Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling


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3/19/19  7:20 pm
Commenter: Bambi Shingler

Conversion Therapy

Counselors are ALLOWED to help a minor client to explore and facilitate same-sex feelings, attractions and behaviors, or even to “change” their sex altogether, but they are strictly PROHIBITED from helping a minor client struggling with unwanted same-sex attractions from developing a natural and Biblical sexual ethic, or aiding a child dealing with gender dysphoria in learning to embrace his or her biological status as either male or female. So, children can change in one direction, but not the other. Why the bias? Please allow equal justice by allowing counselors to help those seeking to disengage from harmful dames sex attractions. Stop the one sided pursuit of encouraging sexual disfunction and discouraging common sense therapy choice.

The Boards “guidance” to counselors is clear and simple: If you hold to the natural, biological, historical and/or Biblical understanding of human sexuality, be prepared to lose your professional license. 

CommentID: 70299

3/19/19  7:28 pm
Commenter: Justin Jordan, Virginia Tech

Conversion therapy is unethical practice

Conversion therapy is, without a doubt, unethical practice and against the values of counseling and allied mental health professions. The archaic idea that mental health providers can or should change someone’s gender expression/identity or their affectional orientation is based on a history of stigmatization and pathologizing of normal and positive identities. The board of counseling has a moral and ethical responsibility to ban these practices that increase the risk of suicide of our brothers and sisters by traumatizing them via conversion therapy, which has no valid research support. Please ban this tactics immediately for the health and wellness of our society.

CommentID: 70303

3/20/19  7:06 am
Commenter: Carol Schall, Virginia Commonwealth University, Autism Center for Excellenc

Ban all conversion therapy

Conversion therapy, (aka: Sexual Orientation and Gender Identity Change Efforts) are not scientifically sound practices and they cause significant harm to all. Banning these practices from use with minors is a good start. Next we must ban them outright from all professional use. 

CommentID: 70394

3/20/19  7:11 am
Commenter: Isabel Jane Dowrick

Please ban conversion therapy

I am not a health care professional, but am aware of findings of professionals that sexual preferences, both hetero and non-hetero are not a product of a disorder, but rather the inherent makeup of an individual, and therefore conversion therapy should be banned because it runs counter to what we know about sexual preference.

CommentID: 70396

3/20/19  8:21 am
Commenter: Marlene meade

Ban Conversion Therapy

Conversion Therapy is unethical,, unkind, and unsupportive.  It causes great pain to those it is used on.  People are born differently and that’s ok.

CommentID: 70405

3/20/19  8:30 am
Commenter: Marcy Walsh

Conversion Therapy is Dangerous

Leading mental health organizations (APediatricsA, AMA, APsychiatricA, etc.) are opposed to the dangerous practice of conversion therapy.  There is no evidence that it is helpful and plenty of evidence that it is psychologically harmful to participants.  The practice should be considered abuse in this state and outlawed in order to protect children and adults.  Already members of the LGBTQ community experience suicide at greater rates than the general population.  Conversion therapy is dangerous. 

CommentID: 70408

3/20/19  9:12 am
Commenter: Stephanie Malady

Ban the erroneously named abuse known as Conversion Therapy

Leading mental health organizations (American Pediatrics Assn, American Psychiatric Assn, etc.) are opposed to the damaging effects of conversion therapy.  There is no evidence that it is helpful and plenty of evidence that it is psychologically harmful to participants.  The practice, simply put, is sanctioned abuse by this state and must be outlawed in order to protect the mental and emotional well being of both children and adults.  It can be reasonably argued that members of the LGBTQ community experience suicide and assault at greater rates than the general population, in part, due to the continued authorization of such bigoted abuses as Conversion therapy. 
The archaic idea that mental health providers can or should change someone’s gender expression/identity or their affectional orientation is based on a history of stigmatization and subjective, restrictive sexual identities. The board of counseling has an ethical responsibility to ban these actions that increase the risk of suicide of our children from trauma via conversion therapy. Ban this psychological and emotional torture immediately for the health and well being of our entire society.

CommentID: 70418

3/20/19  10:46 am
Commenter: Jane Cornelius

Conversion therapy is torture. Ban it!

I heard a talk recently by a man who had been forced to undergo conversion therapy.   He described how torturous it was to him psychologically, and of course it didn't have the desired effect.   Conversion therapy has been documented to have adverse effects, especially to youth.   Please help put an end to this traumatizing and barbarous practice. 

CommentID: 70441

3/20/19  10:55 am
Commenter: Julianna Williams, Virginia Tech

Ban Conversion Therapy

The mental health professions have agreed, based on extensive research, that same-sex sexual attractions, behavior and orientations are NOT indicative of mental or developmental disorders and attempts to change sexual orientation are unlikely to be successful and involve risk of harm.  Moreover, there are many natural and positive variants of human sexuality and the notion of "conversion" is misguided.  Conversion "therapy" is a dangerous and unethical practice and should be banned by the Board of Counseling.     

CommentID: 70444

3/20/19  11:43 am
Commenter: Rebecca Seymour

Conversion Therapy is Unethical

The DSM is a manual that most all clinicians in the United States work out of for guidance on diagnosis, treatment, considerations, and more. Clinicians rely on the information within the DSM to make sure that the work they are doing is helpful. Almost FIFTY YEARS ago homosexuality was removed from the DSM; therefore, there should be no clinician attempting to treat homosexuality in the present day.

The following is a list of ethical codes that using conversion therapy would break. After this list of ethical violations, there is a list of peer-reviewed sources (all published within the last 5 years) that discuss the harm that conversion therapy can cause.

A.1.a. Primary Responsibility: The primary responsibility of counselors is to respect the dignity and promote the welfare of clients. 

A.2.c. Developmental and Cultural Sensitivity

A.4. Avoiding Harm and Imposing Values

A.4.a. Avoiding Harm Counselors act to avoid harming their clients, trainees, and research participants and to minimize or to remedy unavoidable or unanticipated harm. 

A.4.b. Personal Values Counselors are aware of—and avoid imposing—their own values, attitudes, beliefs, and behaviors. Counselors respect the diversity of clients, trainees, and research participants and seek training in areas in which they are at risk of imposing their values onto clients, especially when the counselor’s values are inconsistent with the client’s goals or are discriminatory in nature. 

B.1.a. Multicultural/Diversity Considerations Counselors maintain awareness and sensitivity regarding cultural meanings of confidentiality and privacy. Counselors respect differing views toward disclosure of information. Counselors hold ongoing discussions with clients as to how, when, and with whom information is to be shared.

C.5. Nondiscrimination Counselors do not condone or engage in discrimination against prospective or current clients, students, employees, supervisees, or research participants based on age, culture, disability, ethnicity, race, religion/spirituality, gender, gender identity, sexual orientation, marital/ partnership status, language preference, socioeconomic status, immigration status, or any basis proscribed by law. 

C.7.a. Scientific Basis for Treatment When providing services, counselors use techniques/procedures/modalities that are grounded in theory and/or have an empirical or scientific foundation. 

C.7.b. Development and Innovation When counselors use developing or innovative techniques/procedures/ modalities, they explain the potential risks, benefits, and ethical considerations of using such techniques/procedures/ modalities. Counselors work to minimize any potential risks or harm when using these techniques/procedures/modalities

C.7.c. Harmful Practices Counselors do not use techniques/procedures/modalities when substantial evidence suggests harm, even if such services are requested. 

E.5.a. Proper Diagnosis Counselors take special care to provide proper diagnosis of mental disorders. Assessment techniques (including personal interviews) used to determine client care (e.g., locus of treatment, type of treatment, recommended follow-up) are carefully selected and appropriately used. 

E.5.b. Cultural Sensitivity Counselors recognize that culture affects the manner in which clients’ problems are defined and experienced. Clients’ socioeconomic and cultural experiences are considered when diagnosing mental disorders. 

E.5.c. Historical and Social Prejudices in the Diagnosis of Pathology Counselors recognize historical and social prejudices in the misdiagnosis and pathologizing of certain individuals and groups and strive to become aware of and address such biases in themselves or others.


Doyle, C. J. (2018). A New Family Systems Therapeutic Approach for Parents and Families of Sexual Minority Youth. Issues in Law & Medicine33(2), 223. 

McGeorge, C. R., Carlson, T. S., & Toomey, R. B. (2015). An Exploration of Family Therapists’ Beliefs about the Ethics of Conversion Therapy: The Influence of Negative Beliefs and Clinical Competence With Lesbian, Gay, and Bisexual Clients. Journal of Marital & Family Therapy41(1), 42–56.

Flentje, A., Heck, N. C., & Cochran, B. N. (2014). Experiences of Ex-Ex-Gay Individuals in Sexual Reorientation Therapy: Reasons for Seeking Treatment, Perceived Helpfulness and Harmfulness of Treatment, and Post-Treatment Identification. Journal of Homosexuality61(9), 1242–1268.

Turban, J. L., Beckwith, N., Reisner, S., & Keuroghlian, A. S. (2018). 4.10 Exposure to Conversion Therapy for Gender Identity is Associated With Poor Adult Mental Health Outcomes Among Transgender People in the US. Journal of the American Academy of Child & Adolescent Psychiatry57, S208. 

Mahler, L., & Mundle, G. (2015). A need for orientation: The WMA statement on natural variations of human sexuality. International Review of Psychiatry27(5), 460–462.

CommentID: 70460

3/20/19  1:06 pm
Commenter: Lindsay Grohowski

Coversion therapy is abuse and current research shows this practice is NOT effective.

CommentID: 70482

3/20/19  3:15 pm
Commenter: Erik Fessler

"Conversion Therapy" is Threat to Virginia Minors

I am writing to support restrictions - and an outright ban - on so-called "sexual orientation conversion therapy" in the Commonwealth.

Conversion therapy is opposed by most major professional health and mental health organizations (American Pediatrics Assn, American Psychiatric Assn, etc.) are opposed to the damaging effects of conversion therapy. These effects include significantly higher rates of depression and suicide among our fellow LGBTQ Virginians. Our children are suffering at the hands of a practice with no backing in science.

Please end this nightmare immediately.

CommentID: 70520

3/20/19  4:09 pm
Commenter: Christine Walther-Thomas

Ban Conversion Therapy--Bad Science and Disastrous Outcomes for All

I am opposed to Conversion Therapy on many levels--as a teacher educator, education policy researcher, social justice advocate, friend, colleagues, and most of all, as the proud mother of a wonderful gay man.

For more than 30 years, medical and mental health communities have rejected the practice of conversion therapy as quackery. Science shows very clearly it is impossible to the sexual orientation with which someone is born. Efforts to change an individual’s gender identity have disastrous effects for LBGTQ+ individuals and for their families. American Psychiatric Association declassified homosexuality as a mental disorder more than 40 years ago and in 1998 denounced conversion therapy because it is ineffective and causes "...substantial psychological pain by reinforcing damaging internalized attitudes.”  Similarly, the American Psychological Association rejected these practices many years ago and repeatedly affirmed its stance. Research clearly shows these misguided practices can produce serious physical and mental health to LGBTQ+ children, adolescents, and adults.  Many national and international organizations have also rejected these practices because they are not scientifically, socially-, or ethically sound.  Some of these organizations include the World Health Organization,  American Medical Association,  American Academy of Pediatrics,  American Academy of Child and Adolescent Psychiatry, and the American Counseling AssociationIn addition, more than 15 U. S. states, the District of Columbia, and 50+ major cities have banned conversion therapy.

Good public policy is based on evidence, core principles and values, and respect for all. Unfortunately, well-respected research often takes years to become the everyday evidence needed to improve the lives of people. When it does, effective policies and practices replace ineffective ones; knowledge and skills unfounded myths, fears, and superstitions and social attitudes change.. The Commonwealth has long been recognized as a national and international leader championing knowledge, justice, freedom, and respect for all.  As such, Virginia must help lead the way of banning conversion therapy and ensuring the protection of our citizens and especially our most vulnerable children and youth.

CommentID: 70532

3/20/19  8:31 pm
Commenter: Jenny Moore

Ban Conversion Therapy

Homosexuality is not a mental disorder in need of being changed. Conversion therapy is not an appropriate treatment plan for any individual. Psychological peer-reviewed journals site that conversion therapy is not effective in changing an individual's sexual orientation. It is appaling that in 2019 there would still be a discussion about the validity of this unethical practice. 

CommentID: 70597

3/20/19  9:57 pm
Commenter: Susan Moore

Long overdue!

Conversion therapy been rejected by every mainstream medical and mental health organization for decades.  It is a very harmful practice. Young people are especially vulnerable as conversion therapy can lead to depression, anxiety, drug use, homelessness, and suicide.

To date, over a dozen states have laws or regulations protecting youth from this abusive practice. I am glad that Virginia plans to get on board and prohibit licensed counselors from engaging in conversion therapy. This is long overdue. 

CommentID: 70616

3/20/19  10:29 pm
Commenter: Jennifer Oribello

Sexual conversion therapy is an abhorrent and abusive practice

Sexual conversion therapy is a abusive practice that should not be permitted in the Commonwealth, and any medical professional who performs such "therapy" should be subject to discliplinary action by the Virginia Board of Psychology if not have their license revoked. To force a child, or anyone, against their will to change their sex is medically unnecessary and factually ineffective at what it purports to achieve. Being gay, lesbian or transexual is not a choice and those who would attempt to "fix" a child's gender through converstion therapy are only creating physical and mental trauma. 

CommentID: 70620

3/22/19  4:41 pm
Commenter: William A Harrison Jr

"Conversion therapy" does not work

I went through "Christian" therapy years ago and as an end result married a woman. I knew full well that i was still homosexual, but did what i thought God wanted me to do. As an end result my marraige ended in a horrible, painful divorce. and trust me, none of that "was what God wanted." Sexual orientations cannot be changed. Putting children through this IS THE SIN, not being gay.

CommentID: 70661

3/22/19  5:34 pm
Commenter: Renee Staton

Conversion Therapy is Unethical Practice

SAMHSA has provided 3 compelling points relevant to considerations of conversion therapy:

  • Diversity regarding gender identity and expression is normal
  • The premise on which conversion therapy is based is not supported by research; and
  • Interventions such as conversion therapy can be harmful and should not be considered viable treatment options.

These points clearly indicate that conversion therapy is an unethical practice that is not endorsed by professional counseling and psychology organizations. This position has been affirmed, in various ways, by the American Counseling Association as well as other reputable organizations such as the American Psychiatric Association, the American Psychological Association, and the National Association of Social Workers.

I appreciate the Board of taking the step of joining other states and ensuring that licensed counselors in Virginia do not engage in unethical practice and may not refer to individuals who offer this practice.

CommentID: 70662

3/22/19  7:13 pm
Commenter: Richard Rutherford

ban so-called "conversion therapy," especially for minors

This fake, destructive "therapy" does just the opposite of "no harm."  It is known to cause damage to the extent of self-destructive behavior, and most critically, is never successful in changing a person's sexual orientation. Please do not allow it in the Commonwealth.

CommentID: 70663

3/24/19  2:54 pm
Commenter: Ralph

conversion therapy

tell the VA Board of Counseling not to punish licensed counselors for helping patients overcome their unwanted sexual feelings by affirming biological realities concerning male and female.  The key word being unwanted.  And it should be between a counselor and the patient to decide which route to take.

CommentID: 70669

3/25/19  11:00 am
Commenter: William Esswein

Ban Conversion Therapy NOW!

I am delighted to here that the VA Board of Counseling is considering putting a ban on conversion therapy. I believe this is also long overdue, especially since there has long been evidence that it does not work. In fact, the evidence points in the direction of conversion therapy being harmful towards those who are put through it. It is unethical and irresponsible for any counselor in this day and age to be practicing this type of therapy. Potential clients deserve to be protected from this harmful practice henceforth.

CommentID: 70686

3/25/19  8:24 pm
Commenter: Julie Miller

Ban conversion therapy
Conversion therapy does not make gay people straight. It makes gay people (usually gay kids) ashamed and guilt-ridden. The kids wind up full of such self-loathing that they wind up committing suicide. We need to protect our LGBTQ youth from this harmful practice and show them we love them exactly as they are.
CommentID: 70703

3/27/19  10:35 am
Commenter: Jamie Bennett

Conversion Therapy

A counselor should be able counsel a minor according to the specific needs of the child. They should not be restricted from discussing the option and benefits of pursuing a heterosexual relationship. The focus is all pointing towards encouraging children to pursue homosexual relationships. Anyone that discusses the alternative is branded homophobic and in the case of a counselor, the movement is to outlaw promotion of heterosexuality. Minors are highly impressionable and many are influenced by their peers, teachers, and peers. Hollywood promotes homosexuality. The LGBTQ community is militant about promoting their agenda and that is to silence all opposing viewpoints. I ask that you please not ‘outlaw’ the ability for counselors to discuss the benefits of  heterosexuality with their patients.

CommentID: 70736

3/28/19  11:25 am
Commenter: Equality Virginia

Re: Support for Guidance Document 115-10, on the Practice of Conversion Therapy

Dear Virginia Board of Counseling,


Equality Virginia is pleased to support Guidance Document 115-10, 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 counselors 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, 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] 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] 


Virginia law already prohibits discredited and unsafe practices by licensed therapists. This guidance would prevent licensed psychologists 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 guidance 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 guidance.



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).

CommentID: 70742

3/28/19  11:40 am
Commenter: Jeff Caruso, Virginia Catholic Conference

Oppose Guidance Document

Dear Virginia Board of Counseling,

The Virginia Catholic Conference is the public policy agency representing Virginia’s Catholic bishops and their two dioceses. The Conference urges the Board of Counseling to reject the draft “Guidance Document on the Practice of Conversion Therapy (115-10).” If implemented, 115-10 would usurp the primary and fundamental role of parents, violate First Amendment rights, and exceed regulatory authority. 

Role of parents

Healthcare decisions involving the mental and emotional health of children do not fit neatly into “one-size-fits-all” regulations. Parents are closest to their children’s challenges. They know their unique needs and are in the best position to identify solutions. Some young people may have attractions they desire to change or moderate. Others may simply desire counseling to live a chaste life compatible with their religious or personal values. In either instance, there should be options available for families to make informed decisions.

Just as parents must give consent for over-the-counter medications,[1] field trips, and extracurricular activities, they have the constitutional right to guide mental health care for their children.

The child is not the mere creature of the State; those who nurture him and direct his destiny have the right, coupled with the high duty, to recognize and prepare him for additional obligations.[2]

115-10 also violates the presumption of parental autonomy in Virginia. Code Sec. 1-240.1 provides that a parent has the fundamental right to make decisions concerning the upbringing, education and care of the parent’s child. 

Families should also be free to make these decisions in private consultation with their child’s counselor.

First Amendment

The First Amendment prohibits the government from favoring one viewpoint over another. 

[T]he government has no power to restrict expression because of its message, its ideas, its subject matter or its content…. [T]he requirement that the government be content neutral in its regulation of speech means that the government must be both viewpoint neutral and subject-matter neutral. The viewpoint-neutral requirement means that the government cannot regulate speech based on the ideology of the message.[3]

115-10 defines “conversion therapy” or “sexual orientation change efforts” as any practice or treatment that seeks to change an individual’s sexual orientation…or eliminate or reduce sexual or romantic attractions or feelings toward individuals of any gender. Because it seeks, for example, to prohibit the provision of licensed services to help clients achieve alignment between their subjective sense of gender and their objective biological sex while permitting services to assist clients towards a subjective sense of gender at odds with their objective biological sex, it is neither content nor viewpoint neutral. In addition, 115-10 would allow those who provide services to assist clients in directing their attractions in one direction but not in the other direction.

Document 115-10, therefore, gives the Board sweeping authority to sanction counselors’ speech and engage in unconstitutional viewpoint discrimination.

As applied to faith-based, licensed counselors, 115-10 also would result in censorship of religious beliefs in violation of the First Amendment.

To comply with 115-10, these counselors must terminate or self-censor any conversation with a client that may tend toward reducing same-sex attraction, regardless of the client’s or family’s desire to seek counsel. Because of this, 115-10 would also impermissibly restrict a patient’s First Amendment freedom to speak candidly about intimate concerns and to receive counsel.

Ethics rules should be enforced and frequently examined for effectiveness and uniformity across all professions. They should also not be applied in ways that are biased to favor certain viewpoints or to target others for sanction. At a minimum, speech must be protected.

Conversely, 115-10 sets a double standard.  It does not, for example, sanction dangerous treatments to accelerate “gender transition” among children, e.g., through irreversible surgery or hormonal treatments.

Exceeding regulatory authority

For reasons such as those explained above, the General Assembly has rejected legislation to ban “conversion therapy.” In 2016, the legislature rejected three such bills in committee: (SB 262 and SB 267, Senators Surovell and Dance; and HB 427, Delegate Hope) that would have prohibited “conversion therapy” on persons under 18 to change sexual orientation or gender identity. 

Similarly in 2018, the General Assembly rejected two bills (HB 363, Delegate Hope; SB 245 Senator Surovell) which would have prohibited counselors from providing any treatment to those under 18 which would seek 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 the same sex. Nearly identical to 115-10, these bills were also defeated in committee.

Administrative agencies can adopt rules and policies to carry out duties delegated by the legislature. The rules and policies, however, should be consistent with statutory provisions.[4] The General Assembly has specifically and repeatedly rejected proposed “conversion therapy” bans. The Board does not have the authority to adopt 115-10 because doing so would circumvent the General Assembly’s decisions in this matter.

Accordingly, the Virginia Catholic Conference urges the Board of Counseling to reject 115-10.



Jeff Caruso

Executive Director

Virginia Catholic Conference



[2] Pierce v. Society of Sisters, 268 U.S. 510 (1925). See also Wisconsin v. Yoder (1972).

[3] Erwin Chemerinsky, Content Neutrality as a Central Problem of Freedom of Speech in the Supreme Court’s Application, Southern California Law Review, Vol. 74: 49, 51 (2000). Citing Police Dep’t. v. Moseley, 408. U.S. 92, 95 (1972).

[4] Mobil Oil Exploration & Producing Southeast v. United Distrib. Cos., 498 U.S. 211 (U.S. 1991)

CommentID: 70743

3/29/19  12:45 pm
Commenter: Elizabeth Surma, VCU

Ban Conversion Therapy!

Ban conversion therapy! It only causes harm! It is a horrible practice that is unfounded in research. No person should ever have to suffer through conversion therapy due to ignorant practices.

CommentID: 70770

3/30/19  6:06 pm
Commenter: Sarah Deprey-Severance

Stop Conversion Therapy

I am writing in support of Guidance Document 115-10: Guidance on conversion therapy. “Homosexuality,” or same-sex attraction and partnership, has not been listed as a diagnosable psychiatric condition since 1973. Still, social stigma and mainstream narratives about how humans ought to be in consensual relationship (romantic, sexual) with other humans continues to contribute to pathologizing of non-heterosexual identities, and LGBTQ+ youth are vulnerable to these narratives and judgements. LGBTQ+ youth are three times as likely as their non-LGBTQ+ peers to report suicidality and are six times more likely to experience depression than the general population (Marshal et al., 2011; NAMI, 2019). This already vulnerable population should not be subject to ineffective and harmful treatments like conversion therapy. Research on conversion therapy from peer-reviewed literature released by the American Psychiatric Association, the American Psychological Association, and the American Academy of Child and Adolescent Psychiatry has shown no evidence that conversion therapy is effective in changing sexual identity, and other peer-reviewed journals have published evidence that this treatment is harmful (Drescher, 2016).  

            Certainly, mental health professionals may encounter clients who are interested in changing their sexual identity, and yet mental health professionals would do well to wonder about the why of this request. LGBTQ+ youth often experience “minority stress,” which, according to NAMI (2019) are disparities in this community, made from a combination of “social stigma, discrimination, prejudice, denial of civil and human rights, abuse, harassment, victimization, social exclusion and family rejection.” This minority stress may be a primary factor in a young person’s desire to change their sexual identity, since humans are wired to be in connection with others, and the components of minority stress, as listed above, produce considerably disconnected experiences.

            Before engaging in treatment, it is important for mental health professionals to understand the context in which a client is experiencing distress, and certainly if that distress is societally-inflicted and not due to the fault of the client of interest (which is how I, as an emerging mental health counselor, conceptualize difficulty related to sexual identity in clients I see), it would be important to instead treat the distress in a way that is affirmative, empowering, and healing. As the American Counseling Association (2013) states in “Ethical issues related to conversion or reparative therapy,” counselors are ethically bound to share information about potential treatments and must have expertise and training in the treatment methods they utilize. Since there is no ACA-approved training or certification for conversion therapy, a counselor engaging in conversion therapy is not acting within the ethical code for the profession, and counselors who are being asked to provide referrals for a therapist who offers conversion therapy are bound by the ethical code of the profession to share this information with the client prior to a referral, as well. I encourage anyone within the field of professional counseling, mental health, and the helping professions to read the ACA statement on conversion therapy to clarify how the counseling profession views conversion therapy, located here:

CommentID: 70784

3/31/19  2:10 pm
Commenter: Aleta E Strickland EdS, NCSP, Louisa Psychological Consulting, PC

Protect vulnerable youth and end child abuse disguised as mental health treatment.

The idea that homosexuality is a mental disorder or that the emergence of same-sex attraction and orientation among some adolescents is in any way abnormal or mentally unhealthy has no support among any mainstream health and mental health professional organizations. Any practitioner using it is doing so fraudulently and unethically. It is time for Virginia to protect its youth by banning this horrific practice. Why are we allowing clinicians to harm children? The only outcomes documented from this approach are negative and harmful. Make it stop.

CommentID: 70790

4/3/19  2:16 pm
Commenter: Kirsten O'Nell

Ban Conversion Therapy

Conversion therapy is torture plain and simple.  It does long term damage to a child's psyche and should never be practiced.

CommentID: 70862

4/3/19  7:00 pm
Commenter: Zachary Whitten, Virginia Commonwealth University

End Conversion Therapy

I wholeheartedly support guidance document: 115-10 and wish for it to be enacted. As noted in the document, conversion therapy "does not work, can cause harm, and violates [The ACA's] Code of Ethics". For this reason alone, conversion therapy should be prohibited in Virginia. But moreover, conversion therapy is a disgusting practice which seeks to invalidate the LBGTQ+ community. As noted in 115-10, "The ACA Ethics Committee states that counselors who conduct this type of therapy view same-sex attractions and behaviors as abnormal and unnatural and, therefore, in need of 'curing'". I see no way Virginia can proclaim itself an inclusive commonwealth,  can hold "Virginia is for Lovers" as a motto without burning hypocrisy, if it allows such a horrifying and undignified practice to be allowed. For upholding basic human dignity, I respectfully implore you to enact guidance document: 115-10.

Zachary Whitten

CommentID: 70879

4/6/19  9:25 am
Commenter: Latasha Howlett

Not your place!

It is not your place to dictate or overthrow Christian idealogies to support culture's idea of societal norms.  As a Christian it is my right to seek out assistance for my child that may struggling with any  sin including same sex attraction.  To suggest that my efforts are harmful emphasis just how far this culture has moved from the truth of JESUS!  There is nothing wrong with seeking help if a person is struggling and limiting a parent's ability to raise their child so long as it does not  offend a subset of the culture is not cool. This subset is always talking about tolerance how about they show some tolerance for those that disagree with them. I don't tell anyone how to live their lives don't dictate to me how to live mine or raise my kids


iot right 

CommentID: 71037

4/6/19  9:52 am
Commenter: Michael Kim

In support of Jeff Caruso
I support the comment submitted by Jeff Caruso who is against the ban.
CommentID: 71038

4/6/19  3:46 pm
Commenter: Sue Barger


As with any medical and mental health procedures, safe and effective is always part of the goal. To say no to conversion therapy as a whole is BOGUS to say the least.

As for the POLITICS surrounding this topic, let me REMIND, the US Declaration of Independence was written BEFORE the US Constitution—the first thing our Founders did in forming this nation was to declare our Creator and that our rights come from him, so by recognizing the Creator, we recognize his standards, thusly a child in the womb as a life and people are physically born male and female, stating otherwise is contrary—so, if you choose to be contrary and not recognize this Creator, please know you live in a nation that tolerates non-belief but learn to BE AS TOLERANT AND RESPECTFUL AS THE FEW EARLY AMERICANS who were contrary to the Creator but that recognized the good in the Protestant principles of Liberty and Freedom.  

Unfortunately and wrongfully, far too long the spirit of US Declaration has been divorced from the US Constitution in many arenas and especially in decision making, this must be reconciled. Thank you.

CommentID: 71039

4/6/19  5:24 pm
Commenter: Katherine

Ban conversion therapy

Please ban the awful and dangerous practice.. freedom of religion doesn’t give anyone the right to hurt others 

CommentID: 71040

4/8/19  9:00 pm
Commenter: Carey Mason Perkins

Ban conversion therapy

Please, Virginia, ban this therapy which is known to be harmful to gay and lesbian children and adults. Just show them we love them just the way they are!




CommentID: 71049

4/8/19  10:06 pm
Commenter: Susan Ricci

Ban Conversion Therapy

Conversion therapy should be banned.  It is damaging to our LGBTQ citizens.  LGBTQ youth especially need support and acceptance.  Being homosexual isn’t a disease that can be treated and eradicated.  

CommentID: 71050

4/9/19  10:38 am
Commenter: Deborah Cohen

Ban Conversion Therapy

Gay people are just fine the way they are. “Conversion therapy” is a bunch of religious nonsense used by Christian supremacists to enforce their hate of gay people using the law.  Thank you for standing against this utter stupidity and hate!  The only conversion therapy needed is to convert white/male/religious/wealth supremacists into human beings with compassion & empathy!

CommentID: 71052

4/9/19  4:08 pm
Commenter: Josh Hetzler, Legislative Counsel for The Family Foundation of Virginia

Unlawful Prior Restraint on Speech

I write to express The Family Foundation of Virginia's opposition to the Board of Counseling's proposed Guidance Document 115-10. Such guidance will not only cause numerous ethical and moral harms to professionals, and developmental harms to children, but it is at odds with the laws of Virginia and the Constitution of the United States. 

As a general matter, the Virginia Code expressly provides that parents, not the government and its regulatory agencies, have a “fundamental right to make decisions concerning the upbringing, education, and care of the parent's child.” Va. Code § 1-240.1 However, the effect of this Guidance Document would unduly limit the right of parents to make decisions concerning the upbringing, education, and care of their child by preventing them from getting them the help they and their child need and desire.

Virginia’s constitution declares that “the right to be free from any governmental discrimination upon the basis of religious conviction . . . shall not be abridged[.]” Constitution of Virginia, Article 1, Section 11 (Bill of Rights). This Guidance Document would directly discriminate against Christian, Jewish, and Muslim health professionals who maintain, as a fundamental tenet of their faith, that human beings are created by God as either male or female and that human sexuality is only properly expressed between a man and a woman in the context of marriage. Such a conception of human sexuality reflects the historical, conventional, and orthodox views of these major faith traditions, and has transcended cultures and boundaries for millennia. Denying licensed psychologists through this policy the right to acknowledge this while acting in their professional capacity subjects them to "discrimination on the basis of religious conviction," and thus runs afoul of one of Virginia’s most basic constitutional guarantees.

The Board's policy as expressed in this proposed Guidance Document would also be unconstitutional in light of the U.S. Constitution because it would infringe on the free speech rights of professional counselors by prohibiting them from speaking certain messages (or, if not strictly prohibiting it, then by significantly "chilling" their free speech). In 2018, the U.S. Supreme Court rejected the state of California’s claim that so-called “professional speech” receives less First Amendment protection than ordinary speech, stating that: “This Court has not recognized ‘professional speech’ as a separate category of speech. Speech is not unprotected merely because it is uttered by ‘professionals.’” National Institute of Family and Life Advocates (NIFLA) v. Becerra, 138 S. Ct. 2361, 2371-72 (2018).

The Supreme Court's opinion highlighted three cases – two of which involved state bans on so-called “conversion therapy” for minors – as being erroneously decided for holding that counseling was afforded less constitutional protection as a matter of free speech. As a result, the lower court cases upholding bans on “conversion therapy” were effectively overruled. Because this policy would have the direct and immediate effect of censoring the protected speech of health professionals in Virginia, it would not likely survive a legal challenge. If this Board does go forward with such a violation of free speech, it should expect such a challenge. 

Effectively prohibiting the practice of so-called “conversion therapy” among licensed counselors, as the draft Guidance Document defines that term, goes too far in its attempt to address the hypothetical concerns some have raised. (It is worth noting that no known complaint has ever been received by any of the health regulatory boards concerning "conversion therapy.") As the term is now over-broadly and vaguely defined, it “compels individuals to contradict their most deeply held beliefs, beliefs grounded in basic philosophical, ethical, or religious precepts, or all of these.” NIFLA v. Becerra, 138 S. Ct. 2361, 2379 (Kennedy, J., concurring).That is something this Board may not do.

The Supreme Court in NIFLA cautioned that “when the government polices the content of professional speech, it can fail to ‘preserve an uninhibited marketplace of ideas in which truth will ultimately prevail.’” Id. at 2374 (quoting McCullen v. Coakley, 134 S. Ct. 2518, 2529 (2014)). There are significant disagreements about the merit of therapies which help a young person resolve, and in many cases by reversing (read testimonies of many for whom this happened at their unwanted sexual attractions or gender confusion. These disagreements should be settled in the marketplace of ideas and according to the wishes of the minor and his or her parents. The effect of this regulation, however, would only be to silence unpopular ideas and suppress information.

We urge this Board to heed the U.S. Supreme Court’s words when it observed that “‘the best test of truth is the power of the thought to get itself accepted in the competition of the market’ and the people lose when the government is the one deciding which ideas should prevail.” Id. at 2375 (quoting Abrams v. United States, 250 U.S. 616, 630 (1919) (Holmes, J., dissenting)).

CommentID: 71055

4/9/19  5:08 pm
Commenter: Casey Pick, The Trevor Project

Support for Guidance Document 125-9, on the Practice of Conversion Therapy

Dear Virginia Board of Counseling,

The Trevor Project is proud to support Guidance Document 125-9, 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.

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.

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.

The Trevor Project is invested in ending conversion therapy in every state because we know from experience and rigorous social science that conversion therapy contributes to an increased likelihood of suicide attempts among the youth we exist to serve. Recent research by The Family Acceptance Project has found that rates of attempted suicide by LGBT youth whose parents tried to change their sexual orientation were more than double (48%) the rate of LGBT youth who reported no such attempts to change their orientation (22%). Suicide attempts for LGBT young people who reported both home-based efforts to change their sexual orientation by parents and formal change efforts by therapists and/or religious leaders were three times higher (63%).      

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 guidance would protect.

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 guidance 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 guidance 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 Guidance Document 125-9. Thank you for your consideration of this importance guidance.


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

CommentID: 71056

4/9/19  5:10 pm
Commenter: Rev. Donald Spitz

VA Board of Counseling should not punish licensed counselors

VA Board of Counseling should not punish licensed counselors for helping patients overcome their unwanted sexual feelings by affirming biological realities concerning males and females

CommentID: 71057

4/9/19  5:11 pm
Commenter: Mark Bowyer


There is a serious free speech principle here. While some forms of therapy may indeed cause harm, it is up to the medical community to oversee that, NOT the government. The matter of whether people may need or want therapy to address their sexuality is a personal one. Banning ANYTHING related to therapy is an egregious overstepping of constitutional rights. All these folks that want conversion therapy banned are barking up the wrong tree! NOT a matter for governent!

CommentID: 71058

4/9/19  5:12 pm
Commenter: Judy Cook

Christian counseling

Christian counselors have the right to offer counsel based on a Biblical worldview as well as the latest scientific research.   

Judy Cook.  over this text and enter your comments here. You are limited to approximately 3000 words

CommentID: 71059

4/9/19  5:13 pm
Commenter: William Hyde

Don’t stop peoplw from getting the help they want

Don’t listen to activists looking to the state to enforce their beliefs by violating g other people’s first amendment rights. No one forced people to participate in therapy and any abusive therapeutic relationships are are already covered by other laws and regulations. If people want to undergo therapy and a therapist wants to help them they should be allowed to do so. Mental health treatments need to be left to therapists and their patients. 

CommentID: 71060

4/9/19  5:17 pm
Commenter: Patricia Magyar

NO censorship: administrative regulations!!!

Please stop the hostility towards counselors who uphold these natural, biological and/or Biblical viewpoints of human sexuality, and its willingness to violate any and all free speech and conscience protections in order suppress these deeply held beliefs. Please do not punish licensed counselors for helping patients overcome their unwanted sexual feelings by affirming biological realities concerning males and females.

CommentID: 71061

4/9/19  5:22 pm
Commenter: Stephanie Seely

freedom of conscience for counselors and safety for the families they help

Do not punish licensed counselors for helping patients overcome their unwanted sexual feelings by affirming biological realities concerning males and femalesThis is censorship! It presents an ethical dilemma for counselors who do not agree with this policy, and will damage the children being counseled. To take away a counselor's license because he/she followed their conscience is WRONG!

CommentID: 71062

4/9/19  5:24 pm
Commenter: George Elliott

counseling gender confusion

 The VA Board of Counseling should not punish licensed counselors for helping patients overcome their unwanted sexual feelings by affirming biological realities concerning males and females.

CommentID: 71063

4/9/19  5:29 pm
Commenter: Paul Perrone

Let Counselors Do Their Job

Counselers should be allowed to do their jobs to help patients who want to change.  They should not be held hostage to well-financed political organizations who have a political agenda to change the culture.

CommentID: 71064

4/9/19  5:31 pm
Commenter: Marsha Johnson

Allow clients with unwanted same sex feelings to get the help they want

When a child wants help with unwanted same sex feeling you are forbidding him or her from getting that help.  Do not punish licensed counselors for helping patients overcome their unwanted sexual feelings by affirming biological realities concerning males and females. Banning honest communication between therapist and client creates a blatant double standard whereby counselors would be free to help minor clients explore and possibly cultivate same-sex feelings or even to “change” their gender, while simultaneously prohibiting them from helping minor clients flee from unwanted same-sex attractions and embrace natural sexual expressions and/or their true gender.  Licensed counselors have a responsibility to speak honestly with their minor clients about life’s fundamental truths, and any state policies that compel them to repress those truths during counseling would lead to real ethical dilemmas, not to mention damage to those children. 

CommentID: 71065

4/9/19  5:39 pm
Commenter: Henry Polczer

Counselors MUST be allowed to speak their option

Allow counselors to speak honestly and not be centured by the state!  Licensed counselors have a responsibility to speak honestly with their minor clients about life’s fundamental truths, to include dealing with harmful same sex attraction, and any state policies that compel them to repress those truths during counseling would lead to real ethical dilemmas, not to mention damage to those children.

CommentID: 71066

4/9/19  5:43 pm
Commenter: Richard W Firth


IT IS GOD'S MOST HOLY WILL not to punish licensed counselors for helping patients overcome their unwanted sexual feelings by affirming biological realities concerning males and females. This is a SPIRITUAL MATTER not a secular one with grave consequences for not dealing with it as such.

Gpd created us either a female or male with no go betweens  Until we realize we are but one sex, either a male or female people will have no peace or happiness.

CommentID: 71067