British Association for Counselling and Psychotherapy
'...There is no single entry qualification to counselling and psychotherapy. In psychotherapy the only formal award is post graduate, but 56% of courses have no formal award yet state that they are ‘Master’s level’. Most psychoanalytic trainings also have no formal awards but position themselves when asked at doctoral level based it seems on the length of the trainings. These traditional trainings will find it particularly difficult to gain academic validation in their current format, as such clinical trainings do not map onto QAA benchmarks and the clinical work undertaken does not fit with APL credits.' more |
British Psychoanalytic Council
'...We consider that the public has a right to know:
• The nature (in broad terms) of the treatment model guiding the therapist’s actions
• That the treatment model is based upon a theoretically coherent approach, is scientifically informed and evidence based...'
'...Psychoanalytic or psychodynamic clinicians uniquely set out to work with the mind’s dynamic unconscious...' more
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College of Psychoanalysts
'We have never been opposed to regulation, provided this is in a form that does not damage, or indeed render impossible, the clinical practice of the discipline of psychoanalysis. We have always had doubts about whether the state is capable of providing a suitable regulator of psychoanalysis. Nevertheless, we wish to co-operate fully in the exploratory process now begun by HPC, in order to determine for ourselves, following the conclusion of that process, whether regulation of psychoanalysis by HPC is indeed compatible with the aims of psychoanalysis...'more |
eIpnosis
If objections to state regulation are over-ridden, any structure for an HPC register of psychological therapy practitioners must take account of the substantial number of practitioners who see state involvement in the field as mistaken. A way of acknowledging this through relationship rather than evasion/avoidance/false compliance would require provision of a Principled Non Compliance [PNC] list of practitioners eligible but opposed in principle to state regulation as health care workers. Registration on this list would entail submitting evidence supporting what amounts to an assertion of Conscientious Objection [CO] to the state regulation of the psychological therapies, coupled with details of the practitioner’s civic accountability arrangements.' more |
Julia Evans
'There is no need for the HPC’s existence to tell me not to commit serial murder. If the police cannot foresee and prevent these criminal acts, then I suggest neither will the HPC. The HPC will be enforcing this legislation onto the Talking Therapists – psychologists, psychotherapists, etc. Our working process relies on speech. Speech does not kill. There are laws in place for financial, sexual, physical abuse. What is the HPC going to contribute which will add significantly to the protections in place?' more |
Guild of Psychotherapists
4.1 Broadly speaking The Guild supports the UKCP’s Submission Response No. 1, particularly with respect to the structure of the register and the number of protected titles: that there should be a single protected title ‘Psychotherapist’, without modality specific descriptors; that the entry level requirement for registration under this title should be those that the UKCP applies for all registrants.
4.2 However, in addition, we want to point out that the majority of our members are opposed on principle to HPC regulation of psychotherapy [...]. We have therefore made the case for such principled opposition.
'4.5...We strongly suggest that the Register for psychotherapists now under discussion is established in such a way that there is provision for principled non-compliance recognized as a register of those eligible but opposed in principle to state regulation as health service workers. This could be thought of within the tradition of the rights of the individual to be a conscientious objector.' more
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Penny Georgiou
'The aim of this response is to persuade the Government and the HPC that an enforced statutory regulation of the talking therapies is a bad idea. For psychoanalysis in particular, such a move would wantonly destroy a practice that offers the suffering subject the scope to transform his/her suffering into the motor for a project of work. Further, to posit that what is not a good idea for psychoanalysis is not a good idea for the talking therapies generally; and what is not a good idea for the talking therapies generally is not a good idea for society. This being because falling under the banner of a standard is a road to uniformity, which itself erases the stabilising networks that are woven of meandering diversity. Sadly this meandering diversity has been misdiagnosed as constituting ‘part of the problem’, whereas, it is on the side of the multiple and various inventions and innovations that arise in the attempts to treat intractable problems.' more |
Guy Gladstone
'It is not the proper business of the state to be busying itself with the subjective life or inner worlds of its citizens. For the state to arrogate to itself or its agents a managerial capacity in this respect is to jeopardise the neutrality of the practitioner and to erode the psychic space of the client...'
'...If or when the HPC presides over the psychological therapies there is a likely negative knock-on effect within the psy field. The current local ear-to-the-ground network of ethics committees and panels for complaints procedures will wither, the requirements of ownership and the sense of responsibilities that go with self-management will atrophy. Arse covering and cynicism will be on the up. STASI-style demands and rewards will begin to appear as the fear levels rise. Shop that colleague before she shops you. The HPC has already signalled that it will not tolerate any rival complaints procedures. The One court rules O.K.' more
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Richard House
'A number of us in the ‘psi-field’ have developed detailed and compelling arguments against the statutory (and state) regulation of our work over approaching two decades. Those arguments have been exhaustively developed in many different published forums; and those of us responsible for that literature probably share the view that if rational argument were to have been given due and appropriate weight in this debate, the argument for the statutory regulation of the psychological therapies would have been lost, sunk without trace, a long time ago. In sum, what we are arguing is that the HPC route to regulation entails values and assumptions that a substantial swathe of the therapy modalities simply reject outright.' more |
Richard Klein
'A call for ideas has gone out from within the HPC. It produces an enigma similar to that of Kafka's Trial. The HPC's task is to implement HPO2001,and it is therefore bound to a rigid, legal framework. Why then raise a call for ideas? Any idea that arises outside its framework is already illegal. I can provide at least one reason. It is an attempt to get more precise information on the position of the audience it thinks it is addressing. Such information can only be for political use.' more |
Janet Low
'I understand the impossibility of the situation you are in, given that the government has declared its intention to regulate these groups no matter what the ideas you receive today, but I cannot make your position any easier, and in fact I wish to bring its impossibility more clearly into your view.
You have been given power from the State to ‘protect the public’, but you have not yet shown yourself able to register that this is an impossible task. To grasp the truth of this you will need to draw on all your classical and cultural education, all your feminine colleagues and confidantes, and your wisest friends and acquaintances. They will tell you this: you cannot protect the public from a phantom.' more |
Arthur Musgrave
'In this submission I have attempted to explain why there is such a strong body of opposition to regulation by the HPC. Some of this opposition derives from the way in which the Department of Health, in a whole series of initiatives, has been pressing a partisan agenda based on a flawed reading of the scientific evidence. Some is based on an awareness that the Department has opted for a basis for regulation that, while it may suit the needs of management within the NHS, it is likely to adversely affect the quality of counselling and psychotherapy available to the public. As counsellors and psychotherapists become more fully aware of how badly thought through these proposals are, opposition to HPC regulation is likely to grow. Many now believe that matters have reached the point at which it would be unethical for them not to take a stand of conscientious objection.' more |
Ian Parker
One of the advantages of the rhetoric of transparency and accountability is that the functionaries now feel impelled to put everything up on the internet. For now, this to the benefit of those who want to know what they are up against, but you will see that when psychoanalysts, psychoanalytic psychotherapists, psychodynamic therapists and other analytic therapists are brought into the HPC this tangle will turn from the dream some have of complete protection into a nightmare of surveillance and perpetual insecurity. By looking closely at the website now, we will see that the norms and procedures of the HPC are antithetical to analytical practice on the following counts, ten counts: [...]
What, even, if only some of these ten points pose problems for our practice? The conclusion should then surely be that the HPC is not fit for practice, and that we should say no to it now. more
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The Psychoanalytic Consortium
'Experience with Skills for Health has been wholly unsatisfactory, producing risible draft occupational standards, which although perhaps applicable to a very small segment of psychoanalytic practice under very restricted conditions goes no way towards recognising the full diversity of legitimate psychoanalytic and psychodynamic practice in the UK. Concerns that the HPC would be forced down a similar path for the sake of a simple regulatory model would be a great risk, restricting public choice for no public benefit.' more |
UKCP
Part 1
'3.10 UKCP is currently an organisation of organisational, not individual, members.This is due to change in the near future. UKCP is aware that its MOs represent several thousands more individuals than those currently on its registers. UKCP will expand, post-statutory regulation, to be inclusive of the input and influence of a wider membership, thus supporting the development of the profession and extending the protection of the public interest through greater diversity.'
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Part 2
'4.3 The Dissenting Voice
4.3.1 A portion of the psychoanalytic therapists registered with the UKCP and others have strong concerns and misgivings regarding the current movement to bring psychotherapy under the regulation by HPC. Whilst not all of them object to this plan outright, they think it imperative to acknowledge their objections and to let HPC and Government know that, under certain circumstances, they might feel compelled, for ethical and professional reasons, to refuse acceptance of the regulation of their practice by the state. We ar e engaged in providing education and information to examine the impact of these beliefs on practice and regulation.' more
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