There are other examples in the birthday thread where people say that their therapists don't say "happy birthday" to them even when they know. You could say that is a boundary, but jeepers how much effort does it take to wish someone a happy birthday? And why in the world would someone do that to another? It's just not human.
I don't expect therapists to remember birthdays or do anything about it if they do know, but a verbal gesture is hardly asking for much.
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“Our knowledge is a little island in a great ocean of nonknowledge.” – Isaac Bashevis Singer
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