The state regulation of counselling and psychotherapy: sometime, never…?

Richard House

Magdalen Medical Practice, Lawson Road, Norwich NR3 4LF, UK

‘The institution… exercises a form of seduction by comforting [us] with its common aims, absorbing [us] with the mechanisms of its orientation towards official roles, and tempting us to relinquish [our] own free, unique individuality… The future of… humanity depends upon this: will each person learn to form institutions into instruments for the unfolding of human individuality, or will the outer power of institutions be regarded as so impressive… that people consider them more important than the human being himself, than his physical, soul and spiritual evolution?’
Pietro Archiati

‘What is most tangible has the least meaning, and it is perverse then to identify the tangible with the real.’ 
Michael Polanyi

Introduction: Professionalisation Beyond Modernity?

‘Under postmodern conditions, persons exist in a state of continuous construction and reconstruction; it is a world where anything goes that can be negotiated. Each reality of self gives way to a reflexive questioning of irony, and ultimately the playful probing of yet another reality. The center fails to hold.’
Kenneth Gergen

Since the early 1990s, a number of concerned practitioner-writers, myself included, have been engaging in the literature of our field with multiple arguments that challenge what seems to be an increasing and uncritically embraced orthodoxy about institutional professionalisation and the state regulation of therapy practice (e.g. Mowbray 1995; House and Totton 1997; Oakley 1998; Bates and House 2003; House 2003). On being asked to pen another contribution on this issue, I struggle with apparently contradictory feelings – eagerness to engage once again in an argument which I feel so passionately about, on the one hand, and on the other, a certain weariness that it is still necessary so to engage in arguments which, in my perception, those challenging the alleged beneficence of institutional professionalisation have decisively won. While revisiting in what follows several of the more familiar arguments in this debate, I will also attempt to raise the discussion to embrace a more overarching framework about the place of therapy in the evolution of consciousness, which approach can lead to all manner of surprising conclusions - not least, that it may actually somehow be necessary for us ‘obediently’ to ‘jump through’ the state regulation hoop in order to discover experientially just how irrelevant its accompanying ideology is to the goal of achieving excellence in the field of therapeutic help. But more of that later.

Association with the Academy?

Perhaps the most notable development in the therapy field of the past decade or so, and one which has gone hand in hand with the ideology of statutory regulation, has been the ‘academicisation’ of therapy training, with its now almost universal embeddedness in the university sector of higher education. Yet in the ‘modern(ist)’ university, and as van Houten (1999: 7) has argued, there is a palpable trend towards premature specialisation and self-contained, competitive faculties and departments showing ‘little sign of the kind of general education of the human being that would further our culture’, and with ‘students’ independent judgement decreasing’. Relatedly, the direction of higher-educational teaching, assessment and accreditation is also moving in a regressive direction – with ‘an academy increasingly saturated by an ethos of measurement, calculation, commodification and control of teaching, research and thought’ (Kilroy et al. 2004: 2). 

Not that the world of higher education was always thus. In the early nineteenth century, universities were autonomous cultural institutions whose role was to provide social critique, independent of the State, and with knowledge being pursued for its own sake rather than being deliberately geared to utilitarian ends. In stark contrast, what we now see in what is sometimes referred to as the ‘New Public Management’ and the ‘New Managerialism’ is knowledge being ‘commodified so as to make it a useful product of pre-ordained and pre-conceived… directives and scientific outcomes not necessarily for the sake of science, truth or knowledge’ (Trifonas 2004: 39). Lynn Fendler (1998: 57) is very eloquent about these issues:

‘Now there is a reversal; the goals and outcomes are being stipulated at the outset, and the procedures are being developed post hoc. The “nature” of the educated subject is stipulated in advance, based on objective criteria, usually statistical analysis. Because the outcome drives the procedure (rather than vice versa), there is no longer the theoretical possibility of unexpected results; there is no longer the theoretical possibility of becoming unique in the process of becoming educated… In this new system, evaluation of educational policy reform is limited to an evaluation of the degree to which any given procedure yields the predetermined results…’ (my emphasis)

In this way, then, the ‘modern’ university (or better, perhaps, the university cast in the image of modernity) is actually and disconcertingly moving ever further towards a stultifying and anxiety-inculcating culture of ‘surveillance’ and bureaucratic control holding increasing sway in the Academy. What we are witnessing around the Western world more generally is an economy-driven ‘neo-liberal’ colonisation of secondary and tertiary education, far removed indeed from an education system arising (as educationalist Rudolf Steiner put it) ‘purely from cultural needs’. Commentators are increasingly issuing grave cautions about today’s toxic educational climate, with its obsession with audit, accreditation and ‘manic’ accountability. Andrew Cooper (2001: passim) has well summarised the nature of the ‘audit culture’:

‘We now live in a relentlessly superintended world, a quangoed regime of commissioners, inspectors, and regulators… [quoting Peter Preston], [and] important questions of truth, meaning and authenticity are sacrificed on the altar of compulsive reassurance of the critical superintendent… Fundamental principles about freedom, autonomy and citizenship are threatened by this state of affairs… Obsessional activity… is essentially about control rather than creativity… These systems may be contributing to a deterioration of standards, while maintaining a pretence that they are achieving the opposite.’ 

I cannot emphasise too strongly that there are very considerable dangers indeed in counselling and psychotherapy training and practice engaging with this pernicious Zeitgeist – one which is arguably quite antithetical to the core values of therapeutic work at its best. In the fields of psychotherapy and counselling, of course, the issues of accreditation, state regulation and the ‘professionalisation’ process more generally have played an escalating role since the early 1990s. In the field’s professional journals I and others have repeatedly challenged the gravely debilitating effects upon therapy practice that soulless, ‘didactic professionalisation’ entails. I maintain that therapy practice requires what might be termed a ‘post-professional’ enabling framework that encourages, as fundamental prerequisites, innovation, pluralism, diversity and self-regulation - progressive values which are faithfully embodied, for example, in the practice of progressive ‘formative assessment’ approaches within higher education. It is, not least, delicate, subtle soul-qualities which give therapy practice at its best its uniquely distinctive characteristics – features that a one-sidedly materialistic ‘modernity’ with its regulation- and credential-mindedness is arguably placing under great threat, as an ‘over-professionalised’ psychotherapy and counselling practice (House, 2003) uncritically threatens to embrace these pernicious cultural forces. 

There are certainly very considerable concerns about the currently fashionable ‘audit society’ and its accompanying dynamics and ideology (e.g. Power 1997; Strathern 2000; Cooper, op. cit.; Parallax 2004). In ‘credentialisation’, for example, there is a grave danger of intrinsic distortion, not merely because a one-off qualification can never capture the complexities and subtleties of excellence in therapeutic help, but because the qualification itself so easily becomes more important than the qualities it is purported to measure and guarantee. In such circumstances it is quite natural for trainees and practitioners to focus all or most of their energies on  getting the diploma or achieving the accreditation status, while the far more subtle and complex issues of true quality in therapeutic help can be compromised or even lost. Moreover, as with all technocratic intrusions into human systems, such a regime commonly leads to quite unpredictable side-effects which commonly do more net harm than do the quality guarantees they are supposed to effect – a point made forcefully and convincingly by Richard Mowbray in his seminal book The Case Against Psychotherapy Registration (1995).

Accreditation, ‘credentialisation’ and statutory regulation are further dimensions of the ‘audit and control’ culture. Lee Harvey (2004: 207), referring specifically to ‘the power of accreditation’ in the British university sector, argues that 

‘Accreditation processes… are not benign or apolitical but represent a power struggle that impinges on academic freedom, while imposing an extensive bureaucratic burden... Accreditation can also act as a restraint on innovation and run counter to pedagogic improvement processes… - represent[ing] a shift of power from educators to bureaucrats.’ 

Crassly ‘positivistic’ and ‘technocratic’ conceptions of assessment – what Kilroy et al. (2004: 1) refer to as ‘the reduction of (qualitative) thought to (quantitative) product, (critical) education to (utilitarian) skill-set’ – certainly constitute a singularly inappropriate means of evaluating efficacy or competency in the range of human endeavours in which they are being uncritically applied – and perhaps most of all, in the field of therapeutic help. What our field should surely be embracing is the most radical thinking in relevant and associated fields, rather than simply mimicking the worst features of the ‘surveillance culture’. Thus, for example, Paul Gibbs and Panayiotis Angelides (2004) have recently considered the nature of experiential learning and its relationship with other forms of learning that gain their authority through assessment. They argue that experiential learning is the proper goal of an educated populace - an argument that sees wisdom as the goal of education, wisdom which is revealed in becoming wise through being-in-the-world. To consider a person in this way is not to accredit or ‘credentialise’ her ‘by separating her self-knowledge from her in some externality, but to recognise her as being knowledgeable and wise rather than having knowledge’ (ibid.: 333). They maintain, further, that ‘higher education ought not enframe students through assessment practices but liberate them in a mode of learning that reflects Heidegger's notion of “letting learn”’ (ibid.).

Another recent example of best radical thinking is a paper that echoes many of my own concerns about therapy’s constraining and normalising ‘regime of truth’, and the ways in which it can perpetrate far more net abuse than the more overt abuses against which statutory regulation aspires to legislate (House 2003). Damien Riggs (2005) thus addresses some of the ways in which psychological constructs, which have been traditionally positioned as intra-psychic phenomena, may be more productively understood as local performances of intelligible 'healthy subject positions'. Focusing on the cultural location of psychological epistemologies, and the assumptions of Eurocentric universality that shape them, Riggs explores the ways in which individualistic notions of 'personality traits' enact a form of ‘governmentality’ over subjects who are expected to inhabit specific, fixed subject positions. Thus, for example, traditional research on locus of control can be seen as self-fulfillingly instantiating the very subject positions that it seeks to measure. Riggs draws upon experience as a methodological tool to examine some of the ways in which neo-liberal discourses of control work to homogenize the broad range of experiences that construct intelligible subject positions. The relevance of these concerns to therapy practice will be self-evident.

Those aspects of human experience which are most important in, for example, learning and human development, are arguably inherently and in principle unquantifiable – i.e. factors like existential aliveness, the quest for personal identity, spiritual well-being, the enhanced meaningfulness of lived experience, and the experience of loving and being loved. What I am offering here, then, is a trenchant and spirited defence of the subtle, and of the intangible, and of what is inherently qualitative in human experience, against the blunt, bludgeoning juggernaut of ‘modernity’ and soulless materialism in all its manifestations. It follows that technique-oriented approaches of ‘empirically-based’ evaluation and accreditation may well largely or completely miss the point in their attempts ‘objectively’ to measure competency outcomes in terms of quantifiably measurable, sense-tangible variables – an issue to which I return later.

As soon as we admit these kinds of arguments, then it immediately follows that there must be profound concerns about any approach to professionalisation that seeks to legislate upon and effectively exclude certain routes to practitionership in the therapy realm – for as Gladstone (1997) has convincingly shown, there are many and diverse routes to effective practitionership, not least the much-neglected ‘apprenticeship’ model, and the ‘life experience’ path to excellence in therapeutic helping.

Moreover, it has never been convincingly demonstrated either that there is a significant problem of abuse within therapy work that is more prevalent than occurs within the other statutorily regulated professions, or that the institutionalised ‘regime of truth’ into which ‘professionalised’ therapy can so easily degenerate (House 2003) is not far more abusive than are the alleged abuses against which the professionalisers so assiduously seek to legislate. In such a situation, the very least that can surely be said is that the onus is upon those who would professionalise and statutorily regulate the therapy field to demonstrate both empirically and logically just why such intervention is justified. And in the absence of any such attempt, it is very difficult not to conclude that the drive towards statutory regulation is far more to do with professional and institutional vested interest than it has to do with a genuine concern to generate a net improvement in the overall quality of available therapeutic help. 

It is also worth noting that there is no attempt whatsoever to locate the desire for state regulation within the overarching cultural-political context or within the evolution of human consciousness more generally. I refer to the latter issue elsewhere in this article; and in the former case, not only has the audit and ‘surveillance culture’ of the New Public Managerialism (of which state regulation is just a recent instance) come under convincing critique from a number of sources (see earlier), but as Krejsler (2005: 353) has recently pointed out, the ‘protection of the public’ argument routinely invoked by the professionalisers completely fails to take account of clients’ own increasing sense of individualisation and responsibility-taking. On similar lines, in the realm of ethics according to the world-view of Rudolf Steiner, we find the anthroposophical view that ‘all morality in the future must be individual, and… we have to reach our own individual ethic through out own free spiritual activity’ (Easton 1982: 313).

There are associated questions about the ‘academicisation’ of virtually all counselling and psychotherapy trainings (House 2001a,b; Parker, 2001). For the reasons outlined earlier, I have major concerns about therapy training developing largely exclusive associations with the Academy. Universities are, understandably and appropriately, sites of intellectual and academic excellence (though ironically, even these values may be under threat from the ‘New Managerialism’ and its audit culture); and the internal standards of the universities are almost exclusively informed by those values. Yet many if not most therapy schools and approaches - quite appropriately, I believe - place at least as much emphasis upon emotional intelligence and being-values than they do upon cognitive and academic intelligence, and there are therefore considerable dangers in associating the soul-subtle work of therapeutic help with the university sector. 

In the therapy world, some have remarked upon how seductively attractive it can be to be associated with the Academy - and even that the prime motivation for such association sometimes seems to be that of seeking a kind of ‘kudos-by-association’ with the academic world, which is in turn far more to do with appearance than with substance. Certainly, the ‘audit society’, and its arguably pathological preoccupation with how things look rather how they actually are, is a culturally damaging phenomenon which the therapy world must surely be extremely wary of embracing. 

Almost a decade ago, a thought-provoking article by journalist Melanie Phillips (1996: 5) focused on our current ‘national obsession with university degrees’, and the concomitant neglect of vocational training – and the relevance to therapy training should be immediately apparent. Phillips first bemoaned a discernible cultural shift towards favouring the socio-professional status of a university degree over the craft-based values of vocational learning, training and, above all, experiential learning through an apprenticeship approach – with ‘degrees [being] increasingly substituted for essential craft or skills training on the job’, and people ‘being funnelled towards qualifications which mask their vocational deficiencies by increased social status’ (ibid.). Moreover, she maintained, ‘the drive for “professionalisation” means that the craft base is replaced by abstract theorising’ (ibid.). These are major concerns indeed for therapy training – a vocation or ‘calling’ whose parameters and practices by far transcend the abstract theorising or narrowly conceived academic learning that commonly dominate the Academy.

Citing the case of nursing, Phillips continues: ‘The trend towards degree-based training equips nurses to be managers and bureaucrats, while on the wards rolled-up sleeves nursing care leaves much to be desired.’ (ibid.) Similarly, we can argue that while degree-based training will no doubt give students extensive theoretical understanding of how to work therapeutically, whether such ‘objective’ knowledge has anything like a decisive, or even a significant, influence upon practitioner competence is at the very least open to significant question. Indeed, it is at least as plausible to argue that the kind of overly-academic, over-theoretical approach to training which an association with mainstream universities entails is likely to detract from the kind of ‘being values’ and inner soul development that necessarily lie at the heart of therapeutic help at its best. 

As a strong matter of principle, therefore, I favour pluralism and a ‘freedom of diversity’ in practitioner development, and I would be very concerned at any regulatory move that could impinge upon the creativity and innovative thinking that surely lie at the heart of our work, and are arguably a necessary pre-requisite for nurturing what I like to call a ‘living art’ of therapeutic help. 

In sum, I maintain that the becoming of a therapist is more appropriately seen as a craft that is learnt experientially and artistically, and through practice-related experience, than as a quasi-medical, quasi-scientific knowledge-based profession which increasingly privileges theory over practice, didactic assessment over self and peer validation and empowerment… - in short, head over heart. There is surely a fundamental and irresolvable tension in any approach to training which attempts to fit what is a quintessentially experiential, artistic and subjective experience into the objectifying academic framework of university education. Indeed, a profound concern is that the only way in which this process can ‘successfully’ be effected – and especially in the current climate of audit, surveillance and manic accountability - is through ‘mechanising’ what is a deeply individual, subjective and human(e) undertaking. As Rudolf Steiner once said, ‘If… mechanical thinking is carried into education,… there is no longer any natural gift for approaching the child himself’ – and the words ‘therapy’ and ‘client’ could easily be substituted for ‘education’ and ‘child’, respectively, in this telling quotation. 

Medical-model professionalisation?

There is also a grave danger that regulation via the Health Professions Council – the form of state regulation currently being pursued - will necessarily entail a medical-model focus which is quite antithetical to the broad swathe of therapeutic approaches (with the not insignificant exception of cognitive-behavioural approaches). The recent cautionary experience from the USA should give long pause for thought, for as Bryceland and Stam (2005) have pointed out, American codes of ethics have begun to refer to preferences that therapeutic interventions be ‘empirically supported’. Yet the movement towards such Empirically Supported Treatments (ESTs) is based on a medical model of intervention using randomized controlled trials as the prime methodology, presuming standardised, ‘objective’ procedures that demonstrate interventions in an unambiguous manner. As the authors point out, many alternative therapy practices 

‘are at risk of being considered unethical within this framework because their practitioners are unlikely to conduct the kind of outcome research that is considered necessary to demonstrate efficacy…The move toward placing ESTs within codes of ethics is premised on limited conceptions of therapy that, we argue, fail to grasp the moral nature of the therapeutic relationship’ (ibid.: 131).

Moreover, the important work of John Heron (1996) convincingly shows that the positivist methodological approach of the clinical trial methodology (CTM) is fundamentally flawed in a research context in which, for example, its statistical methodology hides, through the comparison of means, what actually happens to individuals in the trial – meaning, for example, that there may easily be some people in both groups who are worse off after treatment. CTM therefore ignores the different responses of different individuals to the same treatment, so that, as Heron has argued, ‘[CTM] cannot help with the everyday question, “What is the treatment of choice for this individual patient?”’ (1996: 198) (for a fuller discussion of the inadequacy of the CTM methodology, see House 2005; and for a recent discussion of more critical and imaginative approaches to methodology in psychology, see Yanchar et al. 2005).

Some recent counter-cultural developments

There are a number of counter-cultural activities that give the lie to the assertion that there is no alternative to statutory registration as a means of professional development and accountability. Last November (2004), for example, the Independent Practitioners Network (IPN) celebrated its 10th anniversary of providing an alternative form of accountability to mainstream psychotherapy professionalisation. The anniversary was recognised in Autumn 2004 with several special regional ‘gatherings’, and in a special theme issue of the humanistic psychology journal Self and Society (2004) which featured a number of articles about the IPN. Recent years have seen a period of consolidation for IPN, with the building of what aims to be an exemplary form of ‘psychopractice’ accountability - coupled with a vigorous and well-informed critique of the false promises of the institutional professionalisation of counselling and psychotherapy. 

Not least, there has been an increasing awareness of the importance of how mainstream psychopractice institutions manage power relations - and the extent to which this is congruent with practitioners’ claimed approach to working with people. Too often, it is argued, it would seem that there is little or no such congruence – which in turn leads to wider questions about just why and how it has come about that so many practitioners seem to have uncritically (or is it unwittingly?) ‘bought into’ these values – the values of (late) modernity, as I term them in my book Therapy Beyond Modernity (House 2003).

Like many counter-cultural innovations, the IPN still inhabits the margins of British psychopractice, beneath the radar of the mainstream – though it has recently been recognised by, and is taking part in, the ‘mapping’ exercise being conducted by the UKCP and the BACP preparatory to the mooted introduction of some form of state regulation in some years’ time. What the IPN aspires to is a living demonstration of what ethically sound accountability necessarily looks like - face to face contact; responsible and rigorous peer and self assessment; standing by others’ work on the basis of knowing them personally; holding congruence between practitioners' working style and IPN's institutional style….  (e.g. Totton 1997; ‘Ipnosis’ website).

In the psychoanalytic field, there are also moves afoot that question current institutional professionalising developments. The College of Psychoanalysts UK (www.psychoanalysts.org.uk) is organising an International Conference (31st March to 1st April 2006) at the London School of Economics, on the theme of ‘Psychoanalysis and State Regulation’. The conference circular states that: 

‘The drive to state regulation has powerful implications for psychoanalytic ethics, academic thought and the space for speech outside the domain of psychiatric control.  By addressing the historically-contested relationship between psychoanalysis and the state, the implications of regulation will be explored through the psychoanalytic understanding of identity, ethics and adaptation; it will focus on theoretical and practical issues that concern the development of psychoanalysis as clinical work, social theory, and the politics of personal life.’

The College of Psychoanalysts UK has also produced a statement about some of the anticipated problems of the current proposals for state regulation (which can be accessed from the Latest News page) on the College website at www.psychoanalysts.org.uk – where we read, for example, that ‘many psychoanalytic practitioners have  serious reservations about regulation of psychoanalysis under HPC [the Health Professions Council]. …The College is  gravely concerned about whether the present proposals would be in the interests of [clients or practitioners]’.

Moves are also afoot to carry out a statistically representative survey of therapy and counselling practitioners in the UK, in order to ascertain  whether there really is any broad acquiescence amongst practitioners themselves to the institutional drive towards state regulation. Those who wish to keep themselves abreast of the most recent developments in the regulation saga can visit Denis Postle’s regularly updated ‘Ipnosis’ website or read the independent practitioners’ journal Ipnosis. 

Some writers are even questioning what is claimed to be a one-sided, overly ‘psychologising’ approach to subjective distress – which in turn holds grave implications for the attempt to cement in place an institutionally driven state regulation of therapeutic help. A case in point is the recent book by Servan-Schreiber (2004), Healing without Freud or Prozac, which confirms the suspicion that a momentous paradigm shift in our notions of health, illness and healing may well be underway, with the increasing identification of direct physical influences on subjective experience. In turn, it increasingly looks as if the kind of narrow ‘psychologisation’ of human suffering that the psychological therapies at their worst propagate will, in time, become as outmoded as is the psychiatry profession’s narrow medicalisation of human distress. If this analysis is anything like correct, then it may soon be simply unethical for psychotherapists and counsellors to practise without acquainting themselves with this emerging literature, and incorporating its findings into their work. Those who would wish statutorily to professionalise and make a culturally sanctioned ‘institution’ of psychotherapy and counselling should surely think long and hard before they pursue an avenue which would likely place a limiting fetter upon the healthy development of humankind’s evolving understanding of illness and healing in all its manifold complexity and subtlety. 

There are indeed signs of an (as yet unwitting) coalescence of this latter stream with an approach to ‘psychology’ that is emerging from the anthroposophically informed approach to consciousness evolution. In the newly emerging ‘spiritualised psychology’ of Robert Sardello (e.g. 1990, 1999, 2001), for example, we find new ways of grappling with the perennial problems and challenges of evolving human consciousness, and which materialistic positivist psychology has arguably long since relinquished pretty much any purchase upon. In the late 1980s, Sardello elected to leave his erstwhile profession, psychotherapy, for the principled reason that its practices were quite irrelevant to, and a distraction from, what really matters in human development. Certainly, Sardello’s kind of radical, spiritually informed thinking about human emotion promises to revolutionise the way we think about – and ‘treat’ – emotional disturbance and subjective experience; and once these ideas are taken on board, as I believe they eventually will be, then our therapy practices – and their professionalising accoutrements - can and will surely never be the same again. 

Finally, returning to the state of regulation in the UK, Denis Postle’s ‘Ipnosis’ website contains a recent posting (Autumn 2005) which seems to question the alleged inevitability of the state registration bandwagon. Specifically, an IPN participant (unattributed) posted the following message from Brian Magee, Chief Executive of COSCA:

‘Regulation of Counselling and Psychotherapy
Recently I attended a meeting in London of the UK Government's Department of Health's Project concerned with the statutory regulation of counselling and psychotherapy… The Liaison Group has now completed its extensive and challenging work of mapping the training in counselling/psychotherapy, the analysis of the ethical codes of the participating professional bodies, and a study of the functions of counsellors and psychotherapists. In the course of carrying out the above work, there have been increasing doubts cast by the Liaison Group on whether counselling/psychotherapy should be regulated by the Health Professions Council (HPC). One of the main reasons for this is that the above work showed that most professional bodies already have higher standards for counsellors/psychotherapists compared to those that the HPC would apply.

If the mood of the last London meeting was anything to go by, there now seems to be a shift in thinking not only away from HPC as the regulator, but also away from statutory regulation itself and a return to focusing on working together as professional bodies on self-regulating the activities of counsellors and psychotherapists. Depending on the UK Government's response to the above report, this shift may or may not be developed further.’
Brian Magee, Chief Executive (COSCA)   (July 2005)

And in the latest issue of Ipnosis, we read that, according to the BACP Chief Executive Laurie Clarke, regulation is now unlikely to happen before 2011 at the earliest (Anon 2005: 28).

By way of brief conclusion

‘What options are available to us for transgressing the property boundaries of professional knowledges?’
Michael White

One of my favourite quotations from the critical literature on accreditation in the therapy world comes from Richard Mowbray and Juliana Brown, who wrote in the early 1990s that ‘Where there is a genuine need for structures, we should develop structures that foster our values rather than betray them’ (Mowbray 1995: 225). 

I believe it is essential that the therapy world does not (wittingly or otherwise) expediently collude with pernicious cultural forces (the ‘audit culture’), the embracing of which would surely do a kind of ‘soul-violence’ to our work in all its subtlety and spiritual integrity. Concomitantly, my overriding concern is that counselling and psychotherapy practice should seek to create approaches to accountability and quality enhancement which are entirely consistent with the core values and philosophy of our work in its manifold dimensions; and, concomitantly, that we must be extremely careful not to become preoccupied with appearance, and what will expediently ‘look good’ to political forces or superficial ‘consumer’ sensibilities in modern culture which are driven by values that are quite antithetical to all that we passionately believe in. 

Further, I believe it is crucial that training is not limited to association with the modern, audit-obsessed university sector – not only because of major concerns about the over-academic, unbalanced nature of evaluation that understandably dominates those institutions, but because it is through honouring the values of pluralism and diversity in training delivery that we are most likely to witness the creation of the rich panorama of therapeutic help in which Britain has a long and proud tradition, and which our culture most surely needs in these deeply troubled times.

I would like to echo the plea made by Denis Postle on his ‘Ipnosis’ website, as a call to action to all concerned practitioners about the organised momentum towards state regulation:

‘If you feel that these moves towards statutory regulation are mistaken, discriminatory, and bad news for clients' interests — what to do? If you are unhappy about your organization's participation, write to the chair and ask them to justify their actions. Write to your MP and set out your objections, You'll find some headlines of what other people have felt ready to say . There is a listing of MPs names and constituencies  Write to <MP name> House of Commons London SW1A OAA.’

Finally, and somewhat provocatively, rather than being preoccupied with the minutiae of regulation, and whether or not it will help the therapy field in the net sense, I am increasingly thinking that it is much more useful to attempt to locate the therapy phenomenon within the wider evolution of human consciousness in which we are all caught up. Many of the more pernicious tendencies of a one-sidedly technocratic modernity – e.g. control-freakery and associated techniques of surveillance and domination, valuing speed and quantity over quality, the rampant commodification of just about everything, the paranoia-inducing but futile drive to neutralise risk and guarantee security, the entrancing and depowering effects of televisual technology, and, in our own field, the standardising coercion of regulation and the infantilising ‘nannying’ that is ‘Continuing Professional Development’, and the professionalising surveillance culture of which both are an instance….  all – and more - of these disquieting cultural developments are plausibly and convincingly explicable within the ‘consciousness soul’, consciousness-evolutionary framework of Rudolf Steiner’s Anthroposophy (e.g. Steiner 1966; Easton 1982).

If we fully and openly engage with such a path, I believe that before too long, the relevance of state regulation will quite evidently just fall away as an irrelevant cultural footnote in history. Only time will tell whether, in this evolutionary process, we might somehow need to go through the state-regulation hoop in order experientially to transcend the kind of limited and limiting consciousness that drives that very process. And it is important that those of us who are trenchantly against statutory and state regulation and institutional professionalisation be open to that (for us) very radical possibility.

References

Anon (2005) ‘New 2011 estimate for statutory regulation’, Ipnosis, 19 (Autumn): 28
Bates, Y. and House, R. (eds) (2003) Ethically Challenged Professions: Enabling Innovation and Diversity in Psychotherapy and Counselling, PCCS Books, Ross-on-Wye
Bryceland, C. and Stam, H.J. (2005) ‘Empirical validation and professional codes of ethics: description or prescription?, Journal of Constructivist Psychology, 18 (2): 131-55
Cooper, A. (2001) ‘The state of mind we’re in: social anxiety, governance and the audit society’, Psychoanalytic Studies, 3 (3-4): 349-62 
Easton, S. C. (1982) Man and World in the Light of Anthroposophy, 2nd edn, Anthroposophic Press, Spring valley, NY
Fendler, L. (1998) ‘What is it impossible to think? A genealogy of the educated subject’, in T.S. Popkewitz and M. Brennan (eds), Foucault’s Challenge: Discourse, Knowledge and Power in Education, Teachers College Press, Columbia University, New York   
Gibbs, P.  and Angelides, P. (2004) ‘Accreditation of knowledge as being-in-the-world’, Journal of Education and Work, 17 (3): 333-46
Gladstone, G. (1997) ‘The making of a therapist and the corruption of the training matket’, in House and Totton (eds), Implausible Professions, PCCS Books, Ross-on-Wye, pp. 171-85
Harvey, L. (2004) ‘The power of accreditation: views of academics’, Journal of Higher Education Policy and Management, 26 (2): 207-23   
Heron, J. (1996) Co-operative Inquiry: Research into the Human Condition, Sage, London
Hogan, D.B. (1979) The Regulation of Psychotherapists, 4 volumes, Ballinger, Cambridge, Mass.
Hogan, D.B. (2003) ‘Professional regulation as facilitation, not control: implications for an open system of registration versus restrictive licensure’, in Bates and House (eds), Ethically Challenged Professions, PCCS Books, Ross-on-Wye, pp. 160-71
House, R. and Totton, N. (eds) (1997) Implausible Professions: Arguments for Pluralism and Autonomy in Psychotherapy and Counselling, PCCS Books, Ross-on-Wye
House, R. (2000) ‘Stress, surveillance and modernity: the “modernising” assault on our education system’, Education Now: News and Review, 30 (Winter),  Feature Supplement
House, R. (2001a) ‘Psychotherapy professionalization: the post-graduate dimension and the legitimacy of statutory regulation’, British Journal of Psychotherapy, 17 (3): 382-90
House, R. (2001b) ‘What is so bad about the academicization of training? – a response to Frans Lohman’, Universities Psychotherapy and Counselling Association Newsletter, 7: 12-13
House, R. (2003) Therapy Beyond Modernity: Deconstructing and Transcending Profession-Centred Therapy, Karnac Books, London
House, R. (2005) ‘A positive excess?’ – review article Scott O. Lilienfeld, Steven Jay Lynn and Jeffrey M. Lohr (eds), Science and Pseudoscience in Clinical Psychology (Guilford Press, New York and London, 2003), Network Review, 88 (Summer): 54-6
Ipnosismagazine (edited by Paula Bentley and Yvonne Bates),  c/o The Alexander Group, PO Box 19, Llandysul, Ceredigion SA44 4YE, UK
‘Ipnosis’ website (compiled by Denis Postle) - 
Kilroy, P., Bailey, R. and Chare, N. (2004) ‘Editorial sounding: auditing culture’, Parallax, Issue 31 10 (2) (April-June): 1-2
Krejsler, J. (2005) ‘Professions and their identities: how to explore professional development among (semi-)professions', Scandinavian Journal of Educational Research, 49 (4): 335-57
Mowbray, R. (1995) The Case Against Psychotherapy Registration: A Conservation Issue for the Human Potential Movement, Trans Marginal Press, London
Oakley, C. (1998) ‘The perniciousness of professionalization’, European Journal of Psychotherapy, Counselling and Health, 1 (2): 311-18
Parallax (2004) (Issue 31, 10 (2) (April-June): special theme issue on ‘Auditing Culture’
Parker, I. (2001) ‘What is wrong with the discourse of the university in psychotherapy training?, European Journal of Psychotherapy, Counselling and Health, 4 (1): 27-43 
Phillips, M. (1996) ‘When education fuels the class war’, The Observer newspaper, 26th May (Review, p. 5).
Postle (1998) ‘Gold into lead: the annexation of psychotherapy in the UK’, International Journal of Psychotherapy, 3 (1): 53-83
Postle (2003) ‘Psychopractice accountability: a practitioner “full-disclosure list”’, in Bates and House (eds), Ethically Challenged Professions, pp. 172-8
Power, M. (1997) The Audit Society: Rituals of Verification, Oxford University Press, Oxford
Riggs, D.W. (2005) ‘Locating control: Psychology and the cultural production of 'healthy subject positions’, Culture, Health and Sexuality, 7 (2): 87-100
Sardello, R. (1990) ‘Introduction’, in Steiner, R. (ed.), Psychoanalysis and Spiritual Psychology: Five Lectures, 1912-21, Anthroposophic Press, Hudson, New York, pp. 1-29
Sardello, R. (1999) Freeing the Soul from Fear, Riverhead Books, New York
Sardello, R. (2001) Love and the World: A Guide to Conscious Soul Practice, Lindisfarne Books, Great Barrington, Mass.
Self & Society(2004) (vol. 32, no. 4), special theme issue on ‘The Independent Practitioners Network’
Servan-Schreiber, D. (2004) Healing without Freud or Prozac: New Approaches to Curing Stress, Anxiety and Depression without Drugs andwithout sychoanalysis, David Rodale, London
Steiner, R. (1966/1926) The Evolution of Consciousness as Revealed through Initiation-Knowledge, Rudolf Steiner Press, London
Strathern, M. (ed.) (2000) Audit Cultures: Anthropological Studies in Accountability, Ethics and the Academy, Routledge, London
Totton, N.(1997) ‘The Independent Practitioners Network: A new model of accountability’, in House and Totton (eds), Implausible Professions, pp. 287-93
Trifonas, P.P. (2004) ‘Auditing education: deconstruction and the archiving of knowledge as curriculum’, Parallax, 10 (2): 37-49    
van Houten, C. (1999) Awakening the Will: Principles and Processes in Adult Learning, Temple Lodge, London (orig. 1993)   
Yanchar, S.C., Gantt, E.E. and Clay, S.L. (2005) ‘On the nature of a critical methodology’, Theory and Psychology, 15 (1): 27-50

*** END **

Richard House is an NHS counsellor, a Steiner (Waldorf) early-years teacher, a publishing editor, and an academic writer living in Norwich, UK. A founder-participant in the IPN, his latest books, Therapy Beyond Modernity and Ethically Challenged Professions (co-edited with Yvonne Bates) were published in 2003. His new books The Trouble with Education and With an Independent Voice: Critical Essays on Therapy will be published in 2006. With Sylvie Hétu, he recently co-founded the publishing company Ur Publications Inc. (Montreal), run according to the Associative Economics principles deriving from Rudolf Steiner’s cultural indications. Correspondence: