I am writing to strongly object to the proposed regulation. This regulation will interfere in privileged communications between minor patients and their therapists.  Because the proposed definition and ban cover all communication between a social worker and the client, there is a serious risk that children and families will lose the right to client “self-determination” in setting care goals (a core principle of the National Association of Social Workers Code of Ethics).

Moreover, under Virginia law, parents have the fundamental right to make decisions regarding the upbringing, education and care of their children. Parents are closest to their child’s challenges and they are in the best position to identify solutions and to make healthcare decisions involving the physical, mental, emotional and spiritual wellbeing of their child.

As noted in the introduction to a Fall 2016 New Atlantis review of the studies on sexual orientation, “While some people are under the impression that sexual orientation is an innate, fixed, and biological trait of human beings—that, whether heterosexual, homosexual, or bisexual, we are “born that way”—there is insufficient scientific evidence to support that claim. In fact, the concept of sexual orientation itself is highly ambiguous; it can refer to a set of behaviors, to feelings of attraction, or to a sense of identity… Overall, the evidence suggests some measure of fluidity in patterns of sexual attraction and behavior—contrary to the “born that way” notion that oversimplifies the vast complexity of human sexuality.

While I understand that some may view certain types of counseling in a negative light, other individuals, including minors, do want counseling to change or moderate their desires. Adolescents may go through phases in which they are unsure of their sexuality or have desires that they outgrow. Others may simply desire guidance on how to live a chaste life in conformity with their religious or philosophical beliefs. In either instance, there should be options for minors and their families to seek counseling aligned with their views.

Thank you for the opportunity to comment.