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?



3 thoughts on “BACP Audit Consultation: An Inspector Calls?”

  1. Thanks very much for taking the trouble to replicate the survey here and to respond to each question. I especially appreciate the way that you have compared this to the ethical framework and the process by which it was achieved. An online survey really is inappropriate – it has the air of casual laziness coupled with ignorance. A dreadful mix!

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