IPNOSIS: a journal for the Independent Practitioners Network

Dear Colleague,

The Health Professions Council have now published their Draft Standards of Proficiency for Psychotherapy and Counselling. Although they have been working on the proposed regulation of the talking therapies for the last three years, the Standards will surprise many therapists and counsellors. They apply more to medical processes than to therapies, and will be unrecognisable to many practitioners. Indeed, they seem to apply more to a surgical team preparing a patient for an operation than to the open-ended relationship-based work of a talking therapy. The Standards dictate that practitioners should:

- know how to operate equipment and minimise the risk of infection.
- know how to select appropriate hazard control and risk management, reduction or elimination techniques.
- have a knowledge of health, disease, disorder and dysfunction.
- be able to evaluate and implement intervention plans using recognised outcome measures.
- know how to use protective equipment.
- know how to formulate and deliver plans and strategies for meeting health and social care needs.
- understand the principles of quality control and quality assurance and conduct audits correspondingly.
- maintain an effective audit trail, participate in audit procedures and work towards continued improvement.
- be able to formulate specific and appropriate management plans including the setting of timescales.
- demonstrate a logical and systematic approach to problem solving and be able to initiate problem solving techniques.
- observe and record client's responses.
-be able to demonstrate effective and appropriate skills in communicating information, advice and instruction.
- understand the need to engage service users and carers in planning and evaluating the diagnostics, treatment and interventions to meet their needs and goals.
- understand the importance of maintaining their own health.
- know how to meet the needs of the client.

A detailed critique of the Standards is attached to this email, together with a response to the HPC Professional Liaison Group's Report on the proposed regulation of psychotherapy and counselling. Accepting the HPC Standards threatens the talking therapies with the same fate that has met other professions: practice simply becomes a technique of risk management, with the prime concern less the work undertaken with the client than the avoidance of litigation or complaint. Complaints, indeed, would be much more likely given the definition given by HPC of a 'service user': this no longer simply refers to the client, but to "anyone who is affected by the services of a registrant", including a client's relatives or spouse, thus encouraging third party complaints.

Therapists, on the HPC model, would be obliged to act in exactly the ways they may be encouraging their clients to escape from: submission to rather than questioning of internalised authority, and a conformity to socially-agreed expectations, rather then the fostering of creativity and uniqueness that therapies have traditionally aimed at. Whereas the system of values that the talking therapies have always offered was freed from the moral judgements of social authorities, it is now made to conform to exactly these moral judgements. It will no longer be psychotherapy as we know it.

All trainings in the field will, according to HPC, be obliged to meet the Standards of Proficiency, and the hearing of complaints and fitness to practice cases will use the Standards as a benchmark. Aside from the obvious problem of medicalising the talking therapies, the therapists of the future, in such a climate, may feel they are perpetually under a judgmental gaze, the private space of the therapy becoming the stage for an internalised judge or examiner. The consequences of this on therapeutic practice cannot be underestimated, and there is an irony here that many traditional descriptions of psychotherapy define it as the effort to find freedom from the internalised observer-judge that may be at the root of the client's unhappiness.

While we unreservedly support codes of ethics and practice that ensure the practitioner's accountability, we do not believe that HPC's approach is suited to our field and so urge you, should HPC regulation take place, to adopt with us a position of principled non-compliance. If enough therapists and counsellors do not register with HPC, Government will realise the enormous mistake it is making, and our field may not face such a grim future.

Association for Group and Individual Psychotherapy
Arbours Association
Association of Independent Psychotherapists
Centre for Freudian Analysis and Research
The College of Psychoanalysts-UK
The Guild of Psychotherapists
The Site for Contemporary Psychoanalysis