SCoPEd: Butchering Psychopractice

Denis Postle (ARCA; Independent Practitioners Network) interrogates the power relations of the SCoPEd project.


VGDSC03134FLAT

SCoPEd seems to be yet another instance of ethical sleep on the part of its authors, BPC, UKCP and BACP, institutions that aspire to the high ground of human sensibility and civic accountability. One of the long-standing deficiencies of the psy trainings that they validate, and thus the crust of institutions that represent them, notably for 1:1 work, is the lack of explicit attention to the ubiquity of power-relations. If this were not so, how else can the current SCoPEd initiative – and its likely tame acceptance by the psy demographic it refers to – be understood?

The shenanigans of UK therapy training schools’ efforts to secure their economic status via state regulation, has a long history. Isn’t SCoPEd, a remarkable pro-active coming together of entities previously laden with toxic animosity, yet another precursor for state regulation? Or as time may tell, a defensive response to whispers from government that it is minded to take the psy world in-house?

Let’s back off from this to a reprise of what, to a long-term watcher of power relations in the psy demographic, appears to be a continuing ethical contradiction. This can be outlined as follows: the overwhelming source of complaints from clients (leaving aside mistakes) is the result of practitioner behaviour that drifts from facilitation to coercion, manipulation, exploitation or bullying, i.e. dominance behaviours. But if we look at the organisations whose work has given us the SCoPEd taxonomy, they are top-down structures in which dominance behaviour has for decades been intrinsic to their ethos and operation.

People who have trained since say, 2010, may not be aware of this but it was blatantly evident in the previous decades in conflicts over market share, modal validity/invalidity, and here it is again in SCoPEd. Yet another definition of what psychopractice is, yet another taxonomy, with no sense – as I pointed out in 2007 – that such taxonomies are forms of violence and lead to taxidermy of the organism they engage with. What were then relatively open, rich multitude of modes of therapeutic relations are now in SCoPEd reduced to three levels of competency, free of any sense of the coercive forcing of the ecologies of psy practice that this entails.

“overwhelmingly likely to distort or corrupt the wildernesses of nuance in client practitioner relations”

As too often with such intentionally seductive interventions by power-brokers, the context is hidden. Why might this be so? What benefits are intended to accrue for clients and practitioners from SCoPEd? The context that is obscured seems potentially to come in two parts: preparations as I have mentioned, to embrace/field state regulation of the psy demographic; and secondly to provide succour for training schools that not only have the UKCP, BPC, BACP etc. on their backs but also the commodification of their courses via universities selling authority/validation/status. Universities that increasingly are being run as businesses, with ‘products’ and ‘services’.

In this relegation of context to invisibility, the SCoPEd initiative is also a notable example of what I have come to understand as a ‘trance-induction’. Trance induction captures attention via cogent images, sounds, phrases and naming which make the background context go missing. Current examples include ‘take back control’, ‘project fear’, ‘Make America Great Again’. Trance inductions are ubiquitous and through their temporary exclusion of the street, the venue, or the rest of the audience, in cinema, theatre, sport and literature, they can be beneficially entrancing. However when ‘trance inductions’ such as SCoPEd become embedded in our psy culture as agents of dominance, or claims of entitlement, they seem overwhelmingly likely to distort or corrupt the wildernesses of nuance in client practitioner relations.

The claim implicit in the SCoPEd initiative is that it is ‘evidence-based’, currently a very potent trance induction that typically excludes the context of how the evidence for their taxonomy was derived, how the choices were made. SCoPEd doesn’t appear to have been generated via research with people, more likely it has emerged from research on people (or even research without people); the point being that the ownership of the research rests with the researchers, which as in SCoPEd, emerges yet again as institutions presenting entrancing power-over assertions of psychopractice entitlement.

That said, the psy ecology has many inter-related strands, embracing cooperation, challenge and support – some form of civic accountability is essential. SCoPEd demonstrates only too clearly that if its layers of competencies are intended to enhance client safety – i.e. freedom from coercion, exploitation and abuse (why else would the initiative be undertaken) – the way they celebrate top-down power relations in both form and intention means they unawarely subscribe to its opposite, an ethos of entitlement, that is likely to result in client harm. This may support the economic dynamics of training institutions and their validity networking, but it is hard to see how it would be other than harmful to clients.

*


 

Advertisements

Against SCoPEd: actions and materials

The consultation for the draft SCoPEd competence framework for counselling and psychotherapy closed on Friday 22 February 2019. If you are concerned about SCoPEd or you just want to understand more about the project, here’s a summary of some of the materials and activities that have emerged in response, which hopefully will help you to join the debate.


1) Read and comment on the Alliance’s blogs, which have been viewed and shared hundreds of times each:

Joint letter to BACP, UKCP & BPC from the Alliance, PCSR, PCU, the College of Psychoanalysts and the National Counselling Society. 17 Mar 2019.

The SCoPEd Consultation: Methodologically Challenged. Dr Richard House subjects the consultation survey to critical analysis. 12 Mar 2019

SCoPEd: Buthering Psychopractice. Denis Postle interrogates the power relations in the SCoPEd project. 23 Feb 2019.

A damaging business paradigm – latest SCoPEd response by Keith Barber. 20 Feb 2019.

SCoPEd: new consultation responses Arthur Musgrave (BACP Senior Accredited counsellor and supervisor) and Joe Suart (UKCP Registered psychoanalytic psychotherapist) share their SCoPEd consultation responses. 15 Feb 2019.

The Questionable Evidence Base of SCoPEd. David Murphy, Associate Professor at the University of Nottingham, interrogates the claim that the SCoPEd framework is ‘evidence-based’. 31 Jan 2019.

SCoPEd Denial, Distortion & Deception. Andy Rogers – BACP member and counselling service coordinator in further and higher education for two decades – responds to BACP’s consultation survey. 30 Jan 2019.

‘Psychoanalytic Coup’ – Andrew Samuels on the SCoPEd competence framework. 30 Jan 2019.

Regulation, Professionalism & Cultures of Dominance, by Denis Postle. 25 Jan 2018.

2) Read the Alliance’s newsletter, which has been sent to over 500 addresses.

3) Watch the Online Events live webinar event We’ve Been SCoPEd!, featuring David Murphy, Andrew Samuels, & Clare Slaney. This was oversubscribed and can still be seen on Facebook, where it has had almost 5000 views.

4) Follow and join the debate on Twitter with #SCoPEd

5) BACP members might like to sign the petition for BACP to scrap the SCoPEd project. 2500 members have already signed.

6) Read the National Counselling Society’s letter challenging BACP’s apparent u-turn on the counselling/psychotherapy differentiation.

7) Read PCSR’s excellent 10-point statement on SCoPEd.

Last, it is important that as many people as possible fill in the BACP, UKCP and BPC’s consultation survey by end of Friday 22nd February 2019.

The consultation is now closed but if you are a BACP, UKCP or BPC member, please do still contact your organisation to express your views on SCoPEd.

You can see the draft SCoPEd framework here and the equally controversial Methodology document here.

Thank you.

From the Alliance for Counselling & Psychotherapy

Contact info@allianceforcandp.org

 

Blog amended 25/02/2019 following closure of the consultation survey, and will be updated as and when new materials emerge.

 

*


 

 

 

A damaging business paradigm: latest SCoPEd response

The sixth in our series of responses to the BACP/BPC/UKCP SCoPEd project, following responses from Andrew Samuels, Andy Rogers, David Murphy, Arthur Musgrave and Joe Suart. Here, Keith Barber (UKCP registered psychotherapist) critiques the consultation process, differentiation, methodology and the framework itself.


Consultation Process

The clear implication of the introductory remarks to these questions is that SCoPEd is a ‘done deal’ and will be rolled out regardless of the content of consultation responses. If so, this whole exercise is therefore meaningless PR.  It does UKCP no credit, as a professional body, to associate itself with such a flawed process.

The questions and multiple-choice answers are worded in such a way that it is almost necessary to be deliberately perverse if respondents wish to answer in a way that does not support this framework.  Again, the consultation process itself is fundamentally flawed.

I do not believe that the outcome of such a flawed process will command respect in the Profession(s) nor the assent of practitioners.

Differentiation

The question of differentiation between Counsellors and Psychotherapists has been a vexed one for many years.  In spite of repeated attempts to discern such a differentiation, none has been identified that might command sufficient support among practitioners or the public to be accepted.  I can see nothing to suggest this exercise has succeeded where its predecessors have failed.

“the vast majority of therapeutic practice takes place in this overlap, in which counsellors and psychotherapists are equally competent”

Let me be clear: I believe it is possible to differentiate between some activities that are truly counselling and some that are truly psychotherapy.  However, my experience shows there is a huge overlap between them – the overlap covers ground far more extensive than the both differentiated areas put together – and the vast majority of therapeutic practice takes place in this overlap, in which counsellors and psychotherapists are equally competent to practice.  I am quite certain that a considerable majority of counsellors are either trained in or acquire skills sufficient to practice in the area known as psychotherapy (and those who can’t have the skills to refer as appropriate), while it is nonsensical to suggest that psychotherapists cannot function in the area of counselling.  The framework does not, it seems to me, acknowledge the practical implications of this reality.

Any attempt to differentiate the titles will force those seeking our help to choose, right at the start, what kind of work they seek, regardless of their actual need.  Given the stigma that still attaches to mental and psychological distress, this is likely to lead to people in need of psychotherapy choosing, rather, to enter counselling.  If the (entirely artificial, in most cases) differentiation is in any way enforced, they are unlikely to find the help they seek.

Moreover, most clients bring a huge and complex range of experiences that will require an equally large range of responses from a practitioner.  In that case they will find that significant areas they seek to work on are characterised as needing an entirely different kind of help (another practitioner entirely, at additional expense – even assuming the issues around working with two therapeutic practitioners simultaneously can be negotiated).  I quite fail to see how this may be considered to help or protect the public and would welcome enlightenment – if such exists!

The Framework

“cursory inspection of Appendix viii of the Methodology document reveals that the Chair is both a member of the British Psychoanalytic Council and closely associated with Roth & Pilling, therefore hardly independent”

Selection of the Roth & Pilling methodology must be considered controversial, at best, in view if its focus on manualised treatments.  It is impossible for an informed member of the Profession(s) to be unaware of the vigorous debates and deep unease at such ‘treatments’; the way research is used to (supposedly) support such ‘treatments’ is likewise strongly contested and there is as yet no sign of consensus in the field.  It is claimed that the SCoPEd methodology is evidence-based (another area of continuing controversy), yet it is acknowledged that this has had to be adapted “…due to a paucity of empirical research into differentiated competencies.”  In other words, we read that the study was set up with the deliberate intention of establishing differentiated competencies and that the evidence was selected with a view to achieving this result.

Given these manifold defects, I am minded to say that the Framework is not worth the paper it is printed on.  It is incomprehensible to me that such a document could be presented for approval with a view to adoption by our profession(s), and incredible that a learned professional body should allow itself to be associated with it.

I learn from a variety of other sources that the composition of the Expert Reference Group is heavily weighted towards psychoanalytic modalities; cursory inspection of Appendix viii of the Methodology document reveals that the Chair is both a member of the British Psychoanalytic Council and closely associated with Roth & Pilling, therefore hardly independent.  Again, we see defects that negate the credibility of the Framework.

Given the prevalence of psychoanalytic thinking on the ERG, it is most striking that the Framework does not see fit to prescribe competences for psychoanalysts.  I wonder if they are considered, in some way, to be above such reductive and limiting descriptions?  But why should that be so?  Or is the answer, perhaps, to be found in my previous paragraph?

“hierarchical structures, universal application of economically-driven models of outcome evaluation and a strict regulatory model”

More generally, it seems to me that the endless initiatives to systematise the field with standards identified as ‘competences’ indicates an attempt to fit the therapeutic field into what we may describe as the ‘business’ paradigm.  Here I follow Kuhn (1962/1970), who showed that the paradigm we are committed to dictates and limits even the questions we can ask, let alone the ways they can be answered.  The business paradigm privileges hierarchical structures, universal application of economically-driven models of outcome evaluation and a strict regulatory model that facilitates command and control of virtually every aspect of a field of work. It may (the jury is still out) provide economic benefits, but there is no evidence whatsoever that it is good for the psychological health fo the human beings that inhabit it.

This would not be so bad if the competency-based approach was effective.  But my experience in a previous career is that it is, in general, of little utility but comes at the cost of a huge bureaucratic overhead that quickly damages the organisation’s ability to perform its most basic tasks.  Again, the approach of this Framework is unlikely to gain the assent of most practitioners in our field and, given the increasingly-recognised association between psychological distress and (business-inspired) austerity and insecure work, gives every indication of being rather part of the problem than of the solution.

Conclusion

This Framework is not a response to any currently known need.  It is misconceived, insufficiently evidenced and reaches an inappropriate predetermined conclusion.  It will do nothing to help or protect the public but – like the proposals for statutory regulation in 2009 – will do enormous damage to the work of counsellors and psychotherapists, if it does not entirely destroy therapy as we know it. The SCoPEd process should be terminated and the resources our profession commands be redirected to meeting the needs of people in distress in the UK.

Reference

Kuhn, T. S, 1962/1970: The Structure of Scientific Revolutions; University of Chicago Press

*


 

SCoPEd: new consultation responses

Two therapists – one a BACP Senior Accredited counsellor and supervisor, the other a UKCP Registered psychoanalytic psychotherapist – share their SCoPEd consultation responses with the Alliance.

 

Arthur Musgrave, BACP Senior Accredited Counsellor and Supervisor.


The consultation questions

This consultation exercise seeks answers to four questions –

  1. How will the framework affect clients or patients in being able finding the right kind of help to meet their needs?
  2. How will the framework affect employers in being able to establish which counsellors or psychotherapists to employ in their service?
  3. How will the framework affect trainees in their understanding of the pathways open to them for core training with adults? (sic)
  4. How will the framework affect professional bodies being able to promote the skills and services of their members?

Summary

This draft framework promises to provide clarity but fails to deliver. Take, for example, the employment of counsellors and psychotherapists – there is already a well-established and much more satisfactory way of establishing whom to employ and that is through the use of a well thought out person specification and a good selection process. It is hard to see that whatever is finally ratified will add much to this.

Nor does the draft framework offer clarity to other stakeholders who would much prefer that other, more fundamental issues were resolved The key components of training and practice that lead to a good outcome remain as obscure as ever. To what extent, for instance, is there any correlation with the length of training a counsellor or psychotherapist has undergone? Or with hours of personal therapy? Or with hours of supervised practice? Do trainee psychotherapists in practice receive more supervision than trainee counsellors? And, if they do, does that mean their clients/patients are necessarily more satisfied?

Without satisfactory answers to questions of this nature campaigns promoting the skills and services of counsellors and psychotherapists will have limited value. And neither potential clients/patients nor anyone wanting to decide what qualification to pursue will be much the wiser.

“further layers of complexity and obfuscation”

But a document of this kind does more than fail to provide clarity – it actually adds further layers of complexity and obfuscation. The answer to each of the consultation questions must therefore be that the draft framework will make clarity harder to achieve.

Much is being claimed for this exercise, but at root it is an attempt at tidying up discrepancies in documentation held by each of the three sponsoring bodies in order for these bodies to agree between themselves what they regard as the distinguishing characteristics of a ‘qualified counsellor’, an ‘advanced qualified counsellor’ and a ‘psychotherapist’.

Stripped bare of any significant benefit for others, what becomes starkly apparent is that the three sponsoring bodies are set up to be the main beneficiaries. As a result of reaching a shared consensus about common standards for practice and education, they will be better placed to press for control over the entire field of counselling and psychotherapy.

There a serious danger here that once competencies are laid down in this fashion, a common curriculum will be prescribed and good practice will then be judged primarily in terms of adherence to what is taught on training courses. This would undoubtedly have a devastatingly inhibiting effect on creativity and the development of good practice.

Specific concerns: (1) Language

The language is opaque. The competency statements are peppered with words such as ‘suitable’, ‘appropriate’ and ‘relevant’. This language requires a further gloss from those within the profession and defeats the stated purpose of offering clarity to outsiders such as members of the public and potential trainees.

Even when qualifiers of this kind aren’t used the competency statements necessarily lack precision so that, for instance, it is unclear to what extent practitioners of all kinds have “the ability to reflect on their own cultural background and history and have the capacity to work in an authentically non discriminatory manner” (Theme 4.8). It is equally unclear what constitutes sufficient “knowledge and ability” to be able to work within professional and ethical frameworks (Theme 1.1).Two decades and more ago I was involved in helping to draft standards for National Vocational Qualifications and, time and again, found that the language in competency statements was imprecise. At each iteration of the drafting process we were reassured that this would not be a problem since the assessor would be selected by the candidate and would be someone from within the field. In the case of the SCoPEd Framework such an interpreter will clearly not always be to hand.

At other places in the draft framework rather nebulous concepts are deployed in order to distinguish the work of an ‘advanced counsellor’ from that of a ‘psychotherapist’ – for example a ‘psychotherapist’ is able to “negotiate issues of power” whereas an ‘advanced counsellor’ is only able to “address issues of power”. What is the distinction here – that psychotherapists are expected to be in dialogue whereas advanced counsellors are limited to making a speech?

There is great scope for misunderstanding when imprecise language is deployed and this can have serious consequences. In following a case before a Health and Care Professions Council disciplinary panel I had the experience of seeing how problematic matters can become when definitions established in one context are interpreted by others whose professional expertise lies elsewhere. In the case in point a narrow definition of confidentiality based on the notion of consent for medical treatment was utilised to rule that conventional understandings about confidentiality in a group supervision setting were unethical as, somewhat inevitably, personal information about group members was disclosed to other trainees in the group.

Specific concerns: (2) Skills must be tested in context

A serious and even more fundamental problem lies in the fact that skills cannot be adequately tested in isolation from one another as they are in the draft framework. Let me give an example as to why not. I was once approached for help by a student on a counselling diploma course counsellor who had failed her viva apparently because she hadn’t demonstrated basic counselling skills. She brought a tape with them of the session she’d presented at the viva.

When I listened to it in was clear that, at one point when she said something like, “So what you’re saying is A and B”, the client replied, “No I’m not! What I’m saying X and Y!!!”Although the student got things very ‘wrong’ her client was able, as a result and for the first time, to state his viewpoint forcefully and congruently. The trainee then gave her whole attention not to the ‘mistake’ but to what her client had to say. This exchange proved to be the turning point in their work together – which, of course, was why the student had selected it for the viva.

Overtly, then, there was direct evidence of this trainee’s inability to meet Theme 3.8 (i.e. the examiners had detected a failure to sustain the therapeutic relationship) to the point where the existing relationship had been disrupted. However there was other, more subtle evidence, that the student had been able to deal with this rupture in a wholly positive fashion, thereby not simply responding successfully to a difficulty in the relationship (Theme 3.10) but also demonstrating both an ability to work therapeutically with ruptures and difficulties (Theme 3.10 b) and an ability to work proactively to minimise further damage.

Paradoxically, then, this trainee counsellor, in failing her viva, demonstrated that she was able to do something over and above what this draft framework claims only a trained and qualified psychotherapist is capable of doing.

Specific concerns: (3) A flawed threefold separation of roles

The distinction in the draft framework between ‘qualified counsellor’ and ‘advanced qualified counsellor’ doesn’t really work. It is better understood if it is viewed not as a difference in training but as a difference in experience, e.g. in the use of supervision (Themes 1.6 and 1.6a); team working (Themes 1.10, 1.10a and 1.10b); working online (Themes 2.10 and 2.10a); critical reflection on the client/patient’s process within the therapeutic relationship (Themes 3.8 and 3.8a); ability to find ways of making progress in the face of difficulties (Themes 3.12 and 3.12a); and so on.

The ‘advanced qualified counsellor’ reads more as someone who has assimilated what they gained from their training in the light of some years of practice. The threefold division between ‘qualified counsellor’, ‘advanced qualified counsellor’ and ‘psychotherapist’ is therefore fundamentally flawed as like is not being compared with like.

“There is a fundamental problem that training and experience cannot easily be separated when talking about competence”

There is a further fundamental problem in that training and experience cannot easily be separated when talking about competence. Someone whose initial training was as a counsellor can, for instance, obtain further training and experience that gives them the ability to “understand medical diagnosis of mental disorders and the impact of psychotropic medication during assessment and throughout therapy” (Theme 2.4b). Previous attempts to define competency have sometimes floundered on an artificial attempt to determine that labels are acquired only at the point of qualification, a view that can be hard for commissioners of services, employers and members of the public to appreciate when what they are primarily concerned with is practical applications, not demarcation disputes.

Even more problematic is the point that what distinguishes ‘psychotherapist’ from others is largely to do with matters that aren’t essential to what therapy is and that are perhaps better viewed as distinct areas of expertise.

A surprising number of extraneous activities are captured within the rather eccentric definition of psychotherapy used in this framework including being able “to take an active role within the professional community locally and nationally” (Theme 1.10c); being able to “resolve contradictions between ethical requirements and work requirements” (Theme 1.6b) as if psychotherapists are automatically capable of resolving these matters whereas others are necessarily either incapable of dealing with issues of role clarity or only manage to navigate their way pragmatically through intractable situations and irreconcilable expectations; being able “to assess and formulate when working with chronic and enduring mental health conditions”(Theme 2.1b); being able to being able “to critically appraise the history of psychological ideas”(Theme 4.2b) as opposed to simply being able “to critically appraise a range of theories underpinning the practice of counselling and psychotherapy” (Theme 4.2a); being able to utilise audit and evaluation tools/methodologies “to contribute to improving the process and outcomes of therapy” (Theme 4.9b) as opposed merely monitoring and maintaining standards within practice settings (Theme 4.9a); and being able to undertake substantial research projects (Theme 4.10).

A number of somewhat grandiose claims are made for both ‘advanced counsellors’ and ‘psychotherapists’. Apparently they are able to critically challenge their own values and beliefs, whereas mere qualified counsellors aren’t able to do this (Theme 5.3a). They are also able it seems, and again in contradistinction to qualified counsellors, to critically appraise published research on counselling and psychotherapy and integrate relevant research findings into practice (Theme 4.10a).

But to what extent do ‘advanced counsellors’ and ‘psychotherapists’ do either of these in practice? And to what extent do they differ in these respects from qualified counsellors? It is often forgotten that access to published research is limited for those in private practice who do not hold an academic post.

Some of these grandiose capabilities are in the purlieu of psychotherapists alone. They can apparently even “resolve contradictions between different codes of practice and conduct” (Theme 1.6b). They apparently also have a unique ability “to integrate relevant theory and research in the areas of diversity and equality into clinical practice” (Theme 4.8c).

Finally, over and above this substantial list of supposed distinguishing characteristics, one of the most immediately striking aspects of the draft framework is how many gaps it contains. In only a third of the listed competency themes has the draft framework so far been able to distinguish a ‘psychotherapist’ from a ‘qualified counsellor’.

*

 

Joe Suart, UKCP registered psychoanalytic psychotherapist, working and living in Cornwall.


There is a problem with the Roth/Pilling methodology [used to draft the SCoPEd framework], as pointed out in 2008 when Skills for Health were trying to develop National Occupational Standards for the profession. These problems have not been addressed and so have not gone away. The Council for Psychoanalysis and Jungian Ananlysis (CPJA) sent to Skills for Health its response in April 2009, in which it stated:

“Following continuous discussion and debate throughout this process, within the CPJA and with our colleagues in other professional organisations representing psychoanalytic and psychodynamic psychotherapy in the UK, the CPJA has concluded that it cannot support either the process or the outcomes of the Skills for Health consultation. The CPJA will be recommending to the UKCP as a whole that it withdraw its participation and support from the project in favour of its own more appropriately-derived statements of occupational standards for psychoanalytic/psychodynamic and other modalities of psychotherapy”

While the current attempt to standardise Professional/National Occupation Standards is not the same process, its reliance on the Roth/Pilling methodology (which was produced initially specifically for Cognitive Behavioural Therapy practice and then applied to other modalities) repeats the problem that was endemic to the previous attempt.

The SCoPEd Consultation claims to be evidence based, and yet there is no evidence that it’s methodological basis of matching perceived competencies of the therapist to improved life experience of the patient actually works. The collection of descriptions of activities of the therapist, presented under the term competencies are themselves not based in evidence gathering but in the opinion of practitioners and trainers concerning what it is they think should be the case.

The model of gathering empirical data is not well suited to the confidential conversation of two people in camera. At best it can only be done by reportage, usually only done by the therapist. This is an argument that is well known and leads to a well-worn criticism of the process of the ‘talking cure’, however the attempt to get round this problem by defining competencies in the manner done fails. Rather, in attempting to do so, it presents an image of a reality that has been distorted by the wishes and intentions of the presenters. As workers in the field of Freud’s legacy, this is not something that should be ignored or brushed over.

“there are many different and conflicting psychotherapeutic views, some of which would support the competencies and their implications, and some of which would be vehemently opposed to them”

Even within the framework itself, in its own terms, there are problems. The use of the three terms, ‘Counsellor’ ‘Advanced Counsellor’ and ‘Psychotherapist’ is confusing at the outset. It would have been better to use non-specific terms to denote different levels of sophistication and complexity, such as level 1, level 2, level 3. For the use of these terms that imply a reflection on current qualifications and associated capacities appears to mirror and reinforce a hierarchy of professional status that many would say is already in place.

There is then the additional problem that this implied hierarchy of professional status and capacity is one that is intended to become enshrined in nationally recognised standards which training bodies will be obliged to adhere to, and which, when the next attempt to statutorily regulate the profession occurs, will become enshrined in law. When that happens it will become an offence to practice unless you fit yourself into these frameworks.

The success of this attempt to standardise the activities and responsibilities of counsellors/psychotherapists whilst being carried out in the noble desire to protect patients, will have the effect of both reducing patient care and therapists’ ability to respond to the specific and individual needs of the patient. Many of the competencies as set out in the document are written as if they are neutral and non-controversial in their import. This is not the case as there are many different and conflicting psychotherapeutic views, some of which would support the competencies and their implications, and some of which would be vehemently opposed to them.

For example, there are assumptions which would be vigorously challenged when the competencies use terms like ‘conscious’ and ‘unconscious’, ‘inner world’ and ‘outer world’, ‘transference’ and ‘countertransference’. The nature of the complexities and even existence of some of these apparently neutral terms, let alone how the mechanisms, phenomena and experiences that these terms are meant to refer to have been the subject of debate and even controversy for decades. The validity of this history of debate and disagreement is given no recognition by the consultation.

The consequence of this standardisation attempt being successful will be to reduce the options of talking therapy work available to the public, and risk making it an offence for them to be provided with options that are not in agreement with it. This point has been made with full description and elaboration in the Maresfield Report.

*