Why is BACP stifling discussion and debate?

Recent days have seen something of a furore in response to BACP’s 2017 Audit Consultation, which is being run to a very tight deadline – it closes at 5pm on Monday 30th January. Find the survey here: https://www.surveymonkey.co.uk/r/BACPAudit

We know from anecdotal evidence that BACP members are checking out whether they can join another professional body.  Others have resigned or are threatening to do so. Reactions are fiercer than over proposals for either the regulation of counselling and psychotherapy by the Health Professions Council in 2009/10, or BACP’s review of its Ethical Framework in 2014.

These BACP members clearly appreciate the seriousness of the situation. Yet the deadline for responses is very much shorter than in 2014’s Ethical Framework consultation – in this case, just three weeks. This timescale strongly suggests that BACP are trying to pre-empt proper discussion.

Members are telling us they have written to BACP’s journal, Therapy Today, but have been informed that – instead of publishing the letters – BACP wants all correspondence about the survey to be forwarded to the register department, which is where responses to the consultation are being collated. In any event, due to the publication schedule, no letters on the issue could have been appeared in Therapy Today before the consultation closed – but BACP are still preventing members’ concerns reaching the pages of the next issue.

Why? Is BACP determined to present its own conclusions before wider concerns about context or implications have been properly aired? What’s going on?

The questions in the survey don’t invite comment about these wider implications – the final question is a narrow one that simply asks for suggestions on how ‘the audit process’ could be improved. No space is provided where any questions about the underlying rationale can be put, or where any reservations about the process as a whole can be expressed. It’s as though each and every suggestion is regarded as a potential incremental ‘improvement’ on the status quo. The fact that a major change of direction for BACP is being proposed is not acknowledged. That there is no opportunity to make any observations about this raises the possibility that the organisation is trying to slip major change through without proper input from its membership.

At the very least BACP needs to undertake a thorough analysis that weighs up the potential benefits of any proposed changes and set these against any possible unintended negative consequences. This should be done with transparency and with full membership participation – not after BACP managers have already presented their views and their interpretation of the survey results.

“the impression is that BACP regards its members as inherently untrustworthy”

As the Alliance has pointed out, what BACP is proposing is a regulatory framework based on distrust. During the 2014 review of the Ethical Framework, it was emphasised time and again that clients have to be able to trust BACP registrants. Indeed, BACP placed trustworthiness at the very heart of the new Ethical Framework:

‘Therefore, as members or registrants of BACP, we take being trustworthy as a serious ethical commitment’, it says in the opening pages.

Yet the impression from this consultation survey is that BACP regards its members as inherently untrustworthy, so much so they are badly in need of extra monitoring and surveillance. When the Ethical Framework was first introduced in 2001 as a replacement for the previous Code of Ethics, it was argued that the time had come to treat counsellors and psychotherapists as mature professionals. The impression in 2017 is that BACP members are not grown-ups at all but a bunch of potentially naughty schoolchildren who constantly need someone looking over their shoulder.

It beggars belief that such fundamental change is being presented via what is essentially a tick-box survey with further boxes in which comments can be added but which are hard to revise – both because so little text is visible in the space available and because scanning back to revisit earlier comments is so tedious. It’s as though obstacles have been deliberately placed in the way of anyone wishing to make more than perfunctory observations. We were told this survey ‘should take no longer than 20 to 25 minutes’, but a thoughtful response requires much more time than that.

In short, have we already witnessed a managerial coup at BACP HQ that is eager to suppress proper discussion and debate about these matters?


BACP: Masterminding the Death of Trust

What is going on at the British Association for Counselling & Psychotherapy (BACP)? As many of its members are now all too aware, the organisation has recently revealed that it is considering introducing ‘mystery shoppers’ and ‘practice inspections’ into its audit processes for practitioners on the BACP Register.

In an email on Monday 9th January, BACP Chair Andrew Reeves invited BACP members to respond to a survey on changes to the organisation’s register audit processes and CPD requirements. ‘We feel that it is time to make changes to strengthen our commitment to both safeguarding the public and protecting the reputation of the profession’, he writes.

The survey questions say that BACP are considering the use of mystery shoppers and practice inspections to assess members’ policies and procedures, particularly around confidentiality. It also proposed asking supervisors to complete forms confirming ‘frequency and duration’ of their supervisees attendance at supervision and that they have ‘gone through the ethical framework’ with them. If that weren’t enough, supervisors will be sent forms asking if they have any concerns about their supervisees, while registrants could face a ‘revalidation’ process involving some kind of ‘assessment of outcomes of practice’.

“a fundamental shift in the ethical relationship between therapists and their organisations, to a values incongruent one of surveillance and control”

Within hours of the survey being sent out, BACP members were sharing with the Alliance and across social media their deep concerns at such a huge change in policy and procedure; crucially that the proposals represented a fundamental shift in the ethical relationship between therapists and their organisations, from a supportive and challenging one to a values incongruent relationship of surveillance and control.

We wonder whether anyone at BACP has any awareness of the many devastating critiques of this kind approach, not to mention the personal experiences of practitioners from other professions who already work in this kind of culture and can attest to the toxic influence it has upon both their practices – which become increasingly defensive and distorted by the threat of surveillance – and themselves as persons, who become increasingly anxious and burnt out.

Surely of all professions, we would expect those in the field of counselling and psychotherapy to be attuned to these issues, to understand that relationships of trust – such as therapy – are not fostered in a context of suspicion or excessive external controls, and that these proposals would be harmful to both practitioners and clients.

How, then, does BACP imagine such procedures will ‘safeguard the public and protect the reputation of the profession’, as they put it? What is driving its desire to police the field in this way, completely ignoring the possibility that an uncritical over-estimation of its ‘public protection’ function might have a range of unintended negative consequences?

BACP, it would seem, are increasingly keen not to differentiate psychotherapy and counselling from other activities, to celebrate and articulate its uniqueness, nor to embrace and encourage the diversity of thought and practice within its own ranks, but instead to homogenise and take greater control of the field in an attempt to align it with ‘other healthcare professions’, as if it were undisputed that therapy is a ‘healthcare profession’ and should therefore mimic the cultures and practices of its claimed professional neighbours. This drive can also be seen in BACP’s efforts to standardise practice via ‘competency frameworks’ but the survey proposals expose its agenda even more starkly.

What’s the prize here? Winning the battle for influence in the corridors of power? Jobs for members in State agencies and institutions?

As they are keen to point out on social media, BACP are ‘listening’. But to whom and to what ends? What has happened to the largest therapy organisation in the UK that it would even consider proposals that would be the death knell for trust as a core principle in the practice of therapy?

Check out our first blog on the issue here, with one BACP registered member’s responses to the survey. And there’s an interesting analysis of the issue here noting BACP’s ‘ethical blind spot when it comes to practising institutionally what it preaches for its members individually’.

BACP Audit Consultation: An Inspector Calls?


BACP – an Ofsted for Therapy?

In an email on Monday 9th January, BACP Chair Andrew Reeves invited BACP members to respond to a survey on changes to the organisation’s register audit processes and CPD requirements. ‘We feel that it is time to make changes to strengthen our commitment to both safeguarding the public and protecting the reputation of the profession’, he writes.

But BACP members are telling the Alliance that they are deeply concerned about the survey, which you can find here, and the major changes it proposes. The deadline for completion is Monday 30th January, leaving just a couple of weeks to digest the proposals. The Alliance has received a copy of the survey and one member’s responses, which we share with you below.

The proposals envisage changes that go far beyond those made to BACP’s Ethical Framework, which involved a consultation process stretching over a period of more than 18 months. This consultation, in contrast, is a tick box one and has to be completed in less than three weeks. Why the rush?

Many BACP members are concerned about the proposed Ofsted-style inspection regime. BACP is considering introducing ‘inspections’ and ‘mystery shopper’ calls in order to assess practitioners’ policies and procedures, as well as to look at ‘the practice setup’. They want to know about members’ confidentiality policies (aren’t those supposed to spelled out in the ‘commitment to clients’ in the recently revised Ethical Framework?) and about their cancellation policies, when previously it would have dealt such matters via the Ethical Framework or the associated guidance documents.

The proposals also envisage a new role for supervisors as part of BACP’s line management of registrants. Altering supervisors’ responsibilities was rejected as a result of the consultation on the first draft of the revised Ethical Framework, which drew heavy criticism, but here it is again with supervisors to be encouraged to use a form to report any ‘concerns’ they may have about supervisees direct to BACP. This in addition to supervisors having to report on their supervisees’ attendance at supervision and confirming in writing that they have gone through the Ethical Framework with them. There are also proposals for a kind of ‘school report’ from BACP, ‘with more detailed and personal feedback, including… suggested areas for development’, but it’s unclear whether supervisors’ feedback to BACP will be communicated to supervisees through this process.

Demands for information, then, are linked – rather vaguely – with somehow enhancing ‘public protection’. And this is before we get on to ‘third party feedback’, a concept which isn’t explained but which is presumably to do with other people’s views (i.e. the views of people other than the therapist and their client) about the value of the therapy. In the middle of this conceptual mish-mash there’s a hint that BACP is contemplating ways of assessing individual therapists’ ‘outcomes of practice’, an exercise that is fraught with difficulty.

As an increasingly exasperated accredited BACP member articulates below, the proposals highlight the deep incongruence between therapeutic values and BACP’s apparent goals for the future of the field.


The erosion of trust: The BACP audit survey and one member’s responses

  1. Are you responding as a… ?

BACP registered accredited member.


  1. We are considering the introduction of online continuing professional development (CPD) modules that deal with specific issues relating to good practice – for example understanding of the Ethical Framework or obligations in relation to the use of social media. These would be linked with registration and introduced on a voluntary basis initially. Do you agree with the proposal?


This proposal sounds muddled. If online CPD is to be initially on a voluntary basis, the logical implication is that eventually it will be compulsory. Compulsory CPD would be a new departure for BACP and something of a slippery slope, I fear.


  1. We are considering the addition of a reflective paragraph about future continuing professional development (CPD) and thoughts on the previous year’s CPD. This would be in addition to the present requirements. Do you agree with this proposal?


This would represent an artificial constraint. Not everyone works in this kind of way and I think it would be wrong to encourage such a way of thinking as “best practice”. Some of my greatest CPD gains have come from sudden decisions when I have become aware of an opportunity to which I have responded on the basis of a gut feeling. I would prefer BACP to encourage diversity and not impose what to my mind would be an unnecessary straightjacket on members.


  1. The continuing professional development (CPD) requirements currently state that Registrants must record a range of (CPD) activities relevant to current or future practice. We are considering making the CPD requirements more specific by asking Registrants to record five relevant CPD activities. Do you agree with this proposal?


Once again I fear you are seeking to force the diversity of practice into boxes that won’t suit everyone. Why? There’s a nasty flavour about all this – it feels very controlling. If you want to go down this path I think you should make out a rigorously argued case for doing so and not use an internet poll of this kind that risks skimming over the surface of some important philosophical differences.


  1. Currently our selection for audit is random. We are considering more targeted risk-based audit such as selecting those who have previously failed twice or who work in more high risk contexts. This would be in addition to the current random sample. Do you agree with this proposal?


I think you need to consider very carefully what you are suggesting here. You propose moving from a form of monitoring that seeks to check the validity of BACP’s procedures to one whose purpose is to monitor therapists themselves. One could argue that a much more fundamental approach is required since, from an outside perspective, perhaps the most glaring flaw in BACP’s overall approach is that it seeks to assure the public that therapists are able to build relationships of trust without ever meeting them face to face and testing this. Before embarking on such a radical new direction I think you need to demonstrate clearly that the benefits of doing so outweigh any potential drawbacks.


  1. We are currently considering introducing a form to be sent to members’ supervisor/s for them to confirm the frequency and duration of supervision and to confirm they have gone through the Ethical Framework with their supervisee. This would be in addition to the present requirements. Do you agree with this proposal?


Certainly not! You are proposing a change in the role of supervisors requiring them to undertake a managerial function on behalf of BACP. This paragraph in the revised Ethical Framework is pernicious if interpreted in this fashion and enforced in this manner. When the Ethical Framework replaced the previous Codes of Ethics in 2001 it was sold to us as a mark of our maturity as professionals. This proposal infantilises BACP members and indicates a lack of trust in them. It does nothing so much as encourage a culture of compliance. You need to present a rigorously argued case in favour of doing so before seeking to impose such fundamental change.


  1. We are currently considering introducing a form to be sent to members’ supervisor/s to ask if they have any concerns about their supervisee. This would be in addition to the present requirements. Do you agree with this proposal?


You are proposing piece of bureaucratic interference that may be superficially appealing, but which is likely to create muddle. The existing situation is that supervisors have to get a grip on situations of this kind and “telling tales to teacher” after this fashion doesn’t help – the issue has to be confronted within the supervisory relationship itself.


  1. We are considering introducing a report style card alongside the standard pass letter, providing Registrants with more detailed and personal feedback, including areas completed well and suggested areas for development. Do you agree with this proposal?


This sounds muddled too. Do you mean feedback from BACP on how compliant the answers to questions are, or do you mean feedback from registrants’ supervisors too? This is a repellent, patronising suggestion. By what right does BACP believe it is capable of giving registrants ‘personal’ feedback, including areas for development, when its relationship with the overwhelming majority of the membership is anything but personal?


  1. We are considering introducing different standards of audit requirements for accredited and non-accredited members. Do you agree with this proposal?


I think you need to be specific about what you are aiming to achieve before consulting on how to do it. There needs to be agreement on the former before consulting on the latter – otherwise consultation is in danger of becoming a charade.


  1. Some professions have introduced revalidation to ensure members continue to be fit for practice and remain up to date. This goes beyond continuing professional development (CPD) audit requirements and usually includes assessment of outcomes of practice. We are currently considering introducing revalidation for members after being on the Register for five years. Do you agree with this proposal?


How precisely do you envisage assessing “outcomes of practice”? There are many contentious issues here that deserve detailed, serious attention and frankly I find it rather disturbing that you are using a set of questions like these to help formulate fundamental changes in policy and direction.


  1. Some professions have introduced mystery shopping as part of their audit process. We are currently considering mystery shopping telephone calls to members as part of a separate audit procedure to gain statistical information and to enhance public protection. This could include asking questions about members’ confidentiality or cancellation policies. If this were to be introduced all members would be informed in advance. Do you agree with this proposal?


What on earth do you mean by “mystery shopping”? This sounds more like a “mystery question”! Stop hiding behind slick marketing jargon and explain exactly how you anticipate significantly enhancing public protection by making phone calls to members. And surely you need to explain what statistical information you will be seeking and for what purpose before you expect a proper response from me here?

Furthermore, why do you need to ask about members’ confidentiality policies – aren’t these laid out in our commitment to clients as specified in the new Ethical Framework? And why ask about cancellation policies? Surely BACP is capable of producing a set of practice guidelines if this is needed? What’s going on here? You have yet again rolled up several questions into one.


  1. Some professions have introduced inspections as part of their audit process. We are currently considering inspections as part of a separate audit procedure to gain statistical information and to enhance public protection. This could include assessing policies and procedures in place and looking at the practice set up. If this were to be introduced all members would be informed in advance of the visit. Do you agree with this proposal?


This gets worse and worse. Why not come out openly and say you are keen to ape Ofsted? This whole tick-box survey sounds more and more an underhand way of introducing major changes through the backdoor. The proposals sketched out in this survey are much more fundamental than those introduced via the recent review of the Ethical Framework. You need to put together a reasoned argument as to what exactly the advantages will be of the changes you propose and weigh these up properly against any potential drawbacks, which I suspect may be considerable.


  1. Do you have any further suggestions for other third party feedback?


Yes, just stop it! In the first place please don’t count my reply here as approval for third party feedback. Secondly, you need to explain precisely what you mean by this phrase. Feedback from whom? To whom? About what? And for what purpose? Please get a grip before circulating such questions.


  1. Do you have any further suggestions on how the audit process could be improved?


I am struck by the contrast between this survey and the extensive consultation undertaken when the Ethical Framework was reviewed. Many poorly conceived changes to the Ethical Framework were eventually rejected after a lengthy process of consultation – and a few slipped through the net. These seem to be the springboard for what to my mind are an ill thought through set of proposals here that deserve to be thoroughly interrogated over an extended period. I think it would be rather foolish of BACP to conclude, as the introductory letter says, that “with your help we can see exactly how our existing register audit processes and CPD requirements can be improved”. Is BACP willing to consider the possibility that, by going down this route, it may neither be safeguarding the public nor protecting the reputation of the profession? In any case please try to answer the question, in whose eyes would the public be better safeguarded or the reputation of the profession be better protected?


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