Dear Virginia Board of Nursing,

The Trevor Project is proud to support Guidance Document 90-5 to 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 guidance 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. This guidance serves 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 90-5 protecting LGBTQ youth from conversion therapy. Thank you for your consideration of this importance guidance.

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

I support this guidance document and hope to see a ban on nursing professionals practicing a disproven method like “conversion therapy” in Virginia.

Please end the outdated and dangerous practice of conversion therapy as it has been proven to cause an increased risk for suicide. 

I write as a retired Registered Nurse living here in the Commonwealth.  I encourage the Board to ban the practice of conversion "therapy".  There is nothing therapeutic about it.  ype over this text and enter your comments here. You are limited to approximately 3000 words.

Conversion therapy is documented to have caused or contributed to an enormous amount of psychological distress in LGBTQ people, dramatically increasing rates of self injury and suicide relative to the overall population. It is cruel, inhumane, and entirely unnecessary in any case. Therefore, I wholeheartedly support the proposed Board of Nursing guidance classifying the practice as unprofessional conduct. 

We know from countless studies that conversion therapy is not only ineffective, but also incredibly harmful to those subjected to its abuse. 

Conversation therapy is a cruel and abusive tactic to scare and traumatize LBGTQ+ individuals for life. Its use should be disavowed by the Board of Nursing which stands to do no harm and to do what is right by all our patients, regardless of sexual orientation, gender presentation or anything that makes us unique. 

As a member of the LGBTQIA+ Community, it could not cause me more stress to know that there are individuals in this state still being forced to partake in conversion therapy. An ineffective and inhumane approach to “alter one's sexual orientation” in the name of God is outrageous. We adhere to a set of rules outlined in the constitution, one of which being separation of church and state. If a government official were to believe, because of said religious beliefs, that a child without the ability to make a legal, medical decision for themselves or neighbor or whoever be placed under conversion therapy, that government official would be blatantly disregarding the constitution. I hope you guys make the right choice in following our constitution, and the health of all LGBTQIA+ Virginians. 

Dear Virginia Board of Nursing,

The Human Rights Campaign (HRC), on behalf of its more than 151,000 members and supporters in Virginia, thanks you for the opportunity to affirm support for the Virginia Board of Nursing Guidance Document on the Practice of Conversion Therapy. This guidance is an important step in the effort to protect minors in Virginia from the dangerous and discredited practices that falsely claim to change their sexual orientation or gender identity.

The Human Rights Campaign is America's largest civil rights organization working to achieve lesbian, gay, bisexual, transgender and queer (LGBTQ) equality. By inspiring and engaging all Americans, HRC strives to end discrimination against LGBTQ people and realize a world that achieves fundamental fairness and equality for all. As an advocate for LGBTQ young people, HRC believes that no young person should be subjected to dangerous practices that lack legitimate medical purpose, such as conversion therapy. 

Conversion therapy, sometimes referred to as “reparative therapy” or “sexual orientation change efforts,” are practices that seek to change a person’s sexual orientation or gender identity. These practices are based on the false idea that being LGBTQ is a mental illness that needs to be cured—an idea which has been rejected by every major medical and mental health group. 

There is no credible evidence that conversion therapy can change a person’s sexual orientation or gender identity, and it is abundantly clear that conversion therapy poses devastating health risks for LGBTQ youth including depression, decreased self-esteem, substance abuse, homelessness, and even suicidal behavior.  This is why the nation’s leading mental health organizations have ubiquitously decried these unscientific practices. 

Unfortunately, due to discrimination against LGBTQ people and the fact that professional rules have not kept up with this widespread understanding, some licensed mental health professionals continue to engage in conversion therapy.  A recent Williams Institute at UCLA School of Law report revealed that an estimated 20,000 LGBTQ minors in states without protections will be subjected to conversion therapy by a licensed healthcare professional if state officials fail to act. Additionally, a 2018 study from the Family Acceptance Project at San Francisco State University found that suicide attempts nearly tripled for LGBTQ youth who reported both home-based efforts and outside-the-home efforts to change their sexual orientation (compared to LGBTQ youth who did not experience such change efforts).

Providers who engage in conversion therapy under state license mislead families about the risks involved, leading to negative psychological outcomes, irreparable damage to family cohesiveness, and lasting personal and social harms. Regulatory action is needed to protect families from these damaging practices.

Thank you for the opportunity to comment in favor of this vital proposed guidance.

Sincerely,

Sarah Warbelow

Legal Director, Human Rights Campaign

To Whom It May Concern:

On behalf of the youth and families of Side by Side (formerly ROSMY), I write in support of protecting youth under the age of 18 from so-called “conversion therapy” in Virginia. For over 25 years, Side by Side has provided support and mental health counseling to lesbian, gay, bisexual, transgender, queer, and questioning youth ages 11-20 in Central Virginia. We have witnessed first hand the damage “conversion therapy” has on the mental health and stability of LGBTQ+ youth.

Being LGBTQ+ is not a psychological disorder that needs to be “converted” or “changed.” This practice sends a message that there is something wrong with who LGBTQ+ youth are and that they need to be “fixed,” when in fact if they are loved and accepted they can truly flourish. Instead of offering to change someone’s sexuality or gender identity, LGBTQ+ youth should be affirmed in who they are and provided emotional peer and adult support.

Additionally, there is no credible evidence that this type of therapy works at all. Interestingly, Robert Spitzer, one of the initial leaders in “conversion therapy” has come out against the practice stating in an April 2012 letter to the editor of Archives of Sexual Behavior:

“I believe I owe the gay community an apology for my study making unproven claims of the efficacy of [conversion]/reparative therapy. I also apologize to any gay person who wasted time and energy undergoing some form of [conversion]/reparative therapy because they believed that I had proven that [conversion]/reparative therapy works…”

Even though this form of therapy does not work and even though there is nothing wrong with a young person being LGBTQ+ or questioning their gender or sexuality; LGBTQ+ youth still face intense bullying, harassment, and even violence both at school and sometimes at home. Parents of LGBTQ+ youth may turn to “conversion therapy” as a means to stop the pain their child is enduring. They deserve to know the dangers of this practice and that it will not and cannot change their children. These parents and their children deserve to see counselors who can affirm who they are and provide the emotional support and guidance they need.

We implore you to consider adopting this ban on “conversion therapy” and ensuring LGBTQ+ youth in Virginia are protected, affirmed, and shown the love they deserve.

Sincerely,

Ted Lewis

Executive Director

Side by Side, VA

As a physician we try to make decisions based on data driven evidence. The literature is full of articles denouncing conversion therapy as not only dangerous but ineffective. The American Psychiatric Association, the AMA and the Medical Society of Virginia have come out in support of banning conversion therapy. Unfortunately this often effects minors more than adults. To allow such therapy to continue goes against the medical and mental health communities. I urge you to base your decision on the medical evidence.

Why are we even talking about pseudoscience like conversion therapy when it has long been not only debunked (it is not effective) but also shown to be harmful? I fully oppose any use of conversion therapy.

Thank you, Ms. Yeatts, for standing up against pseudoscience and bullying in the realm of medicine. The faster we condemn the holdovers of prejudice in science, the better! 

No one should have to suffer damaging psychological and/or physical stress at the hands of a licensed professional. Conversion therapy has been denounced by all major health organizations, including the American Medical Association, the American Academy of Pediatrics, and the American College of Physicians. Let's put an end to this terrible practice. I support the Board of Nursing's guidance. 

I support this Guidance Document as both an individual and as part of an organization.

As an individual, I have some really painful memories from my time as an ex-gay.  An ex-gay is an individual who, instead of identifying as gay, identifies as struggling with same-sex attraction, believing that one can heal from homosexuality. These attractions did not go away, but my enjoyment of life and self-confidence did.  Instead of learning to love myself, I only learned to resent my parents as I was taught that my mother was overbearing and that my father was emotionally absent. This was taught to me as a “root cause” of me “developing same-sex attractions.”  As someone who was personally impacted by efforts to "heal from homosexuality," also known as sexual orientation change efforts (SOCE), or conversion therapy, I express a heartfelt thank you for defining it for what it is.  Thank you for also wanting to make sure that our community is protected.

I also support this Guidance Document on behalf of Born Perfect as Virginia's Born Perfect Ambassador.  Born Perfect was created in 2014 by the National Center for Lesbian Rights to end conversion therapy.  Few practices hurt LGBT youth more than attempts to change their sexual orientation or gender identity through conversion therapy, which can cause depression, substance abuse, and even suicide. But some mental health providers continue to subject young LGBT people to these practices—also known as “reparative therapy,” “ex-gay therapy,” or “sexual orientation change efforts”—even though they have been condemned by every major medical and mental health organization in the country.  This action is a fantastic step in the right direction.