Meeting to Present the Department of Health Report on the INITIAL MAPPING PROJECT FOR PSYCHOTHERAPY AND COUNSELLING, Friday 18 November 2005, held at London Voluntary Sector Resources Centre, 356 Holloway Road, London N7
Report written by Richard House, IPN
I attended this meeting as a participant of the Independent Practitioners Network, one of the therapy organisations which was involved in the recent BACP/UKCP-led ‘mapping exercise’ of the field of counselling and psychotherapy in Britain, as a prelude to the mooted statutory regulation of the field. In what follows I set out my report on the meeting. As far as possible my aim is to describe the meeting as dispassionately as possible, though of course I have necessarily been selective in choosing what to highlight in this report which includes detailing the specific questions which I raised in the ensuing discussions (see below). For a more polemical ‘take’ on the meeting, see my IPN colleague Denis Postle’s ‘Ipnosis’ Editorial, the sentiments in which report I broadly support. I have an emailable copy of the report (which runs to some 87 pages), which I would be happy to circulate on request please email me at firstname.lastname@example.org or email@example.com
The meeting was jointly chaired by Nicola Barden, Chair of the BACP, and Lisa Wake, Chair of the UKCP.
THE PRESENTATION OF THE REPORT
Sally Aldridge (BACP) and James Pollard (UKCP) are cited as authors and ‘Joint Project Managers’ of the report, and they jointly presented its findings in summary form at the meeting. They reported that the mapping exercise (hereafter referred to as ‘ME’) covered some 37,500 members of the various organisations involved in the research project. Some 20 per cent of this total were sampled by questionnaire, and the response rate was 48 per cent. It was emphasised that we simply do not know how many other practitioners exist who are not members of any organisation hence, we also do not know how many practising therapy and counselling practitioners there are in the UK.
There are some 5,000 new entrants into the occupational field every year. Some 90 per cent of respondents were in paid employment i.e. there were relatively few volunteer respondents. There is an ongoing question as to whether there are one or two ‘occupational fields’ a question that ran through the whole ME. It was claimed that there are sufficient commonalities between counselling and psychotherapy to justify their regulation at the same time. The report has been criticised for being too counselling-orientated, and not sufficiently focused to elicit differences between counselling and psychotherapy. There was evidence that some psychotherapists and counsellors were likely to be working with different client populations.
Only a relatively small proportion of respondents were doing long-term work with clients (defined as over 20 sessions, or 6 months+). The ratio of respondents was 2:1, counsellors:psychotherapists.
With regard to training and standards, some 570 training courses were identified and there are almost certainly more than this. One-year and introductory courses were excluded from the survey. There is clearly no single route of entry into the field. Some 26 per cent of courses had no external validation and there is a proliferation of titles (‘certificate’, ‘diploma’, etc.) with no consistency of what a given title represents in terms of training quality. Most respondents were found to be practising in the same framework/approach in which they were trained.
The question of a core curriculum was raised. Certainly, every course surveyed had a stated theoretical base.
It was emphasised that this report is simply concerned with what practitioners have said that they do and have done - further research would be needed to discover whether what has been reported is indeed a true and accurate representation of the field.
Regarding conduct and ethics, the advisability of setting up an independent complaints body and advocacy organisation was mentioned. No organisations have independent regulatory functions. It was remarked that ‘we are trying to get to the place where the government wants us, but we don’t have the legitimacy to get there’.
Regarding recommendations for future development, these are set out on pp. 8-9 of the printed report. Note that the report does not take into account the differences in terms of what ‘treatments’ (their term) are aiming at. It was also remarked that the ‘structural problems’ of regulating psychotherapy are different from those of counselling, and that this could lead to confusion and complexity in the regulation process. Five modalities were proposed on the basis of the research project viz. cognitive behavioural; humanistic and integrative; hypno-psychotherapy; psychoanalysis; and systemic.
Ros Mead, New Regulations Projects Manager at the Department of Health (DoH), then responded to the report.
ROS MEAD'S PRESENTATION
The main question was how to carry this work forward. (Note it was announced that the notes on which her talk was based would be emailed to all participants, but nothing had been circulated/received at the time of writing this report.) Ros Mead stated that the DoH ‘are still trying to achieve’ regulation because of the public protection argument and the importance of adequate disciplinary procedures being in place. The DoH has never wanted one-size-fits-all regulation of psychotherapy and counselling. A central question for the DoH is: How many different roles are there, with titles to be associated with each role? Standards have to be achievable by existing working practitioners hence the mapping exercise (which, she said, ‘was only partially successful’ in terms of covering the whole field).
She emphasised that any regulatory system will need to take account of, and not contradict, human rights law.
The DoH has also funded another project (following its £60,000 funding for this mapping exercise), looking at: (1) improving levels of co-operation between the UKCP and other organisations (which she called ‘a mammoth task’); (2) separating the regulatory functions in some organisations from the non-regulatory which will be important if we get to state regulation because a new regulator will take on some of these functions; and (3) addressing any anomalies in the way it is structured prior to hand-over of voluntary regulatory functions (this latter was requested by the UKCP).
It wasn’t possible to use the ME data to ascertain the number of different roles in the field as a whole. One cannot have a plethora of roles with statutory regulation that are effectively the same role under different labels, as this could lead to inequitable application of standards and statutory regulation must be standardised.
It was stated unambiguously that <<Statutory regulation will require identified roles, competencies and training.>> - and ‘we can’t go further until this is done’. Mead somewhat tentatively suggested that the five modalities mentioned earlier (in Aldridge and Pollard’s presentation) could serve as a list of possible psychotherapy roles together with a sixth, Child Psychotherapy. ‘Is this a starting-point for defining role and competency differentiation?’, she asked.
In the case of counselling, she suggested a role framework along the following lines: general mental health; bereavement; relationship; school/student; drug & alcohol; and trauma counselling. (Some significant objections were raised about this proposal in subsequent discussions.)
In terms of what Mead called ‘drivers for progress’, there is, first, that the government is committed to increase access to the talking therapies, aided by agreed standards of practice and training for roles; this is indeed a government manifesto commitment from the 2005 General Election. Secondly, there is a government commitment to public protection.
Mead said that ‘You have to have an existing voluntary register before it can be statutorily regulated’. Perhaps the field needs to move towards setting up a universal voluntary register and we can’t move forwards until this is done, she said.
These were ‘the controversial bits’, she said.
(1) Standards must reflect roles at point of first qualification broad competence, not later career qualification.
(2) Standards must reflect what is needed now, not what may be in process of development they can be reviewed over time.
(3) Roles must reflect what service users and providers need, not just what professions provide or aspire to.
It was stated that any independent regulator must take account of all players in the field including clients/users, employers etc. There was a strong statement from Ros Mead concerning the importance of including users in these consultations etc. (though James Pollard later cautioned that client/user involvement was a complex issue, while agreeing that it was/is important).
‘Professional self-regulation’ is the term that is being used to describe the regulation process to make it as watertight as possible vis-à-vis public protection.
It was acknowledged that there will almost certainly need to be some kind of ‘grand-parenting clause’ to cover practitioners with considerable career experience but who might not meet agreed training standards, and/or who fall outside the mainstream institutional umbrella(s).
It was mentioned that there is a review of non-medical regulation due to be published before Christmas.
Mead reported that the DoH was proposing to involve external facilitators with expertise in competence mapping and development to take matters forward possibly with a planning meeting early in 2006 (February or March), involving the national training organisations, the Qualifications Authorities, representation of the four home countries’ health departments (since devolution, the government does not have reserved powers in these matters - Scotland, Northern Ireland, or Wales could decline to support state regulation), and some representatives of professional organisations. Under this proposal, national training organisations would co-ordinate the production of a competence map for counselling and psychotherapy, using existing competence frameworks. These would then be used to compare existing roles, to see how they fitted against the map and then to use this study as a basis for agreeing standards.
There was a lot of space given to questions, queries and comments from the floor. In my perception, every question and comment, apart from my own and that of my IPN colleague, took it as an unquestioned axiom that statutory regulation was not only inevitable but desirable. In the first of my two contributions from the floor, I said that since the early-mid 1990s, I had repeatedly asked, in both published writings and to many diverse practitioners, precisely who within the field was allegedly calling for statutory regulation, and that no-one had given me a remotely convincing explanation as to why such regulation was necessary or desirable (the ‘If it ain’t broke, don’t fix it’ argument). A representative from British Association for Behavioural and Cognitive Psychotherapists immediately responded with incredulity, saying that he was aware of a litany of abusive therapist practice that needed to be eradicated. I replied that I had never heard such accusations or assertions in all my experience of/in the field.
My IPN colleague then followed up by asking whether there was any evidence that existing regulatory frameworks stopped abuse from happening, and whether there was evidence about whether there was more abusive practice in unregulated compared with regulated practitioners. No satisfactory answer to this came from the platform, save Ros Mead saying that the DoH had ‘evidence’ of abusive practice but no details were given about this evidence, in particular either about its source or its scale in relation to the size of the field as a whole.
In my second contribution, I picked up on an admirably open admission by Ros Mead that ‘we all make mistakes’ in this process. I quoted this back to her, to ask whether there was an openness to the possibility that the move to statutory regulation might itself be such a mistake and I shared my perception that there seemed to be little if any openness to such a possibility in the assembled gathering. Ros Mead seemed to indicate some agreement with my substantive point; but again, there was an immediate response from the floor, from a Lacanian representative, claiming that my point was ‘complacent’; and he then went on to completely misrepresent what I had actually said which for me provided yet another example if any more were needed as to how those caught up within a powerful ‘regime of truth’ are routinely quite unable even to hear accurately any dissenting voices which dare to challenge or problematise that regime (cf. ‘The Emperor’s New Clothes’).
Richard House, Research Centre for Therapeutic Education, Roehampton University