenter: Cat Spinelli

PARENTAL RIGHTS
 

Parents are closest to their child's challenges, we are in the best position to make healthcare decisions regarding the wellbeing of our children.

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

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

CommentID: 74479
 

7/26/19  8:37 pm
Commenter: Mimi A

Stop the ban
 

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.
Parents have the fundamental right to make decisions regarding the upbringing, education and care of their children.  This must not be changed; if it is tampered with, where/when will it stop.  Being a preteen and teenager has always been a confusing time, but they are not adults yet; they need unhindered, loving guidance from their parents. 

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 values and/or faith.

CommentID: 74483
 

7/26/19  10:28 pm
Commenter: Martha Dreon

Opposition to adding the provisions of Guidance Document 125-9 to 18VAC125-20.
 

I oppose adding the provisions of Guidance Document 125-9 to 18VAC125-20.

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.  

 Sincerely,

Martha Dreon

CommentID: 74515
 

7/26/19  11:26 pm
Commenter: Rebecca Ing

support parental rights
 

Parents are closes to their child's challenges, they are in the best position to make health care decision involving the well being of their child.

CommentID: 74537
 

7/27/19  7:25 am
Commenter: lawrence zenker

Parents' rights and responsibilities
 

Parents have the duty and responsibility to nurture, teach, and provide moral support for their children.  This should not be usurped by the state.  We need stronger families in today's environment, not interference from outside sources.

CommentID: 74551
 

7/27/19  9:42 am
Commenter: Pamela Wilgus

Oppose Amending 18VAC140-20, Regulations Governing the Practice of Social Work
 

Oppose Amending 18VAC140-20, Regulations Governing the Practice of Social Work

 I oppose amending 18 VAC 140-20, Regulations Governing the Practice of Social Work and respectfully ask you to reject it too.

This proposal would infringe the fundamental right of parents to care for their children and violate their freedom of speech and free exercise of religion.

  • 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. 
CommentID: 74556
 

7/27/19  12:21 pm
Commenter: Mary

Parents should have the authority to decide for the children,
 

CommentID: 74560
 

7/27/19  1:38 pm
Commenter: Mary and Roger Ritter--Virginia Catholic Conference

Parental Choice in Counseling
 

Parents have the right to choose appropriate counseling for their children.

CommentID: 74562
 

7/27/19  2:16 pm
Commenter: Susana Lee

Protect parental rights
 

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

CommentID: 74568
 

7/27/19  2:45 pm
Commenter: Sue A. Huber

Protect parental rights regarding upbringing, education and care
 

 

 

 

  • 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. 

 



 

 

 

CommentID: 74572
 

7/27/19  2:49 pm
Commenter: Charles A. Huber

Protect parents' rights to make decisions regarding their children's upbringing, education and care
 
  • 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. 

 

CommentID: 74573
 

7/27/19  4:18 pm
Commenter: Carmencita B. Clay

Protect Parents' Rights to make Decisions about their own Children's Care, Upbringing and Education
 

I oppose this and any other regulation that seeks to infringe on parents' rights to care for their own children and make decisions about their upbringing and education for the following reasons:  

  • 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. 

 

CommentID: 74577
 

7/27/19  10:02 pm
Commenter: John Miller

Please respect the rights of your citizens
 

While this may sound like a sympathetic policy, it ventures into territory which usurps a parent’s rights.  This also prevents legitimate religious beliefs from being followed.  Lastly there is no study which provides the long term effects of the proposed actions.  This may cause irreversible changes in a child’s development, for an issue which they may later in life desire to not adhere to any longer.  I am certain that society will look back on this as an unfounded action, based on no evidence, having lifelong consequences, and locking people into a life that they may have been only passingly interested in living.  This is too far for the state to try commanding.

CommentID: 74584
 

7/27/19  11:18 pm
Commenter: Edward White

Regulatory Ban on Conversion Therapy
 

I write to oppose the plan to adopt, via regulation, a prohibition on the ability of psychiatric, psychological and counseling professionals to provide certain types of treatments for children who seek treatment for gender disphoria. First of all, as you well know, the General Assembly, elected by the people of Virginia have twice rejected such regulations. This blatant end run around the elected legislature is anti-democratic and outrageous!  Second, parents are closest to their child’s challenges, and 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, and there is no reason why parents ought to be deprived of the choice of how to treat the medical issues 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. Further, the proposed ban would deny families the freedom to seek counseling aligned with their faith.  Finally, 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.

CommentID: 74588
 

7/28/19  12:56 pm
Commenter: Maureen Barrett

Respect parents, citizens and elected officials
 

I write to oppose the plan to adopt, via regulation, a prohibition on the ability of psychiatric, psychological and counseling professionals to provide certain types of treatments for children who seek treatment for gender disphoria. First of all, as you well know, the General Assembly, elected by the people of Virginia have twice rejected such regulations. This blatant end run around the elected legislature is anti-democratic and outrageous!  Second, parents are closest to their child’s challenges, and 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, and there is no reason why parents ought to be deprived of the choice of how to treat the medical issues 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. Further, the proposed ban would deny families the freedom to seek counseling aligned with their faith.  Finally, 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.

CommentID: 74592
 

7/28/19  2:50 pm
Commenter: Edward Krattli

Protect the freedom and rights of Virginia families
 
Under the legal legislative process, attempts to impose a ban on legitimate counseling practices in Virginia failed in 2016 and 2018.  The legislative process involved debate and input by our duly elected state representatives who then voted for or against the misguided bills.
 
Unfortunately, unelected and biased state regulators are going forward with a sweeping proposal to ban the counseling, which would infringe upon the fundamental right of parents to care for their children and would violate their freedom of speech and free exercise of religion; arguably violations under Virginia law.
 
Because the General Assembly has not adopted the governor's extreme and misguided views, ban proponents and regulators appointed by the governor are seeking to impose prohibitions through regulation.  These regulators are attempting to bypass the General Assembly altogether, which has the effect of diluting and ignoring the voice of Virginia's citizens and their elected representatives.  
 
Please consider the following...
  • 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; not the state, and certainly not by unelected regulators.
     
  • 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, all counseling options should be available for families to use based on their particular needs.
     
  • 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. 
CommentID: 74595
 

7/28/19  9:21 pm
Commenter: Robert Lee

Defend parental rights and protect children in need
 

Patients should be able to freely discuss any topic that is troubling them with a counselor. This is especially the case for minors. If it is the will of the patient to seek counseling that helps them understand the roots of unwanted attractions or gender confusion, they should be able to do that with a skilled counselor. 

Do not put in place this wrong prohibition that will cause lasting harm to those seeking mental health counseling.

I have known individuals who sought counseling for their attractions but did not frame it as "conversion therapy" and found lasting help to understand their attractions and live in peace with it. Do not deny future patients that opportunity.

CommentID: 74601
 

7/29/19  9:50 am
Commenter: Craig Mays

Rights of Parents
 
  • 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 and beliefs.
     
  • 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. 
CommentID: 74604
 

7/29/19  11:34 am
Commenter: Gordon Goetz

Protect parental rights and stop censorship in counseling.
 

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

CommentID: 74611
 

7/29/19  1:46 pm
Commenter: Mark Menotti

Parental Rights
 

I am asking that you reject the 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.”   This proposal would infringe the fundamental right of parents to care for their children and violate their freedom of speech and free exercise of religion.  The proposal should be rejected because:

  • 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.
  • 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. 

This should never be allowed to become an Executive/administrative rout of a legislative domain.  Let this be debated in the Virginia Assembly and Senate.  These actions are devolving our Republic. Thank you.  Mark Menotti (Concerned Citizen)

CommentID: 74620