Psychopractice Regulation: SCoPEd – Generating Psychotherapathy?

by Denis Postle

Sometimes there are projects that in their obtuseness, their folly, and their slippery language, do harm to the human condition. The Scope of Practice and Education framework (SCoPEd)1, the creation of three of the dominant UK psychopractioner organisations, is one of them.

SCoPEd shines a bright light on the activities and supposed validity of the British Psychoanalytic Council (BPC), the United Kingdom Council for Psychotherapy (UKCP) and the British Association for Counselling and Psychotherapy (BACP), and claims to have synthesized a catalogue of standards for the practice of counselling, psychotherapy and psychoanalysis. But spotlighting casts a shadow and SCoPEd, with its recent formal adoption, is no exception – it excludes and demeans countless other viable forms of working with the human condition in the UK.

After two books 2,3 and many articles on therapy regulation 4, 5, 6, 7 and 28 years as a continuing participant in the Independent Practitioners Network (IPN) 8 – an antidote to earlier attempts to regulate UK psychopractice – and publishing the eipnosis website 9, I had given up speaking from the regulationist shadow. Except, if direct government control or legalised titles were to emerge. SCoPEd isn’t that, but it points in that direction.

And this is why SCoPEd is a problem. No, worse than a problem, offensive. Younger practitioners may not be aware that SCoPEd is only the latest in close to a quarter of a century of attempts to professionalize their delivery of working with the human condition in the UK, with the barely hidden aspiration of seeking state endorsement of this status.

It was offensive, two decades ago, to sit opposite Anne Casement, the then chair of the UKCP, in a BBC Radio 4 studio,10 declaiming that:

“At the moment, we’re a voluntary register but we are now in the process of moving to registration by law, to statutory registration, we’re actually in the process of doing that… We’re seeking to protect the title of ‘psychotherapist’, so after that, once we’ve registered by law, anyone who calls themselves a ‘psychotherapist’ will have us to deal with”. (Casement 1999)

Other senior therapy practitioners claimed that there was a need ‘to rid the psychotherapy garden of its weeds’ 11. At a Parliamentary hearing about Health Professions Council regulation, I heard someone behind me describe non-compliants such as myself as ‘charlatans’.

Numerous authors and activists pursued opposition to the ambitions of professionalized counselling and psychotherapy. 12,13,14 See also my 2007 book Regulating the Psychological Therapies: From Taxonomy to Taxidermy (mapped, measured, captured and stuffed?)2 , the title of which continues to encapsulate 16 years of the antecedents (and likely result) of SCoPEd.

If you are as yet unfamiliar with SCoPEd, three previously warring factions 15 in the UK psychological demographic – BACP, UKCP, and BCP – got together to enable them to become a closed shop in the provision of psychotherapeutic services in the UK. SCoPEd developed three areas of ‘expertise’ and ‘competence’, to represent the claimed capacities of – respectively – counsellors, psychotherapists and psychoanalysts.

In the latest iteration, the three columns have been neatly scrambled to blur this exclusivity, an arrangement that also softens the ascension of BPC psychoanalysis to the heights of psychopractice insight and expertise, leaving BACP members to occupy the prairies of mere counselling.

So what is wrong, mistaken, or harmful about SCoPEd?

Let’s start with it as a taxonomy – describing and circumscribing instances of life and organising them into hierarchical categories.

The SCoPEd taxonomists looked at the practice of the three distinct, and to some extent, antithetical professional organisations, and came up with a hierarchical array of ‘standards’ and ‘competences’. This does two kinds of harm: it does violence to the need for sufficient varieties of caring response to the miasmic diversity of the human condition; and its exclusivity invalidates the many other ways of working with people, as though Co-counselling, Reiki, Sacral cranial, The Alexander Technique, hypnotherapy, Lacanian analysis, massage, breathwork, birthwork, yoga, meditation, dance therapy, EMDR, animal-assisted therapy, horticultural counselling, aroma therapy, sand tray therapy, mindfulness, acupuncture, reflexology, didn’t exist.

SCoPEd diligently explored the professional walled gardens of BACP, UKCP and BPC, and sought and claim to have discovered a legitimate catalogue of psychopractice ‘standardisation’. Apart from making public and underlining the value of the three psycho-professional institutions, what is this for? Isn’t it primarily trying to make them ‘plug and play’ compatible with the NHS and other institutions that hire psychopractitioners? Not least an increasingly privatized NHS. And let’s not forget the 19+ UK universities and the many higher education institutions that run psychopractice courses; for them and the core group of therapy and counselling trainings, SCoPEd’s standardization of psychopractice is happily resonant with the examination/audit culture that infects too much of education.

In The Administration of Fear 16 Paul Virilio speaks of his WW2 childhood experience in Nantes of living under German rule. There were three ways of coping with it, he says: Occupation, being compliant, making the best of it; Cooperation, actively supporting the occupation; and Resistance, acting to derail or stop it.

I see the gilded credentials of the 75,000 practitioners that support the SCoPEd enterprise as a form of ‘occupation’ of the UK psychopractice demographic. It demeans and excludes. And there seems little doubt this patronizing of the ‘inferior’ is what is intended. While there has been significant disquiet about the ‘occupation’, there does seem to have been too much ‘making the best of it’ and not enough ‘resistance’.

Is it tolerable that the nuances of love, of flourishing, of rapport and presence seem absent from the standards? Will they also be absent from future generations of work with clients?

Is this too strong? I think not. SCoPEd is coercive and prescriptive, the best that could be distilled from warring tribes, built via conversations that we might suspect were conducted in Russian ‘vranjo’ mode: “We know that SCoPEd is ethically dubious”; “you know that we know”; “we know that you know but we all keep pretending it is OK”. But is it tolerable that the nuances of love, of flourishing, of rapport and presence seem absent from the standards? Will they also be absent from future generations of practitioner work with clients?

Some psychopractice organisations have voiced opposition to SCoPEd 17,18 but there doesn’t appear to have been a coalition of the excluded. SCoPEd partners commissioned an Impact Assessment, 19 it acknowledged that there was scepticism of the value of the framework but insufficient to derail adoption by the three principal partners, or to deter the National Counselling Society, Human Givens, and the Association of Christian Counsellors joining it for the ride.

The fundamental flaw of SCoPEd, as a protocol promoting a service industry, is that it does nothing to mitigate or even address, practitioner abuse of clients. It leaves clients as the default quality controller; defective practice is identified when someone complains. It doesn’t include what clients need to feel safe – active practitioner engagement with civic accountability. Do other practitioners who know us well personally, stand by our practice? Would they send us clients? And not least, is there ongoing peer assessment of our ‘presence’ and our reputation, that comes with sustained contact?

Sadly, once qualified, a SCoPEd practitioner can keep up a subscription to their regulation club, occasionally dip into CPD, and discuss clients with a supervisor but otherwise avoid reciprocal exposure of their vulnerability with peers. So far as we avoid sharing with peers where we are in our lives, changes in the quality of our ‘presence’ and ‘rapport’ that would merit support, and perhaps challenge, are likely to remain out of sight. These are qualities that appear to contribute more to beneficial outcomes than MA’s, degrees or diplomas 20. The high price of the ‘qualifications’ that entry to SCoPEd requires may justify a paywall for access to psychopractice but for clients looking for a practitioner who can be trusted with their concerns, or their distress, they can often be an inadequate long-term quality guide to practitioners.

The SCoPEd collection of psychopractitioners are people who we might suppose are aware of the social implications of how power and privilege is distributed, of how it can become fossilized, and who are supposedly sensitive to the infinite varieties of grief, fear and anger we may feel. And while mortgages, as a colleague reminds me, may have a significant influence in these matters, how can they submit to their occupation by the SCoPEd catalogue of ‘standards’?

Beyond its politeness, there is something gross about SCoPEd.

Off the page but successfully expressed in the SCoPEd protocol, is the long-standing determination of psychoanalysis to dominate the psychopractice field; how can this illustration of competencies below not be seen as showing ‘C’ (psychoanalysis) as being on top?

And aren’t dominion and its counterpart, subordination, very common client agendas? So how come the flag of psychoanalytic dominion that SCoPEd waves over the enormous UK psychopractice demographic, is acceptable and even cherished by its exponents? Related to this psychoanalytic dominance, is the extent to which SCoPEd, in its apparent drive to open access for psychopractice to the NHS, mirrors/mimics the pyramidal medical establishment, of which psychiatry, a key product distribution arm of Big Pharma, is the dominant, scandalous 21 partner.

Off the page even further, alongside all these reasons for rejecting SCoPEd, there is a perhaps an even more fundamental reason for scepticism. Chasing the wraiths of regulation, and reflection on my own practice, led me to see that, along with other aspects of our threatened civilisation, psychopractice has the form of an extractive industry.22 People meet with psychopractitioners to have their distress or concerns attended to, and across generations of these encounters, from what we have learned with clients, practitioners have extracted a theory and practice base. Clients and trainee practitioners buy this accumulated knowledge and practice as a service but it could and perhaps should be more freely shared. So, in as much as the SCoPEd iteration of this knowledge base becomes a commodity, designed as it appears, for privileged access to the NHS, it may need to be seen as a form of psychotherapathy, potentially delivering an impoverished version of psychopractice.

Taxonomy as a basis for regulation can seem to be a societal disease, the grasping and compressing of the ineffables of desire and anxiety and disappointment into categories and hierarchies. My recent engagement with the climate crisis revealed that there was a hidden dynamic in all this. I had hinted at it a long time ago as ‘glaciation’22 but it merits a bigger role. I came to see that civilizations and their institutions such as psychopractice can be helpfully seen as an accumulation of ‘crystallization’ 23: feeling and perception crystallize as speech; words crystalize as writing, writing crystalizes as books; risk crystallizes as insurance; client behaviour crystallizes as diagnosis; SCoPEd crystallizes psychopractice as ‘standards’.

Today, with crystallisation proceeding at the speed of light via digitisation, taxonomy may be reaching its ultimate limit, with SCoPEd as an example of its paralysing grasp. At our crisis-ridden time, if we want to sustain a fruitful approach to working with the human condition, might not inventing/building/creating ways of contradicting this crystallization be more relevant than reinforcing it as SCoPEd does?

What would that alternative look like?

A very long way off the page of SCoPEd, is self-directed learning. There used to be a university, East London, that ran self-directed education. I taught there, my son did a very good degree by self-directed learning there; it seemed very successful but it disappeared.

I learned my core psychopractice capacity from the self-directed culture of co-counselling 24, and from cooperative experiential work with John Heron 25 and Anne Dickson 26. Building on 25 years as a film director, I learned to facilitate groups as an apprentice, and with Mary Corr and a dozen others generated thriving ‘cooperative enquiries’ 27,28. Around 2000 hours of this self-directed learning, plus self and peer assessment, became enough to begin to work as an independent psychopractitioner, and 28 years of participation in IPN has supported decades of my practice and civic accountability.

I would like to be mistaken but my guess is that this route to psychopractice – where personal development and self-direction sometimes mutate into a vocation as a psychopractitioner – is now closed. SCoPEd lays the foundations for a day job.

From a long-term client perspective, SCoPEd is bad news. Take it down.


Notes/references

1 The Scope of Practice and Education framework (2022) https://www.bacp.co.uk/about-us/advancing-the-profession/scoped/

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

3 Postle, D. (2012) Therapy Futures: Obstacles and Opportunities (Introducing the PsyCommons), London: Wentworth Learning Resources (available from Lulu.com)4 Postle, D. (2000) Statutory Regulation: Shrink-Wrapping Psychotherapy British Journal of Psychotherapy https://www.academia.edu/26110963/Statutory_Regulation_Shrink_Wrapping_Psychotherapy

5 Postle, D. (1998) The Alchemist’s Nightmare: Gold into Lead – The Annexation of Psychotherapy in the UK International Journal of Psychotherapy 3: 53-83.

6 Postle, D. (1997) How does your garden grow? Counselling News, June: 29-30.

7 Postle, D. (2005) Psychopractice Accountability: A practitioner ‘full-disclosure list’ in Bates, Y. and House, R (eds) Ethically Challenged Professions: Enabling Innovation and Diversity in Psychtherapy and Counselling 172-8, Ross-on-Wye: PCCS Books

8 Independent Practitioners Network, https://ipnetwork.org.uk/

9 Postle, D. (2008) eipnosis: A Journal for the Independent Practitioners Network: Contents http://ipnosis.postle.net/pages/IpnosisContents.htm

10 Casement, A. (1999) Straw poll talkback. BBC Radio 4, 4 September.

11 Postle, D. (1997) How does your garden grow? Counselling News, June: 29-30.

12 Mowbray, R. (1995) The Case Against Psychotherapy Regulation: A Conservation Issue for the Human Potential Movement, London: Transmarginal Press

13 House, R and Totton, N. (eds) (2011) Implausible Professions: Arguments for Pluralism and Autonomy in Psychotherapy and Counselling. 2nd Edn, Ross-on-Wye: PCCS Books

14 Postle, D. (2021) Calling All (UK) Therapists Video London: WLR

15 The Final HPC Professional Liaison Group Meeting (2011) pp 289-294. In Postle, D. (2012) Therapy Futures: Obstacles and Opportunities (Introducing the PsyCommons), London: Wentworth Learning Resources (available from Lulu.com)

16 Virilio, P. (2012) The Administration of Fear semiotext(e): Cambridge Mass. MIT Press

17 Partners for Counselling and Psychotherapy (2023): response to January 22 iteration of the ScoEd framework https://www.partnersforcounsellingandpsychotherapy.co.uk/pcp-response-to-january-2022-iteration-of-the-scoped-framework/

18 The Person Centred Association (2023) Welcome and ScopEd updates and info-where next? https://www.the-pca.org.uk/blog/welcomeandscoped.html

19 ScopEd Impact Assessment (2022) https://www.bpc.org.uk/download/8155/Final-Report-on-the-Impact-Assessment-of-the-SCoPEd-Framework-December-2022.pdf

20 Wampold, B., E. (2001) The Great Psychotherapy Debate, Ch. 8: 2020, London: Lawrence Erlbaum Associates

21 A judge sentences unqualified psychiatrist Zholia Alemi to 7 years in jail but for 22 years the psychiatrists she worked alongside apparently failed to notice that she was as effective, or ineffective, as they were. https://www.theguardian.com/uk-news/2023/feb/28/judge-jails-fake-nhs-psychiatrist-and-criticises-abject-failure-of-scrutiny

22. Postle D. (2014) The PsyCommons: Professional wisdom and the Abuse of Power p16-17 Asylum Spring

22 Postle, D. (1994) The Glacier Reaches Edge of Town. Self and Society 23(6): 7-11.

23 Postle, D. (2021) The End of Progress Self & Society Vol 49 No1 Spring, Podcast version: https://soundcloud.com/denis-postle/the-end-of-progress

24 Co-counselling International (UK) http://www.co-counselling.org.uk/

25 Heron, J. (1996) Cooperative Inquiry: Research into the Human Condition, London: Sage

26 Dickson, A. (1985) The Mirror Within: A New Look at Sexuality London: Quartet

27Postle, D. The Nuclear State (1982) Video Crucible: Science and Society, ATV https://vimeo.com/576904068

28 Spencer A. Postle, D. (1998) From Survival and Recovery to Flourishing: a residential co-operative inquiry, London:  Counselling News

Person-Centred Therapists Call on SCoPEd Partners to Offer PSA-Backed Membership Home for those Opposed to Framework

Photo by Scott Webb on Pexels.com

A group of prominent practitioners, writers, trainers and academics from the Person-Centred community in the UK, along with two organisations, have published an open letter calling on the SCoPEd organisations to provide a professional home on their PSA-backed registers for members who do not wish to be aligned with SCoPEd’s divisive and hierarchical framework.

Referencing the recent Impact Assessment’s recommendation that an ‘important space remain for those therapists who are unconvinced of SCoPEd’s desirability’, the letter lays out some of the main challenges to SCoPEd and proposes a way forward that would include those who do not see the framework as an accurate or ethical representation of their work as counsellors and psychotherapists. As the letter states,

We are calling on the membership bodies to respect and acknowledge the rights and needs of members who do not wish their practices to be aligned with SCoPEd. We value our membership organisations as diverse collectives of professionals and do not want to be forced out of these organisations in order to retain our integrity…. We ask that each organisation develop within their PSA-approved registers an opt-in membership category that is not aligned with the SCoPEd framework’s columns.

See the full letter below.


Open Letter to the SCoPEd Membership Bodies from Members of the Person-Centred Therapy Community

April 2023

Context

SCoPEd has been formally adopted by all the professional organisations involved, including the three largest membership bodies in the UK (BACP, UKCP and NCS), and the project now turns to the question of implementation. For those of us in the person-centred approach who have long critiqued both the framework and the organisational processes around it, and have serious ongoing concerns about the potential outcomes (PCG, 2020), this is a disappointing moment. Despite our best efforts, little of any substance has changed in the structure of the framework since the first iteration and all our principal concerns remain:

  • The impacts on equality, diversity and inclusion in the counselling and psychotherapy profession of adopting a simplistic hierarchical structure based on initial training – a structure which cements and entrenches existing inequalities in the field.

The inability of the SCoPEd organisations to provide sufficient meaningful data on EDI to the Impact Assessment speaks volumes about how seriously it took these concerns until compelled to address them by the assessment process. The proposed ‘gateways’ between levels are still vague, unspecified and fraught with the same issues of exclusion and elitism, while SCoPEd’s likely impact on the training market will only exacerbate the inaccessibility of the top tier(s) of the framework.

  • The poorly evidenced return to differentiating ‘counselling’ and ‘psychotherapy’, with ‘psychotherapy’ positioned as the more competent and skilled activity.

‘Counsellors’ and ‘counselling services’ are often found undertaking some of the most complex work in the field and the BACP itself found no evidence for differentiation as recently as the late 2000s, yet under SCoPEd ‘counselling’ has been demoted to a position of inferior competence.

Within the person-centred approach, counselling and psychotherapy are considered indistinguishable (e.g. Rogers, 1942; Thorne, 1999) but hierarchical differentiation effectively downgrades person-centred therapy, an approach that for historical, political and organisational reasons (Rogers, 2019) rather than issues of competence, depth or evidence-based effectiveness, is mostly practiced in the UK under the title of ‘counselling’.

  • Hierarchical differentiation flies in the face of decades of therapy research studies and meta-analyses, which do not find psychoanalytic psychotherapy and psychoanalysis and their attendant training norms – that so dominate the top tier of the SCoPEd framework – to be in any way superior in helping clients or in producing more competent practitioners to person-centred therapy, which finds its differing training culture mapped onto the lower two tiers despite being solidly evidence-based (e.g. Cooper, Watson & Hölldampf, 2010; Elliott et al, 2013; Murphy & Joseph, 2016).

This creates the absurd injustice that under SCoPEd a new graduate of, for example, a psychotherapy programme approved by the British Psychoanalytic Council (BPC) is automatically deemed more competent (dropping straight into the top level ‘C’) than a humanistic ‘counsellor’ who could never have afforded such a course but has accumulated years of experience: working in a range of settings with diverse client groups; supervising and managing other therapists; engaging in varied personal and professional development; teaching on counselling and psychotherapy training courses; undertaking research; contributing to the profession in a variety of other ways; and yet still finds themselves in column ‘A’ or ‘B’.

Such an injustice is not only wrong on principle, but is also confusing, misleading and potentially harmful to clients, who may be persuaded by SCoPEd’s claims of differing ‘competence’ that, in our example above, the newly trained BPC graduate is inherently more safe and effective than the experienced humanistic counsellor. We note here that there is no evidence that graduates of trainings leading directly into column ‘C’ are less likely to harm clients through professional malpractice.

  • The notable exclusion of person-centred voices in the important developmental stages of the framework and the dominance of psychoanalytic views, e.g. in the make-up of the Expert Reference Group, even after it was minimally expanded, which have distorted the project’s direction.

Here we contrast the role of the British Psychoanalytic Council, which in SCoPEd has enjoyed a prominence and influence disproportionate to its number of members, with the role of the much larger National Counselling Society, which was initially excluded from the project until a draft framework was already in place.

  • The framework’s capitulation to the fading notion that therapy will forever be an extension of medicine and healthcare, with their medicalised systematising of human experience and manualisation of psychological ‘treatment’.

The leading edges of counselling, psychotherapy and psychology are moving away from medicalisation (Johnstone & Boyle, 2018; Sanders & Tolan, 2023), yet SCoPEd takes a step back towards it. As person-centred therapists, we cannot sign up to the framework’s delegitimising of the ‘third force’ in psychology, the humanistic approaches, which have pioneered radically de-medicalised theory and practice since the middle of the twentieth century.

  • The single-minded commitment to a methodology derived directly from the manualisation of CBT for the IAPT project (Roth & Pilling, 2008).

In SCoPEd, this methodology relied on a narrow and self-referential range of evidence and ignored all other research into practitioner effectiveness and client outcomes (Murphy, 2019), with the result being that the framework grossly misrepresents the reality of practice on the ground.

  • The divisiveness of the project, which has talked a great deal about listening to members’ concerns but at every turn has sought to dispute, rebuff, ignore or, in some cases, silence critique and dissent (e.g. by not publishing members’ letters in organisational journals).

‘Listening exercises’ and ‘consultations’ have not led to any substantive change in the trajectory of the project or the structure of the framework itself and it has since emerged that efforts to question the project, temper its excesses and address its failings by senior figures in BACP, such as the former Deputy Chair who recently resigned over the issue (Golding, 2023), have been blocked.

A Way Forward

For us, these are not the characteristics of a project that embodies the values of counselling and psychotherapy. We believe SCoPEd to be too flawed to impose on the field as a whole. We understand that there are complex issues around training, practice and the future of therapy, but we do not find SCoPEd to be a convincing solution to the challenges we face, or even the right path on the way to a solution.

So we are calling on the membership bodies to respect and acknowledge the rights and needs of members who do not wish their practices to be aligned with SCoPEd. We ask that we are not forced to adopt the framework by being assigned a title and position in the columns against our will.

We value our membership organisations as diverse collectives of professionals and do not want to be forced out of these organisations in order to retain our integrity. While some may choose this path to leave (and there are legitimate forms of professional accountability away from the PSA registers), for many this simply isn’t viable due to the requirements of the job market – therapists need to earn a living and being on a PSA register is increasingly seen as a necessity for employment.

The recent Impact Assessment recommends, ‘[a]n important space can remain for those therapists who are unconvinced of SCoPEd’s desirability if the framework is taken forward.’ (Eastside Primetimers, 2022, p.3). In this spirit of inclusiveness and constructive engagement, we call on the SCoPEd organisations to create a professional home for the substantial number of therapists in their memberships, which the NCS member vote suggests could be as high as 46%, who do not see their work and identities reflected accurately in the framework.

We ask that each organisation develop within their PSA-approved registers an opt-in membership category that is not aligned with the SCoPEd framework’s columns.

We would welcome discussion on the practicalities of such a membership track, how it is defined, the standards of entry, accessibility for new and existing practitioner members and so on. We believe this proposal to be a creative, inclusive and growth-promoting response to an issue that has deeply divided the field, threatens to be intractable, and has already consumed too much time and energy for all those involved, including both the SCoPEd bodies and the many therapists, academics, activists and organisations who have attempted to call the project to account.

Therapy is inherently concerned with internal and external conflicts, as well as issues of power, identity, difference and diversity. Therapeutic work untangles externally imposed singular truths and welcomes multiplicity in thought, feeling and being; respectfully holding the tensions this can create. Whatever our concerns, we understand that the leaders of the SCoPEd project believe in their framework and that a portion of members will be content to be mapped onto its tiered practitioner categories. We call on these organisations to respectfully include those of us who experience the framework very differently, not just with words but in action – valuing our ethical, congruent and engaged participation by welcoming us into new membership categories on the PSA registers that are not mapped onto the SCoPEd framework’s columns and titles.

Signed

The Person-Centred Association (tPCA)

United Kingdom Person-Centred Experiential (UKPCE)

Dr Peter Blundell (letter co-author), BACP Registered Member, NCS Accredited, Senior Lecturer, Liverpool John Moores University

Rhianna Broadway, BACP Registered, Primary Tutor/Lecturer, Dip/MSc Contemporary Person-Centred Psychotherapy & Applications, Metanoia

Dr Rose Cameron, Edinburgh University

Dr Shun Chen, BACP Accredited, School of Education, University of Aberdeen

Sally Chisholm, BACP Registered, Programme Director for Counselling and Psychotherapy, Keele University

Lesley Dougan, BACP Accredited, NCS Senior Accredited, Programme Lead MA in Counselling and Psychotherapy Practice, Liverpool John Moores University

Dr Richard Doyle, BACP Registered, Assistant Professor, School of Education, University of Nottingham

Sam Driscoll, BACP Registered

Dr Irene Dudley-Swarbrick, Senior Lecturer, Edge Hill University

Dr Ivan Ellingham, HCPC & British Psychological Society Chartered Counselling Psychologist

Dr Gergana Ganeva, BACP Registered, HCPC, BAAT, CPsychol, Lecturer in Counselling and Psychotherapy, Edge Hill University

Dr Jeff Harrison, BACP Accredited, Senior Lecturer, Liverpool John Moores University

Sheila Haugh, UKCP Registered, Director of Studies, Dip/MSc Contemporary Person-Centred Psychotherapy and Applications, Metanoia

Jen Holland, BACP Registered, Assistant Professor, School of Education, University of Nottingham

Professor Stephen Joseph, British Psychological Society, School of Education, University of Nottingham

Janet Mowat, BACP Accredited, Practice placement coordinator, University of Aberdeen

Professor David Murphy (letter co-author), School of Education, University of Nottingham, Independent Practitioners Network (IPN)

Amber Parkinson, BACP Registered , Senior Lecturer, Edge Hill University

Dr Urszula Plust, NCS Accredited, School of Education, Human Flourishing Research Centre, University of Nottingham

Dr LJ Potter, NCS, School of Health, Science and Wellbeing, Staffordshire University

Dr Sue Price, NCS Accredited

Dr Gillian Proctor, University of Leeds

Andy Rogers (letter co-author), BACP Registered Member, Alliance for Counselling & Psychotherapy, IPN

Federica Savoré, BACP Registered, MCOSCA, Teaching Assistant, University of Aberdeen

Dr Susan Stephen, COSCA Accredited, Lecturer, University of Strathclyde

Janet Tolan (letter co-author), BACP Fellow, NCS Senior Accredited

Dr Kathleen Vandenberg, BACP Registered, Senior Lecturer, Liverpool John Moores University

Graham Westwell, BACP Registered, Senior Lecturer, Edge Hill University

Paula J Williams MSc, NCS Fellow

References

Cooper, M., Watson, J. C., & Hölldampf, D. (2010). Person-Centered And Experiential Therapies Work: A Review Of The Research On Counseling, Psychotherapy And Related Practices. Ross-on-Wye: PCCS Books.

Eastside Primetimers (2022). Final Report on the Impact Assessment of the SCoPEd Framework. Retrieved 02/03/2023 here: https://www.bacp.co.uk/media/16980/final-report-on-the-impact-assessment-of-the-scoped-framework-december-2022.pdf

Elliott, R., Watson, J., Greenberg, L.S., Timulak, L., & Freire, E. (2013). ‘Research on humanistic-experiential psychotherapies’. In M.J. Lambert (Ed.), Bergin & Garfield‘s Handbook of Psychotherapy and Behavior Change (6th ed.) (pp. 495-538). New York: Wiley.

Golding, M. (2023). Linked In post. Retrieved 02/03/2023 here: BACP Resignation Statement Feb 23

Johnstone, L. & Boyle, M. with Cromby, J., Dillon, J., Harper, D., Kinderman, P., Longden, E., Pilgrim, D. & Read, J. (2018). The Power Threat Meaning Framework: Towards the identification of patterns in emotional distress, unusual experiences and troubled or troubling behaviour, as an alternative to functional psychiatric diagnosis. Leicester: British Psychological Society.

Murphy, D. (2019). The Questionable Evidence Base of SCoPEd. Blog retrieved 02/03/2023 here: https://allianceblogs.wordpress.com/2019/01/31/the-questionable-evidence-base-of-scoped/

Murphy, D., & Joseph, S. (2016). Person-centered therapy: Past, present, and future orientations. In D. J. Cain, K. Keenan, & S. Rubin (Eds.), Humanistic Psychotherapies: Handbook of Research and Practice, Second Edition (pp. 185 – 219). Washington: APA.

PCG (The Person-Centred Group) (2020). ‘SCoPEd: Insufficient and Incongruent – An open letter to BACP’. Retrieved 02/03/2023 here: https://allianceblogs.wordpress.com/2020/10/16/open-letter-person-centred-calls-on-bacp-to-halt-scoped/

Rogers, A. (2019). Maps, Languages & Lost Continents: Person-Centred Therapy And The SCoPEd Project. Blog retrieved 02/03/2023 here: https://allianceblogs.wordpress.com/2019/07/31/maps-person-centred-therapy-scoped/

Rogers, C. (1942). Counseling and Psychotherapy: Newer Concepts in Practice (p. 4). Boston: Houghton Mifflin.

Roth, A. D., & Pilling, S. (2008). Using an evidence based methodology to identify the competences required to deliver effective cognitive and behavioural therapy for depression and anxiety disorders. Behavioural and Cognitive Psychotherapy, 36, pp. 129-147.

Sanders, P., & Tolan, J. (eds) (2023). People Not Pathology: Freeing Therapy From The Medical Model. Ross-on-Wye: PCCS Books.

Thorne, B. (1999). ‘Psychotherapy and counselling are indistinguishable’ (pp. 225-232) in Feltham, C. Controversies in Psychotherapy and Counselling. London: Sage.

Partners for Counselling & Psychotherapy

We’re proud to be a part of a new partnership of groups from across the field of counselling, psychotherapy and psychoanalysis called Partners for Counselling & Psychotherapy.

Check out the video above for more about the work of this new and radical collaboration, which includes the following membership organisations, campaign groups and think tanks:

Surviving Work

A Disorder for Everyone

Free Psychotherapy Network

National Counselling Society (NCS)

Psychotherapy & Counselling Union

Psychotherapists and Counsellors for Social Responsibility

Counsellors Together UK

The Person Centred Association

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Maps, Languages & Lost Continents: Person-Centred Therapy and the SCoPEd Project

Andy Rogers takes at look at the telling absence of the Person-Centred Approach in the development of the SCoPEd project.


There is so much to say about SCoPEd that it can be hard to know where to start. Fortunately, many elements of the project – the motivation, methodology, evidence-base, hierarchical structure, consultation process, conflicts of interest and so on – have been closely examined elsewhere, particularly on blogs and social media. So here I want to home in on a few core issues for person-centred practitioners.

Person-Centred Therapy (PCT) has been a major force in the UK therapy landscape since the 1980s. Leading practitioners were influential in the development of counselling services in education and contributed much to the growth of counselling training and professional organisations. The book Person-Centred Counselling in Action (Mearns & Thorne, 1988) is still a core text on many counselling courses and remains one of the UK’s best-selling counselling titles of all time.

Note that already I am referring to ‘counselling’ rather than ‘psychotherapy’. This is important for the SCoPEd project because its draft ‘competency framework’ explicitly differentiates ‘counsellors’ and ‘psychotherapists’, albeit with a third intermediate category labelled ‘advanced qualified/accredited/psychotherapeutic counsellor’. This differentiation, which the largest professional body involved, the British Association for Counselling & Psychotherapy (BACP), had argued previously there was no evidence for, has come in for much criticism; mostly – but not exclusively – from counsellors whose work has been downgraded, with newly qualified psychotherapists defined in the framework as more competent across a range of practice areas.

Inconvenient histories

Before I get side-tracked into the many overlapping issues here – not least around the organisational politics that feed this project – let’s just step back into the world of the person-centred therapist.

In PCT, there is not, and never has been, any meaningful differentiation between counselling and psychotherapy. A contemporary practitioner might be attuned to how others use these terms in a differentiating way and to the tendency for trainings with these labels to meet the differing requirements for professional organisations that cater mostly for either ‘counsellors’ or ‘psychotherapists’. They might also note wryly the way this division operates in the field of employment, with differences in pay, fees, context, status and so on. As Thorne (1999) writes, we need to ‘face the unpalatable truth that the business ethic is all-pervasive… In such a marketplace it is not politic to affirm that counselling and psychotherapy are indistinguishable’ (pp.229-230). Yet, in terms of the therapy itself, i.e. what happens between practitioner and client, there is no substantive case for differentiation within person-centred working.

In the academic literature, the tendency is to refer simply to ‘Person-Centred Therapy’ or to use the terms ‘counselling’ and ‘psychotherapy’ interchangeably. I was going to reference some texts here to illustrate the point but it makes more sense to throw out a challenge: find me a book or paper that articulates the difference between person-centred counselling and person-centred psychotherapy. If any exist, they will still be contradicted by almost all the other person-centred literature.

Much of the contemporary person-centred attitude to these terms has evolved from the position of the approach’s originator, Carl Rogers, who clearly viewed PCT as a form of psychotherapy (just browse his book titles), yet made no distinction between ‘psychotherapy’ and ‘counselling’. As far back as 1942, Rogers was using the terms interchangeably, writing that, ‘intensive and successful counseling [sic] is indistinguishable from intensive and successful psychotherapy’ (Rogers, 1942, p.4, my emphasis). Poignantly for the current debates, the general use of ‘counselling’ for the work of therapy also has its roots in Rogers’s life and work. As a clinical psychologist with no medical training, he made a tactical switch to ‘counselling’ in the mid-1950s in Chicago, when legally the practice of psychotherapy required medical qualifications.

Whatever the pragmatic motivations at the time, it is important to note that the person-centred approach was already becoming a direct challenge to the hegemony of the medical model (and would continue to be so, with increasing vigour and depth), so the switch also made sense politically and philosophically. Clearly, 1950s Chicago is a world away from the UK in 2019, but it is interesting how relevant this moment remains, how the terms continue to have a political potency: are contested, subject to claims of ownership and find themselves jostled into a status hierarchy that serves the interests of those who already have more power in the field by bolstering their portrayal of superior legitimacy, skill, depth or competence.

And there is another more recent historical nugget to unearth here too, which is that PCT’s association in the UK with ‘counselling’ rather than ‘psychotherapy’ could easily have gone the other way. In the early 1980s, as the United Kingdom Council for Psychotherapy (UKCP) developed in parallel with the BAC (then without the ‘P’ for psychotherapy), the person-centred approach had not yet established national organisational representation. So, as Mearns & Thorne (2000) write, there was,

‘no institutional process by which the approach could be involved with the developing professionalisation of psychotherapy/counselling. The result was that the work of engaging with professional organisations was left very much up to individuals, […] person-centred specialists [who] made the pragmatic choice of investing their time in BAC.’ (p.26)

Importantly, the decision not to go with UKCP was not made because PCT failed to qualify as ‘psychotherapy’. In fact, ‘it was only small matters of difference which inspired this choice’ (ibid.), mainly around personal therapy requirements and the approach’s potential positioning within UKCP’s humanistic section.

This alignment with BAC(P) would inevitably lead to an association with ‘counselling’ rather than with ‘psychotherapy’, so it is intriguing to wonder about how the field would have looked had PCT found its professional home within UKCP instead. Who knows how the approach – and indeed UKCP – would have evolved? But the SCoPEd project washes its hands of these inconvenient histories and their attendant complexity and illuminating angles.

Undoubtedly times have changed but PCT has never reneged on its philosophical, political and practical position in relation to ‘counselling’ and ‘psychotherapy’. As one of its leading thinkers in the UK has argued, the case for differentiation – inseparable as it is from professional politics – demands close scrutiny:

‘there is no essential difference between the activities currently labelled “counselling” and “psychotherapy”… [T]o suggest that there is is the result of any one or a permutation of the following: muddled thinking; a refusal to accept research evidence; a failure to listen to clients’ experiences; a lust for status; needless competitiveness; power mongering; a desire for financial gain; or some other unworthy motive prompted by professional protectionism.’ (Thorne, 1999, p.225)

Maps and missing territories

The fact that one of the most established therapeutic traditions in the UK has a lot to say on these matters – not only differentiation but manualisation and professionalisation generally – has been of such little interest to the SCoPEd project that there was no PCT representation on the teams tasked with developing the framework. Even the humanistic modalities more broadly were grossly underrepresented in the Expert Reference and Technical Groups, which were dominated by psychoanalytic practitioners. Statements from BACP following the outcry amongst members about this blatant bias have made small admissions that they got some of the language wrong and were endeavouring to recruit new people to better balance the team.

But how can this have been so overlooked at the outset? What does it say about a project which wants to ‘map’ the world of counselling and psychotherapy that it would erase a whole continent of thought and practice and then, when the inhabitants are outraged, desperately try to patch things up with reassurances that they are ‘listening’ and want to get it right?

What does it say about a project which wants to ‘map’ the world of counselling and psychotherapy that it would erase a whole continent of thought and practice?

Why has the person-centred approach been ignored in this way? Perhaps part of the answer lies somewhere in the SCoPEd organisations’ uncritical embrace of a ‘competency framework’ methodology derived from UCL’s manualisation of CBT for the IAPT project (IAPT, 2007; Roth & Pilling, 2008). While these frameworks might have some uses, it is difficult to understand the perception of the supremacy of this specific method for resolving difficulties in the field and promoting the profession, unless you actually want to bulldoze nuance and erase complexity in order to ‘clarify’ things. But BACP especially seems heavily invested in this approach, having already used it to create frameworks for a range of practice areas (including, it should be said, an IAPT-compliant, manualised version of PCT). Indeed, the organisation is so attached to the Roth & Pilling methodology that in a statement in Therapy Today, the Chief Professional Standards Officer and Chair of the SCoPEd Technical Group, Fiona Ballantine Dykes, claimed that the alternative to developing the SCoPEd framework is ‘doing nothing’ (Therapy Today, May 2019, p.51).

Given this single-minded, blinkered commitment to the competency framework process, it is hard not to conclude that person-centred perspectives – with their critical takes on both the manualisation of therapy and the associated alignment with healthcare values and medicalisation – are simply too awkward, too inconvenient, too damned political. As if a project like SCoPEd could not be political! As if, in its much-trumpeted spirit of collaboration between competing organisations, it could magically transcend all the history, politics, power struggles and diversity of thought and practice in order to objectively ‘map the competences’ of ‘counsellors’ and ‘psychotherapists’, without in the process distorting the field to shoehorn it into such a simplistic hierarchical structure.

I am not suggesting a deliberate conspiracy here, more that a number of professional interests converge around the adoption of these frameworks, whose politically expedient effect – in the apparent coherence of their efficiently organised categories and columns – is to eliminate awkward truths, not least in the profession’s sales pitch to governments and the NHS.

From this perspective, the SCoPEd project is so full of holes that, in one sense, it is hardly there at all. Part of me wonders whether, for all the fanfare and controversy, it will end up – like so many other documents – parked on our hard-drives or floating in the digital cloud, read more than once by almost no one outside of the organisational players, ignored by most of the public, of little interest to potential clients, perhaps skim-read by other stakeholders in the mental health field and then… what?

Well, it is how these things linger on the edges of awareness that says something about their potential power, about how – once installed – their unspoken values seep almost unnoticed into all sorts of areas of our lives as therapists (practice, training, supervision, organisational procedures, government policy). In person-centred terms, they begin to form a hard-to-grasp but nonetheless influential set of conditions of worth for therapeutic practice, which further externalise our professional loci of evaluation.

This is particularly problematic for PCT because, as I wrote in my own submission to the BACP consultation, the draft SCoPEd framework is alarmingly ignorant of person-centred working. Some of the exclusively ‘psychotherapist’ competences, for example, are almost the bread and butter of person-centred therapeutic relationships, which in the real world are often engaged with under the banner of ‘counselling’. Check out 3.5.c:

Ability to negotiate issues of power and authority experienced in the inner and outer world of the client or patient as part of the therapeutic process.

As I say in my response, for person-centred counsellors this would be a central principle of everything they do. Yet ‘qualified counsellors’ are deemed only to have the:

Ability to recognise and understand issues of power and how these may affect the therapeutic relationship.(3.5)

They are perceptive but passive witnesses to issues of power, which for me edges into an unethical disavowal of both the potential impact of their role and the asymmetry of the therapeutic encounter.

Read on and we find that only trained ‘psychotherapists’ have acquired the:

Ability to evidence reflexivity, self-awareness and the therapeutic use of self to work at depth in the therapeutic relationship and the therapeutic process.(5.1.c)

Which, again, is at the very heart of person-centred working (e.g. Mearns & Cooper, 2017). Yet ‘qualified counsellors’, we are led to believe, have only an:

Ability to demonstrate a commitment to personal development that includes self-awareness in relation to the client or patient to enhance therapeutic practice. (5.1)

Elsewhere, other competences make ‘psychotherapist’ the sole territory of those who lean heavily towards medical or psychoanalytic thinking, e.g. Ability to demonstrate the skills and critical awareness of unconscious process (3.10.b), which further alienates and excludes person-centred therapists.

Language barriers?

In response to the criticism attracted by the draft framework, BACP has suggested it will attempt to iron out some of these issues with language tweaks in future iterations, but such errors are extremely revealing of the way the unique theory and practice of PCT is invisible in the project, subsumed and submerged within generic statements around counselling practice while its more challenging perspectives have been redacted or just ignored into oblivion.

In any case, we should be wary of the reassurances from the SCoPEd teams that they just need to get the language right. For one thing, this smacks of PR rather than full engagement with the critiques (as in the infamous politician’s or corporate CEO’s defence, “I misspoke”). Furthermore, in this focus on language, BACP et al seem (wilfully?) to misunderstand the various challenges and objections, which are not only about words – as if swapping them with others would make it all better – but rather see language as the most obvious manifestation of deeper flaws in the project.

Something else I find troubling here is my own personal experience of having the same conversations with senior individuals at BACP about another competency framework, one drawn up for university and college counselling in 2016, which I had criticised as inappropriately redefining the sector as a branch of manualised healthcare (Rogers, 2019). In a face-to-face meeting and follow-up emails, it was acknowledged that BACP did not ‘get the language right’ and I was offered reassurances that this would be taken on board for future frameworks. Yet here we are again. I have no idea what the people I spoke with took away from our chat but somewhere in the subsequent organisational processes these reassurances evaporated into nothing and PCT once more finds itself ignored and excluded.

The person-centred approach, arguably, is not blameless in all this. Perhaps we have not been great at organising; perhaps we have felt so compelled to make concessions to the dominant narratives in ‘mental health’ and the therapy professions that we have our lost ourselves a little along the way, woozy with disorientation and gripped by a fear of judgement if we defy the trajectory of our own field. Nevertheless, the fact that a voice speaks with less assertiveness amid the noise of our culture’s deepening conversation with psychological distress is no excuse to ignore it, and it is troubling – and disturbingly ironic – when therapy organisations fall into this trap.

Perhaps my own tiny sketch of PCT’s political difficulties does it a disservice too. While I have drifted away from person-centred forums (journals, organisations, conferences etc.) over the years, social media – for all its flaws – has reminded me recently that there is a vibrant community of practitioners out there and PCT still has a unique and vital contribution to make to our field, to ‘mental health’ thinking generally and to our culture more widely. As ever, what the person-centred approach has to say is not always easy listening for those with professionalising aspirations and intentions, but surely it is our job as therapists to hear the things that others cannot bear, to listen to the most difficult truths, to welcome their complex, quietly spoken messages, to meet and fully engage with the challenges they present – why can’t our organisations do the same?

Tipping point

 As I researched the background to PCT’s early alignment with counselling and BACP (as discussed above), I stumbled across another passage in the same book (Mearns & Thorne, 2000) that, although written in my early days as a person-centred therapist twenty years ago, rings as true now as it did then:

‘It would be a tragedy… if person-centred therapists lost heart at this stage when, precisely because of some of the unfortunate moves towards a sterile professionalism… there is a greater thirst than ever among therapists and would-be clients for an engagement with what is truly human’ (p.218).

Whatever happens as SCoPEd ploughs on, we urgently need to find our voices. There are shifts in the mental health sector across disciplines and hierarchies. The medicalisation of distress, the dominance of biomedical psychiatry/pharmacology, the related mechanisation of therapy as another manualised treatment for discrete psychological ‘disorders’ and its subsequent co-option by the State in health and welfare policy are all coming under increasing pressure from a range of critical standpoints.

We may be at a tipping point. The more people experience this rigidly medicalised ideology in practice, the more they become aware of a need for something else and actively begin to seek it out. With IAPT’s legitimacy crumbling (Jackson & Rizq, 2019), the promises of psychopharmacology unfulfilled and psychiatric diagnosis itself falling further into disrepute, it is starting to look as if Person-Centred Therapy was on the right side of history all along.

Our professional organisations might want to listen more closely to what we have to say; not to assist their PR blitz around contentious projects, but to reset the course of the professions in ways that more authentically respect and promote the core values and diverse perspectives found in our field’s rich ecology of practitioners.


Andy Rogers has been a BACP member and counselling service coordinator in further and higher education for 20 years. He also works in private practice in Basingstoke, Hampshire.


References

IAPT (2007) The competences required to deliver effective cognitive and behavioural therapy for people with depression and with anxiety disorders. https://www.ucl.ac.uk/drupal/site_pals/sites/pals/files/migrated-files/Backround_CBT_document_-_Clinicians_version.pdf (accessed 05 July 2019).

Jackson, C & Rizq, R (2019) The Industrialisation of Care: Counselling, Psychotherapy and the Impact of IAPT. Monmouth: PCCS Books.

Mearns, D & Cooper, M (2017) Working at Relational Depth in Counselling and Psychotherapy. 2nd edition. London: Sage.

Mearns, D & Thorne, B (1988/2013) Person-Centred Counselling in Action. London: Sage.

Mearns, D & Thorne, B (2000) Person-Centred Therapy Today. London: Sage.

Rogers, A (2019) ‘Staying Afloat: Hope & Despair in the Age of IAPT’ (pp. 142-155) in Jackson, C & Rizq, R (2019) The Industrialisation of Care: Counselling, Psychotherapy and the Impact of IAPT. Monmouth: PCCS Books.

Rogers, C (1942) Counseling and Psychotherapy: Newer Concepts in Practice. Boston: Houghton Mifflin.

Roth, AD and Pilling, S (2008). ‘Using an evidence based methodology to identify the competences required to deliver effective cognitive and behavioural therapy for depression and anxiety disorders.’ Behavioural and Cognitive Psychotherapy, 36, pp. 129-147.

Thorne, B (1999) ‘Psychotherapy and counselling are indistinguishable’ (pp. 225-232) in Feltham, C. (1999) Controversies in Psychotherapy and Counselling. London: Sage.

 

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Joint letter to BACP, UKCP and BPC on the SCoPEd consultation results

In response to the SCoPEd initial consultation results, a joint letter to BACP, UKCP and BPC has been signed by the Alliance for Counselling and Psychotherapy, the National Counselling Society, Psychotherapists and Counsellors for Social Responsibility, the Psychotherapy and Counselling Union and the College of Psychoanalysts.


Dear Chairs and Chief Executives of BACP, UKCP and BPC,

The Alliance for Counselling and Psychotherapy, the National Counselling Society, Psychotherapists and Counsellors for Social Responsibility, the Psychotherapy and Counselling Union and the College of Psychoanalysts have noted your claims hailing the results of the recent consultation.

We have analysed the available statistics, and, on behalf of our combined memberships of well over 2,000 practitioners, nearly all of whom register with yourselves, respectfully beg to differ.

The results are hardly a ringing endorsement of the SCoPEd project (dramatically so, as far as BACP is concerned).

The return rates are assuredly below acceptable minima for the adoption of such wholesale change in any profession. We calculate that there is an overall return rate of the survey of around 13 per cent (7,087 respondents out of 53,500 members) – or about one in eight.

BACP’s return rate appears to be 13 per cent (5,878 respondents out of 44,000 members. (If the smaller register were used then the return rate will have been higher.)

BPC’s return rate appears to be 15 per cent (230 respondents out of 1,500 members).

And UKCP’s return rate appears to be 12 per cent (979 respondents out of 8,000 members).

Our organisations consider that it would be foolhardy to attempt to make such fundamental changes to the structure of our professions on the basis of the level of response garnered up to now. Don’t forget, it is you yourselves who have asserted that the changes will be fundamental, not only your critics. We will continue proactively to oppose any such developments.

Nor do the more detailed statistics offer you anything like the succour that you have claimed. Drilling down, we find that:

60 per cent of respondents did not believe SCoPEd would improve things for clients.

46 per cent did not believe it would help recruitment.

39 per cent did not believe it would make things clearer for trainees.

46 per cent did not believe it would help professional organisations to promote therapy.

Given that the leaderships of the three organisations so strongly supported the direction of travel of the project, these figures should make for depressing reading for you.

And among BACP members, the positive responses were even lower. Only 36 per cent of BACP respondents to the survey believe SCoPEd will make things easier for clients trying to find the right help (Question 1a). This is just 2,131 members, which is about 5 per cent of BACP’s total membership.

For comparison and to get these returns into some kind of proportion, this is 1,000 less than those, mainly but not all BACP members, who signed the petition to scrap the project.

It also contrasts fairly dramatically with the 57 per cent of BPC and 56 per cent of UKCP respondents who believe the framework would be positive for clients – an intriguing difference that is reflected throughout all the results, as laid out here.

On the question of how useful SCoPEd will be for employers (Q1b), 50 per cent of BACP respondents answered that it will be easier to establish who to employ, whereas 78 per cent of BPC and 71 per cent of UKCP respondents agreed.

On the effect on clarity for students choosing training pathways (Q1c), 57 per cent of BACP respondents were positive, compared with 84 per cent of BPC and 78 per cent of UKCP. Similarly, 50 per cent of BACP members answering the survey believed SCoPEd would make promotion of members’ skills by professional organisations easier (Q1d), whereas 75 per cent (BPC) and 73 per cent (UKCP) felt the same.

What are we to make of this? Is it surprising that organisations representing those identifying more often as ‘psychotherapists’ (and in BPC’s case, exclusively psychoanalytic psychotherapists), rather than ‘counsellors’, would favour a framework that places psychoanalytic psychotherapy at the top of a hierarchy of practice? We also note with as little cynicism as we can manage the close ties these organisations have with training programmes that would profit from such an assertion or reassertion of superiority.

Despite the deeply problematic nature of the consultation methodology, as shown in this article, and the lack of any real endorsement of the project in the results – not to mention the widespread dissatisfaction with the framework (particularly amongst ‘counsellors’ and especially the under-represented person-centred/experiential/existential/humanistic communities), as well as the substantive critiques of the political agendas and claimed ‘evidence base’ of the project – despite all this, BACP, BPC and UKCP assert nonetheless that, ‘we have an early indication that we should progress this work’.

Surely, if anything, a dispassionate viewpoint would be that there is an ‘early indication’ that the entire project is deeply flawed, and is pursuing a path that a substantial portion of the field finds at best misguided, and at worst a complete betrayal of their practices. In what sense, then, can this work be said to be happening ‘alongside our memberships’?

To progress the SCoPEd framework anywhere near ethically, it would mean reappraising every single aspect of it: its motivations and intentions, its assumptions, its methodology, its form, the composition of its ‘expert reference group’, the ‘independent’ chair, the disputed ‘evidence base’, the nature of further consultations, and so on.

Is there any will at all to do this within BACP, BPC and UKCP? The leaderships of your organisations may ‘acknowledge’ the ‘strength of feeling’ in the debates around ScoPEd, but how can they possibly continue with the project in this form, knowing the numerous substantive critiques of the project and its current functioning?

Perhaps the 3,000 consultation comments, as yet not analysed by the ‘independent research company’, hold some of the answers. Is it possible that all of these comments and all other relevant data beyond what you have released thus could be published on one of your websites? We are serious about this and consider it to be normal good practice for a consultation. Not to do so, or to refuse to release the comments, will leave you open to allegations of cooking the books.

In the meantime, the organisations sending this letter would welcome open dialogue, above all in a public format, with BACP, BPC and UKCP about the future of the therapy field.

Collegial greetings from,

The Alliance for Counselling and Psychotherapy

Psychotherapists and Counsellors for Social Responsibility

The Psychotherapy and Counselling Union

The College of Psychoanalysts

The National Counselling Society

 

19 March 2019: post amended to add the National Counselling Society to the letter signatories.

 

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SCoPEd Consultation: Methodologically Challenged

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Richard House Ph.D., former Senior Lecturer in Psychotherapy, Counselling and Psychology at the University of Roehampton, subjects the SCoPEd framework consultation exercise to critical analysis.


Introduction and Context

In this commentary I wish to deconstruct, and subject to critical analysis, the apparent methodology used by the psy sponsor organisations in their recent SCoPEd consultation process. In precipitating a process that could end up having major implications for the practice of many thousands of psy practitioners, organisations surely have a grave responsibility to ensure that, as far as possible, any research that is carried out is methodologically robust, and transparently fair and unbiased. In the case of the SCoPEd consultation, I will show below that this is, alas, very far from being the case – which, in turn, places substantial doubt on the reliability of the initial findings as recently announced.

A Fair Consultation?

The first observation to make about the consultation process is that the most important question of all wasn’t even posed – i.e. “Do you think that it is necessary and appropriate for the psy organisations to develop an explicit written framework for competent practice in the therapy field?”.

Rather, the need for a competency framework is merely asserted and assumed by “organisational fiat”, as a background given; and only then do respondents answer the questions posed, having already tacitly and implicitly agreed to the need for such a framework by the way the consultation has positioned them, and by the very act of them completing the consultation.

It should by no means be tacitly or casually assumed that everyone who completed the consultation necessarily agrees that such a framework is necessary; yet there is no mechanism within the consultation as implemented to discover this vital information. One has to ask whether this was an oversight, or a quite deliberate “positioning” by those conducting the process.

So one has to ask, further, why were members not asked, first and foremost, to give their view on whether a generic framework is necessary and appropriate? Although of course this has to be speculative, it might conceivably be because by doing this, it would then have been far more difficult to position members into accepting the principle of a framework per se without any debate. And as mentioned above, the very “democratic” act of completing the consultation can easily be read as giving tacit legitimacy to that which, at the outset, should have been open to discussion and possible refutation, rather than merely assumed as an uncontested datum.

Thus, a fair and proportionate consultation that was genuinely aiming to find out members’ views – as opposed to one merely seeking rubber-stamping legitimation for a pre-decided view – would have sent all potential respondents both the proposed framework and a document of equal length critiquing the need for a proposed framework. This would then have left members free to make up their own minds, “un-nudged”, with an accompanying, genuinely open-ended set of consultation questions.

As it is, a methodological “coach-and-horses” can be driven through this whole process, as anyone with any expertise in research methodology will know. (I can just imagine what a group of sharp, methodology-savvy Roehampton PsychD research students would have made of this! – and it wouldn’t have been pretty…)

It’s therefore extremely disappointing to this commentator, at least, that this consultation wasn’t far better informed methodologically. Moreover, this in turn is, at the very least, consistent with the suspicions of organisations like the Alliance for Counselling and Psychotherapy that this is yet another choreographed, top-down power move by our field’s psy organisations, still intent on importing the dead hand of state regulation into our work.

An “Independent” Research Company?

We read in the rubric from the organisational sponsors of “[t]he consultation exercise, which was run by an independent research company on behalf of BACP, the British Psychoanalytic Council (BPC) and the UK Council for Psychotherapy (UKCP), … [and that] … More than 3,000 members and stakeholders submitted a comment as part of the consultation process. These are currently being analysed by the independent research company for the key themes, which will be published in the summer.” (my emphasis)

The phrase “was run by” needs to be carefully interrogated and unpacked. It is indeed potentially reassuring to be told that the research company “running” the consultation process was “independent”; but such cosy reassurance is of no substance unless respondents are told in detail what the term “running” actually means in practice. For example, to have any methodological confidence in the consultation’s reported findings, the public needs to know what written remit the “independent research company” was given by the sponsoring organisations prior to the consultation exercise. This is critical, because it needs to be totally transparent to what extent the research company is, indeed, genuinely “independent” – e.g. merely in the sense that they carried out the data-collecting exercise, or in the sense that they themselves decided on the questions to be asked in it, and how those questions were framed.

Moreover, regarding the analysis of the comments received, we also need to know what, if any, guidance was given to the “independent” company by the sponsoring organisations, in terms of how the company analyses and presents the qualitative findings. If this information is not completely transparent, respondents will have no way of knowing whether the presentation of the results is a fair and representative depiction of the actual feedback which respondents gave in their thousands.

The Questions Themselves

Regarding the actual questions posed in the consultation procedure: first, respondents were asked, “Q1a – How will the framework affect clients or patients being able to find the right kind of help to meet their needs?” (my italics).

First, note that the tell-tale word “will” is used here, rather than “would”. If this were a genuinely open-minded consultation that hadn’t already pre-decided the desired outcome, the word “will” would most certainly not have been used in this question. Rather, the hypothetical “would” should and would have been used.

This is by no means a minor, semantics-oriented issue – for the way these questions are worded will have a major impact in creating the background “mood-music” to ease the driving through of any required institutional agenda. Those composing the wording of these survey questions will have been well aware of this (and if the sponsoring organisations weren’t, for any reason, then any reputable “research company” worth its salt certainly would have been).

In my view, and strictly speaking, respondents who were expecting a fair and open consultation which was not already positioning them by the way the questions were posed should have refused to answer this question. A much fairer and objective wording for this question would have been something like the following:

Q1aWould a framework like the one suggested have any impact, negative or positive, on clients/patients being able to find the right kind of help to meet their needs; and if so, how?”.

The key point here is that such a question might well have yielded significantly different results from the question that was actually posed (on which, see below).

Indeed, all four consultation questions commit this elementary methodological error in using the weasel word “will”. So, in relation to question 1b, a fair, more objective wording would have been as follows:

Q1b – Would a framework like the one suggested have any effect, negative or positive, on employers being able to establish which counsellors and psychotherapists to employ in their service; and if so, how?”

And for question 1c:

“Q1c – Would a framework like the one suggested have any effect, negative or positive, on trainees in their understanding of the pathways open to them for core training with adults; and if so, what and how?”

And finally for 1d:

“Q1d – Would a framework like the one suggested have any effect on professional bodies being able to promote the skills and services of their members; and if so, how?”

If the employed research company wished to test the reliability of the first reported consultation results, they could quite easily carry out a much smaller survey of practitioners who did not complete the first survey, using these alternatively worded questions. The results of such a survey would then provide clear evidence on the extent to which the original survey results are reliable and representative, or otherwise. Without doing such a follow-up, the reliability of the original survey results must remain in question.

Finally, regarding the raw presented statistical results, it’s clear that even when we ignore the multiple biasing effects of the way in which the whole consultation process was conducted (referred to in detail above), around 25 per cent of respondents – a considerable minority – were not happy with the proposed framework. If I were one of the psy organisations wishing to see this framework implemented, I certainly wouldn’t be feeling at all triumphant about these initial results.

In Conclusion

I have raised a number of core methodological issues in this commentary, and I ask the sponsoring organisations to reply to the concerns I have raised here in adequate detail.

If there is no full response, the silence will be deafening, and the many thousands of concerned practitioners will no doubt reach their own conclusions.

 

Dr Richard House, C.Psychol., AFBPsS, Cert.Couns.

Former Senior Lecturer in Psychotherapy, Counselling and Psychology, University of Roehampton; former PsychD research supervisor; former counsellor and psychotherapist in General Practice (1990–2007); author of Therapy Beyond Modernity (2003) and co-editor (with Del Loewenthal) of Against and For CBT (2008).

richardahouse@hotmail.com

 

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SCoPEd: Butchering Psychopractice

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


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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.

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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.

 

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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

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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’.

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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.

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