Tag Archives: PSA

Regulation, professionalism and cultures of dominance

The government has published a consultation document, Promoting Professionalism, Reforming Regulation. Although the paper does not mention counselling and psychotherapy directly, it does ask questions of, and propose changes to, the current system under which registers of counsellors and psychotherapists are accredited by the Professional Standards Authority (PSA).

In 2011, the Alliance cautiously welcomed the PSA system as an alternative to an earlier proposal to regulate counsellors and psychotherapists under the Health & Care Professions Council (HCPC), a plan we – and thousands of other practitioners – strongly opposed.

As we start to make sense of the current discussions, in which some in our field are already pushing again for state regulation while seeking to further align therapeutic practice with healthcare, we share as food for thought one submission to the consultation from long-term regulation-watcher and Alliance participant, Denis Postle.


Promoting Professionalism, Reforming Regulation: Consultation Submission from Denis Postle, ARCA

January 20, 2018

“How could the dominance cultures of the professional psychological organisations, however well intentioned, make reliable, just adjudications of the dominance misbehaviour of alleged errant members?”

I have been a practitioner of group facilitation, personal development training and therapy in the Humanistic Psychology and Human Potential traditions since 1985. In 1995 I was a founder participant of the Independent Practitioners Network (IPN) and for me this continues to be a dynamic way of sustaining practitioner civic accountability. This is not an Independent Practitioners Network response.

Over the last 20 years I have taken a detailed and sustained interest in the ongoing processes of regulation of the psychological therapies, publishing a considerable  amount of material on the internet via eipnosis: a journal for the Independent Practitioners Network  and two books, plus participation in several others.

As I will outline below, the more I saw of mainstream counselling and psychotherapy institutions in this time, the less I was inclined to be associated with them; this perspective is thus of an outlier. IPN emerged as a response to what was perceived as inadequate forms of civic accountability in the psychological therapies.

2.2  ………As the HCPC has traditionally been the regulatory body to assume regulatory oversight of new groups, it could be seen to have a vested interest in expanding its registrant base. We therefore believe that the PSA, working with relevant stakeholders, would be better placed to provide advice on the regulation of professions

During the abortive process of taking counselling and psychotherapy into regulation by the HCPC, then just HPC, I had extensive contact with its chief executive, Marc Seale, and attended and reported on a substantial number of events and meetings there. I became convinced that, then or now, for the HCPC to regulate psychotherapy and counselling would be as inappropriate as putting the Royal Ballet under the control of the Sandhurst military academy. The HCPC knew how to ‘grasp’ but had no capacity for ‘holding’ the nuances of the practice of counselling and psychotherapy. Happily the HCPC’s coercive, prescriptive approach to this task failed and should not be revived.

I attended many of the early foundation meetings of the PSA and its cultural grasp of regulatory tasks was notable for its more participative, cooperative stance.  I regard it as a least worst option.

Promoting professionalism, reforming regulation

The text of the departmental statement under this headline, as so often, appears to make a presumption that psychotherapy and counselling are some subsidiary of medicine, i.e. they consist of ‘assessment’, followed by ‘diagnosis’ and ‘treatment’ of ‘patients’. This hegemony of the medical paradigm and the assumption that how medicine is regulated can transfer to the psychological professions continues to defy constant challenge from critical practitioners. It is perhaps a key vehicle through which harm to people in need continues to be enacted.

There may be a small place in the diverse cornucopia of the psychological therapies for biomedical treatment using zero responsibility elixirs but the overwhelming basis of psychological work is relationship. This means that there is an intrinsic element of risk, and insofar as  regulation has sought to make this disappear, it has tended to make professional practice defensive. How can this be in the public interest?

Risk can and should be minimised, to do this successfully would seem to  mean there was comprehensive evidence of the actual amount of harm that was prevalent in the psychological therapies. I and colleagues I have consulted are not aware of any such evidence.

Witnessing the regulatory shenanigans over the last 20 years in the UK convinced me that ‘Professionalism’ in the psychological therapies is comprehensively compromised in ways that this consultation seems unaware of.

Some perspectives that may be relevant:

The psychological therapies can be seen as an extractive industry. Practitioners work with clients, they accumulate in professional journals the insights that emerge; there is parallel input to trainings, supervision and professional conferences, where the extracted knowledge is refined  and fed back into practice. This tends to be a self-referential elite activity, the psychological knowledge does not diffuse significantly into society. One result of this elite grasp of work with the human condition amplified by the pathologising of instances of common human distress, has been the generation of stigma. As a result, and especially in the current climate of economic ‘austerity’, access to professional psychological knowledge typically requires a crisis.

For the industrialised psychological therapies, regulation has multiple benefits. It supports the creation of professional walled gardens of therapeutic practice membership of which is restricted in ways that generate unnecessary scarcity. The walled gardens are also professionally and economically in competition with each other and have often seemed more concerned with status and protection of the profession than of enriching and empowering the population at large.

Due perhaps to the medical paradigm that shaped early development but also because of an overly self-referential professional culture, access to these professional walled-gardens tends to be excessively expensive, unduly lengthy and with inappropriately complex academic content. Where is the evidence that, apart from the economic benefits to universities and training institutes, and enhanced professional status, a Masters or a PhD is a requisite education path for sitting alongside people who are struggling with human condition difficulties?

2.9  ……….In addition, the Law Commissions recommended that regulatory bodies be given powers to operate a form of negative register through the use of prohibition orders for those groups not subject to statutory regulation. Such a scheme allows individuals to be barred from practising a specified profession or from carrying out specific activities and would set the standards required of a certain occupation. Where these standards were not met in a way that places the public at risk of harm, the relevant regulatory body would issue a prohibition order that would prevent or restrict an individual from carrying out a certain role or providing certain services.

This is perhaps the most important issue of the consultation.

I see no problem with a person convicted by a court of abuse or fraud being included on a public register of such offenders. The key to this is ‘convicted by a court’.

Inclusion on such a list of people found guilty of abuse by the professional bodies that are presently under the wing of the PSA would be unacceptable.

Three reasons for this:

1. In my experience of the behaviour of some people in the psychological professions, there will likely be a witchhunt of practitioners like myself who are on, or just outside, the margins of the regulation regime. Or for instance, who belong as I do, to civic accountability bodies that are too small for the PSA’s attention.

2. My study of the UK psychological professional bodies, including the HCPC, constantly demonstrated a profound paradox. The bodies claim to be protecting the public from abuse. But what is the origin of abuse? It is the enactment of some form of physical, emotional or cognitive dominance behaviour, i.e. some form of coercion, bullying or sexual abuse, due, leaving aside mistakes, to an unworked thread of belief or behaviour in the practitioner that licences them to enact some form of domination.

Why does this matter? It matters because with no exception that I know of, the professional psychological bodies associated with the PSA are all structured as traditional top down dominance cultures in which executives make decisions on behalf of members.

How could such dominance cultures, however well intentioned, make reliable, just adjudications of the dominance misbehaviour of alleged errant members? Especially if they are licensed to enact extreme dominance behaviour such as legally enforceable negative prohibition orders.

3. A negative prohibition order is way too close to potential abrogation of human rights, i.e. the human right to have a conversation with a consenting Other, paid or unpaid. In the hundreds of modes of approach to working with the wildernesses of the human condition, there will always be people and institutions who find some other approaches to be anathema or alien, and worthy of being dismissed as charlatanism. If they are introduced at all, negative prohibition orders should only apply to convictions by the courts.


Brief references

Books

Postle, D. (2007) Regulating the Psychological Therapies: From Taxonomy to Taxidermy. Ross-on-Wye: PCCS Books.

Postle, D. (2012) Therapy Futures: Obstacles and Opportunities. Lulu.com

Videos

The PsyCommons – Ordinary Wisdom and Shared Power

Around 75% of the UK population have no need of ‘mental health’ services. What is it they know and do that keeps them psysavvy? The psyCommons examines the ordinary wisdom and shared power hidden from us by the mental illness industries and the medicalization of ordinary human distress.

The psyCommons and its Enclosures: Professionalized Wisdom and the Abuse of Power

The second in a series of videos about the psyCommons looks at how the basic human capacity to resolve and survive the ordinary difficulties of daily life through family, friends and local communities, is undermined by the psychological professions, along with their pharma allies.

 

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PCSR & Alliance September Conference Announcement

THE  BIG  ISSUE(S) – Addressing the Crisis in Psychotherapy and Counselling


An invitation from Psychotherapists and Counsellors for Social Responsibility and the Alliance for Counselling and Psychotherapy to a day conference at Resource for London, Holloway Road, London N7.

Saturday 26th September 2015 – 10am to 5pm. Donation: £10 in advance, £20 on the door.

This event is intended as an opportunity for practitioners to express their concerns about the current direction of counselling and psychotherapy, and to discuss plans for action. If you care about the future of counselling and psychotherapy, please come!

More details and booking form here

BACP’s Ethical Framework Revisions – The Emergence of State-Endorsed Therapy?

I want to talk about what is happening within the British Association for Counselling and Psychotherapy (BACP). I want to put it to you that what is going on there represents a shift towards “state endorsed therapy”.

I use the phrase “state endorsed” to draw attention to the fact that these proposals are designed not by government, or by one of its arm’s length agencies, but by one of our own professional associations. I want to make a separation between this and “state approved therapy”, a term that has been applied to the delivery of therapy under the banner of IAPT (Improving Access to Psychological Therapies). There the format and structure are, to all intents and purposes, laid down by the state itself.

BACP is in transition. In February 2013 its register of counsellors and psychotherapists was endorsed by the Professional Standards Authority for Health and Social Care. In December 2013 the BACP Board of Governors decided to align its membership structure to the BACP Register. By April 2016 all members will either be registered or en route to becoming so. In April 2014 BACP began a consultation with its members on professional ethics. This consultation closed on 28th November and its revised Ethical Framework will come into force in January 2016.

Until this summer BACP had not undertaken a thorough review of its ethics since the late 1990s. In April, May and July this year it ran three 2½ hour webinar seminars on Saturday mornings.

To give you an idea of what this involved, on each of these Saturday mornings there were two half hour presentations by Professor Tim Bond, Emeritus Professor of Professional Ethics (University of Bristol). There were questions from the live audience and there were panel discussions before and after each presentation. The presentations themselves were accompanied by a split screen PowerPoint display so you could read as well as listen to what was going on.

The impetus for changing the Ethical Framework comes from a variety of sources. There have been those developments in theory, in research and in the law that one might expect – and there has also been a quantum leap in computerisation. The most important changes though are connected to the abuse of trust. There have been a whole string of celebrities who have been exposed – Jimmy Savile, Rolf Harris and the rest; there’s been the Winterbourne View care home scandal where residents were physically abused by staff; and there’s the Mid Staffordshire hospitals scandal where perhaps 300 or more people died unnecessarily.

Most importantly there have been the two Francis Reports. One published in 2010 was some 2,000 pages long and dealt with what went wrong in Mid Staffordshire. The other, published in 2013, is half that length and is about how to prevent it happening again.

Robert Francis QC wanted a change of culture in the NHS, but his proposals have been taken up not just by Government but by local authorities, trades unions and professional associations. His reports are changing the whole landscape of health and social care.

In brief Francis is demanding that, when things go wrong, managers must be much more active in setting about remedying matters. They can no longer receive a complaint, set up an enquiry and then sit back and wait for it to report. The impact of the Francis Reports was most apparent in the second of these webinar seminars which proposed major changes to line management and supervision – and these changes need to be understood in the context of two notions which had been previously floated in the webinar presentations: (a) that therapy can be conceptualised as a product, and (b) that supervision can be thought of as part of a quality assurance system.

Not surprisingly, I was more than a little taken aback when I heard these comments.

To the specific proposals and their implications –

  • All clients to be informed by their therapist of the name of their supervisor.
  • The jobs of both therapist and supervisor to be defined as operating in the “best interests” of the client.
  • Supervisors to be required to keep records to show that they have acted in this way.
  • These records to demonstrate that each client of each of supervisee has been spoken about at each supervision session and that the supervisor has, in each case, acted in the client’s best interests.

The focus in this webinar seminar was squarely on the position of those in employment in the health and social care sector. The argument was that, as austerity bites and managers, like everyone else, are expected to do more with less and to new “post-Francis” standards, the position of employed supervisors will be in danger of being marginalised unless supervision can be demonstrated to have a direct impact on client outcomes.

But for me, as a self-employed supervisor working from home, the nightmare scenario was that, if my name is given to all my supervisees’ clients, because of the ease with which contact details can be identified via the internet, I will have to be prepared for the possibility of dissatisfied “customers” contacting me at any time of the day or night demanding that I intervene on their behalf to remedy whatever they happen to be concerned about. The pressure to “do something” will be inescapable and I am almost certainly going to get caught up in enacting something that properly belongs within the therapy itself.

But the situation is worse than this. If BACP is to lay down that there is to be a this direct link between supervision and client outcome and I’m required to keep records on all the supervision I do, I need to be mindful that anything I write may be trawled over by a lawyer in order to detect whether a case can be made Musgraveout that, at some point, I have failed to act in the “best interests” of his or her client.

What’s the likely outcome? Three things, I think –

In the first place there’s the danger of supervisors slipping into defensive practice. Secondly, the knock on consequence is that a surface level understanding of reflective practice will be further entrenched – instead of a reflective attitude lying at the heart of good supervision it becomes a kind of “add on”. Another way of putting this is to say that something will be taken away from the quality of attention I believe a supervisor needs to cultivate, who then acts a role model for each supervisee. Let me give some examples. For Freud the ideal state of mind for a therapist is one in which attention is “evenly hovering” or “evenly suspended”. Drawing on a very different body of theory, Carl Rogers identified six necessary and sufficient conditions for therapeutic change. In both cases there’s a focus that requires full attention – and, if this focus is absent or diluted, something is lost in the quality and depth of the work.


under the rubric of revising its ethics, BACP is apparently willing to accommodate its definition of good practice in counselling and psychotherapy to a shift in government policy


Taken altogether, then, what we have here is an impoverishment of supervision and therefore a constraint on supervisees’ learning about good practice. This is bound to lead, I would argue, to a narrower understanding of what in depth therapy is.

Moreover, in these webinar seminars BACP drew explicitly on an understanding of therapy that highlights its role in the alleviation of distress without any acknowledgement that any such understanding needs to be embedded within a contextual understanding concerned with meaning‑making. This is contrary to the research evidence, as Bruce Wampold showed in the meta-analysis he undertook for his book ‘The Great Psychotherapy Debate’, where he carefully examines the results of thousands of outcome studies.

What puzzled me deeply about these proposals for change is that they appeared to run counter to BACP’s traditional stance, which is to position itself as a broad church and so maximise its chances of dominating the field. So, I suppose, it’s not surprising that, when BACP circulated a revised draft early last month it had made changes.

The emphasis on supervisors keeping records of each supervision session was limited to a general obligation to keep records appropriate to the service being provided. And the duty to tell each client the name of your supervisor has been dropped completely.

But what, you may say, are we to make of all this? Should we be pleased that BACP is responsive to feedback? Or should we be alarmed at the extent to which, under the rubric of revising its ethics, BACP is apparently willing to accommodate its definition of good practice in counselling and psychotherapy to a shift in government policy?

At a BACP meeting I attended in September it was claimed that the original proposals were simply possibilities that were being floated rather than serious options. Shades here of Nigel Farage’s recent backtracking from a firm commitment to privatise the NHS (“We never really meant it anyway”, “It was just an idea we were floating”). But I think what we can say is that, in the course of these webinar seminars, we got some insight into what BACP would be willing to countenance.

So what is there in the latest draft of BACP’s Ethical Framework that still gives rise to concern? And to what extent is it still legitimate to be worried about a movement towards “state endorsed therapy”?

I think there is a good deal to be concerned about, but first we need to look more closely at the wider context and the kind of organisation that BACP is in the process of becoming. BACP’s mission includes wanting to be the leading body for counselling and psychotherapy in the UK. BACP was originally founded in 1977 as an educational charity open to anyone with an interest in counselling. Charitable status confers a patina of respectability and, under English law, all BACP’s activities must be charitable and wholly in the public interest so that any personal benefit accruing to members has to be “incidental”.

Yet at the same time BACP operates a trade association – in other words, it is a group, one of whose primary purposes is to attempt to influence public policy in a direction favourable to its members.

BACP’s membership has expanded rapidly in recent years. When I joined in 1992 it had 6,000 odd members. It now claims it has over 41,000. I think it’s pretty self-evident that people join BACP because they think it is an important step in advancing their careers. Is that, then, an “incidental” benefit? So how can BACP continue to be a charity? I have to hold my hands up here and admit I am completely bemused by what looks to me, a mere cottage industrialist, to be a mismatch between the theory and practice of how charity law works. But what do I know? Eton school, after all, remains a charity.

BACP’s Register is endorsed by the Professional Standards Authority for Health and Social Care. By endorsing Registers such as BACP’s the PSA has said it hopes to establish a gold standard for voluntary regulation in the area of health and social care – and thus obviate the need for statutory regulation. BACP has decided to align its membership structure to the BACP Register. By April 2016 its membership will consist of registered therapists or those on their way to becoming so.

This series of steps links membership of BACP back to the state and, I suggest, leaves individual BACP members more anxious than ever that they will need to comply with any requirements laid down by the organisation if their careers are to thrive.

One thing I think we can say is that, whereas in the past statements about ethics issued by BACP could be viewed as the distillation of a consensus about good practice that was derived from the field, matters are now more complex. In the October 2014 draft of its Ethical Framework, BACP is in some respects more prescriptive. Sometimes the requirement is straightforwardly normative – for instance, formally reviewing knowledge and skills in supervision – but elsewhere standardisation is embedded in the very fabric of the document. The argument seems to be that introducing standardised practices is a good thing because it makes matters more explicit and a greater degree of explicitness is the route to establishing greater trust between therapist and client. This is evident in the overarching structure of the commitment to clients, which frames everything that follows –

  • We recognise that our clients must be able to trust their practitioners with their well-being and sensitive personal information. Therefore we have agreed…that we will…

The detail then follows – for instance in paragraph 26 in the section on ‘Good Practice’ there are the new requirements about written contracts between therapist and client. In this way the building of trust is reduced to a standardised procedure.

The relationship between line managers and clinical supervisors is also specified in terms of procedures that have to be adhered to and reviews that have to be undertaken at least once a year in particular ways – again a standardised procedure. Here are some examples:

  • Where supervision is taking place alongside line management we will consider how responsibility for the different supervision tasks is distributed and will review how the allocation of these tasks is allocated at least once annually.
  • We will review the application of this Ethical Framework to the services being provided at least once annually.
  • We will clarify who holds specific responsibilities to our clients between the practitioner, supervisor and any line managers and review how well these responsibilities are working in practice. This review will take place in supervision as required and at least once annually.

Members are even required to be activists outside the therapy room:

  • We recommend supervision to anyone providing therapeutically‑based services, regularly giving or receiving emotionally challenging communications or engaging in relationally complex or challenging roles.
  • We will challenge colleagues or others involved in delivering related services whose views appear to be discriminatory

In other words – it’s not all bad!


BACP is abdicating its responsibility to assert what it believes is distinct about good practice in counselling and psychotherapy


Elsewhere in this document BACP is deliberately using vaguer language. Some of this is both badly phrased and, I want to say, provocative – for example, “we have agreed…that we will demonstrate accountability and candour by being accountable to you for the …effectiveness of services provided”

What on earth does this mean? Statements of this kind could prove a hostage to fortune, for instance when working with people who adopt a wholly passive attitude to therapy and expect their therapist to fix their problems for them without ever themselves really engaging in the therapeutic endeavour. I don’t think it would be hard for such an individual to use this paragraph in order to make a complaint.

BACP has been here before. In the mid 1990s the BBC’s Watchdog programme took what was then just the BAC (the British Association for Counselling) to task for not taking effective action against the comedian Bernard Manning who had joined BAC and then fixed a brass plaque to his wall announcing that he was a counsellor. BAC claimed this attack was unfair as they had no power to stop him and make him take it down – all they could do was expel him from membership. After that BAC redoubled its effort to gain statutory powers.

In offering to be accountable in this way is BACP setting things up for another media furore that will allow them to press Government for more powers? I wonder.

But there’s another even more significant matter, which is that BACP has deliberately put at the core of the 2014 Ethical Framework the notion that therapists will work in clients’ “best interests”.

Who defines “best interests” and from whose point of view? This is a notoriously slippery concept in law and here, I would argue, BACP is quite deliberately leaving it to the courts to decide what good practice is, I would say in line with what good practice is in the health and social care sector – as opposed to asserting what is special and different about therapy.

A statement asserting what is different about the professions of counselling and psychotherapy is something the courts could have reference to if they needed to consider whether therapists, and especially those in private practice, have different obligations in law from those in the state sector – they certainly do under the Children Act and for good reasons.

Here BACP is emphasising the similarity between therapy and health and social care rather than highlighting the difference –

  • Commitment  We recognise that our clients must be able to trust their practitioner with their well-being and sensitive information. Therefore, we have agreed as members or registrants of BACP that we will…. Put our clients first by making you our first and most important concern during our work together
  • Putting clients first  4. We will make each client’s well-being and best interests our priority whilst working together.
  • Working to professional standards  12. We will collaborate with colleagues to serve the best interests of clients.

In short, is BACP in this draft of its Ethical Framework, abdicating its responsibility to assert what it believes is distinct about good practice in counselling and psychotherapy in favour of inviting the courts to determine how counselling and psychotherapy sit within the overall thrust of state health and social care policy?

Looking into what’s going on in this kind of detail reveals the underlying thrust of the present revision of BACP’s Ethical Framework. If you want further evidence, look no further than the new title – ‘BACP Ethical Framework for the Counselling Professions’.

So there we have it – an organisation, whose mission includes being the lead body for counselling and psychotherapy, is subsuming both coaching and psychotherapy under such a heading – and is thereby marginalising both psychotherapy and in depth counselling whilst, at the same time, privileging a narrow definition of counselling that is actively not supported by the research evidence. Not only that, BACP is preparing to redefine coaching, psychotherapy and counselling as subsets of health and social care. And, whilst claiming that this is a review of ethics, BACP is overtly (as was quite clear in the webinar seminars) redrafting those ethics in order to seek to protect members’ jobs – and, I would argue, promote itself and curry favour with Government.


By Arthur Musgrave. This blog was originally a conference presentation for the Universities Psychotherapy & Counselling Association (UPCA), November 2014. For Arthur’s detailed account of the BACP consultation process, see: https://arthurmusgrave.wordpress.com/2014/11/12/the-british-association-for-counsellings-2014-consultation-on-ethics/

Therapy as State Sponsored Brainwashing?

Unpublished letter to The Telegraph by Professor Andrew Samuels, Centre for Psychoanalytic Studies, University of Essex.

‘As Chair of the UK Council for Psychotherapy 2009-12, I very much hope that all the psychotherapy and counselling registering bodies, particularly those held under the accredited voluntary register scheme of the Professional Standards Authority (PSA), will pay heed to what Sarah Wollaston has said (Stripping benefits claimants if they refuse depression treatment is ‘unethical’, The Telegraph, 13 July 2014).

For any registered member to participate in this Government scheme would constitute serious professional misconduct and lead to serious sanctions. The PSA and the registering bodies that it accredits should immediately issue a joint statement to this effect. From Freud’s idea of ‘free association’ to Jung’s concept of ‘individuation’ to Carl Rogers’s idea of ‘person-centred’ therapy, counselling and psychotherapy are practices that rest entirely on the autonomy of both parties being recognised. That is why, in the contemporary lexicon, therapy is referred to as a ‘co-created’ activity. It can never be allowed to become state sponsored brain-washing.’


Statement on Regulation

REGULATION OF COUNSELLING AND PSYCHOTHERAPY

STATEMENT FROM THE ALLIANCE FOR COUNSELLING AND PSYCHOTHERAPY, MAY 2014

Some years ago, the Alliance played a prominent role in the campaign against the statutory regulation of counselling and psychotherapy (SR). In reviewing the success of this campaign, it seems clear that it was not due solely to a change of Government in 2010. Petitions signed by several thousand practitioners against the plan to regulate the professions via the Health Professions Council (HPC, now HCPC) were remarkable, given the reticence usually shown by therapists in the political realm. Permission to proceed with a Judicial Review of HPC’s conduct was also highly significant. In general, the Alliance considers that, in the words of a Coalition health minister, ‘[we] won the argument’.

We are aware that SR is once again being discussed in some political and professional circles. We have studied Geraint Davies MP’s early day motion and Patrick Strudwick’s articles, and noted some pressure and mobilisation from the same groups of counsellors and psychotherapists who were previously supportive of SR under the HPC.

To us, it is, at the very least, foolhardy to consider rejecting the current Accredited Voluntary Register (AVR) scheme run by the Professional Standards Authority (PSA) which is not even a year old. AVR is a progressive institutional innovation that addresses the vast majority of the defects that existed with the old, traditional voluntary registers. It should be given the opportunity to prove itself by allowing it to continue for at least five years.

The Alliance continues to welcome this scheme which, on balance, we see as substantially superior to the proposals for SR under the HPC. In our view, the PSA scheme has already improved matters. For example, although the old voluntary registering organisations were already operating under ethical codes that made the offer of reparative therapy a matter of serious professional misconduct, it was the PSA’s committed anti-discriminatory policy that underlay the decision by the Association of Christian Counsellors (ACC) to follow suit. Until their accreditation by PSA required a rethink, this organisation was one of the main sources of providers of reparative therapy.

The PSA also deserves much credit for the United Kingdom for Psychotherapy’s (UKCP) adoption of a mandatory Central Code of Conduct, a long overdue reform.


“It is simply not the case that counsellors and psychotherapists are untrained and unaccountable”


The Alliance would like to see the PSA doing more to promote counselling and psychotherapy, including drawing the attention of the public to the existence of its accredited registers. It is simply not the case that, as some supporters of the early day motion state, counsellors and psychotherapists are untrained and unaccountable. Our understanding is that the PSA promised such a promotion during early discussions with the former voluntary registering bodies, so is therefore now obliged to conduct an appropriate campaign.

We hope that the PSA might now engage more with its accredited bodies with regard to how serious sanctions, such as striking off, can be better and more widely communicated to the public.

The PSA has, so far, remained silent on the matter of SR. We realise that it may be politically difficult for the PSA to speak in defence and justification of its own existence but now seems a good time to start such a process. Many of the proposals to reintroduce the failed project of SR seem strikingly ignorant of the nature and even the fact of the AVR scheme. In the face of this, we would like to see the PSA issue a statement on the progress of the AVR scheme so far.


“a damaging and misleading idealisation of statutory regulation is taking place”


The Alliance believes that a damaging and misleading idealisation of statutory regulation is taking place. Unless there is a change in primary legislation, we will continue to see people struck off by statutory registers rebranding themselves and continuing to practice as before. It is highly misleading to claim that evasion of sanction is only a problem for accredited voluntary regulators as has been claimed.

We are perplexed at the linkage of the quite legitimate concern over reparative therapy with SR. We speculate that those who want to see statutory regulation are using current repulsion at general homophobia to further their own political agenda. In reality, most reparative therapy was and is offered by people with a religious orientation whose practice is not going to be affected by any kind of regulation of counselling and psychotherapy.

The Alliance also believes that, whilst prejudice can never be eliminated entirely, the situation in our professions has changed substantially since one small-scale research project of 2009 discovered the extent of reparative therapy being offered.

A key factor in the successful campaign against SR was the development of a convincing argument that statutory regulation of counselling and psychotherapy as ‘health professions’ was and is inappropriate for this field. The medical model of clear-cut diagnosis and treatment does not apply. In particular, an adversarial and generic system of complaints, founded on tendentious principles, and with no systematic inclusion of alternative dispute resolution (ADR – conciliation and mediation) will never be fit for purpose.

We should not forget that, when the HPC’s process was halted, there was no agreement over such central issues as the difference (or not) between psychotherapy and counselling, or whether (or not) work with children required different trainings.

The Alliance for Counselling and Psychotherapy will, of course, fight against any new plans for statutory regulation. But the previous experience was so divisive that we sincerely hope that those who are looking to reintroduce the project will read this statement, reconsider their position and engage with us and the majority in our field in making the still-evolving AVR system work as effectively as possible – in the interests of clients and patients, the professions, and society as a whole.

The above statement has been sent to a number of key figures in the debate, including politicians, journalists, regulatory bodies and therapy organisations.