Is The State Regulation Train Leaving the Station? Or is the Station Leaving the Train?
eIpnosis reports on The Psychological Therapies Reference Group meeting June 10 2008
'I have some sympathy with Kipling's view that a poet has no business becoming an employee of the state'. Wendy Cope declining the role of Poet Laureate
The Psychological Therapies Reference Group meetings that eIpnosis has attended over the last year or three, bring together the BACP, BPS, UKCP, BPC, PCA and other related practitioner groupings. BACP deserve appreciation for persisting with the meetings, which they chair and administer, although I could imagine that they would be glad to be rid of the nuisancesome opposition that they hear. And perhaps, as eIpnosis suspects, the real action has gone off to the Psychological Professions Action Group, PPAG, which met before the Reference Group. There are tiers of power here and this reference group is at the bottom of the State Regulation doodoo chain. That being said eIpnosis recognizes that groups of practitioners totaling perhaps 50k, are being represented at these meetings and that our expectations should be matchingly modest.
In talking of the meeting, I find myself recalling it as fragmentary, or composed of fragments of revelation, occasionally hilarious revelation. On the most amusing of which we were bound to absolute secrecy. I'll preserve that fragmentary recall here.
Early in the meeting, we were reminded of the HPC's decision last November that they had chosen to proceed with regulation of the psychological therapies whether or not there were applications to be regulated. In pursuit of this unilateral assertiveness, in July, a time when lots of people are reliably on holiday, the HPC are setting up a Psychological Professions Liaison Group, PPLG, to begin work in the Autumn on regulating the psychological therapies. The BACP and UKCP have been told that there is no guarantee that they will be represented on this group, opening the possibility that the new HPC psychological therapies profession could be modern example of virgin birth. The HPC's openness with regard to membership of the PPLG, (anyone can apply) can of course be interpreted benignly, and eIpnosis has applied for membership, why don't you? (Contact Michael Guthrie firstname.lastname@example.org).
Chinese whispers that have come eIpnosis' way that the DoH had realized that the regulation of the psychological therapies was a mess, were supported by several items in the meeting. Not least the news of a division of labour in the DoH, with Ros Mead and Nick Clark being hived off to look after NHS matters and the writing of the Section 60 regulatory legislation that will need to be confirmed by parliament, plus the appointment of a new Director of Regulation, Gavin Larner, with a staff of 12 in Richmond, Surrey. When asked by people present at our meeting what current government policy was on regulation of the psychological therapies, Gavin Larner admitted he wasn't sure and would go back to the minister to ask for clarification! Was the intention is to regulate on the basis of public protection as well as patient safety or just patient safety?
The BPS detailed their ongoing dispute with the DoH. What would you think it was about? The likely eclipse of ethics that regulation will entail? No, the BPS are adamant about 'title protection', they want 'psychologist' to be protected. The DoH cannot apparently protect the title for undisclosed 'legal reasons' and insist on 'adjectival titles', i.e. 'counselling psychologists', 'forensic psychologist' 'occupational psychologists', etc. Perhaps because of this matter of status and territory, the timetable for BPS regulation has moved from autumn 2008 to 'early 2009'.
EIpnosis asked what process would be involved in this moment of regulation. Apparently the BPS will hand over a list of their members who are eligible to register to the HPC, the HPC will mail each of them with a notice saying that they will be regulated unless they say otherwise.
A consideration in all this appears to be the apparent lack of work in the HPC. Regulation of the psychological therapies was moved up the agenda last November when an unexpected administrative vacuum was discovered in the HPC. Now we hear that the staff project group of 13-14 to implement regulation of the psychological therapies had stopped work in March, because there was nothing to do.
Reading between the lines of this and a cluster of other statements at the meeting there was a sense that, with a government currently in difficulties and the next election less than two years away, there might be a waning of political will. And some organizations present said they were in touch with Tory shadow ministers.
Moving on, CFAR introduced their experience of keeping track of, and critiquing, the SfH work on National Occupational Standards for the psychodynamic and psychoanalytic psychotherapies. This, available here if your constitution can stand such impacts, is a listing of 451 rules and protocols which such therapists must follow in their work with 'patients'. (This was quietly posted for consultation at the end of May with a deadline for responses of the 15th June)
The 'consortium' of psychoanalytic practitioners had questioned the SfH process through which these manualized therapies was being developed and the composition of the committees charged with the task. For example, Lord Alderdice, a person for whom modes of working with the human condition other than psychoanalysis apparently continue to be invisible, and Peter Fonagy, plus others from UCL are on, or chairing, several of the key SfH committees of. CFAR was told, in writing, that on this occasion, SfH had 'chosen not to be democratic' in their selection of advisers. The 'Consortium's' 17 pp critique of the psychodynamic and psychoanalytic psychotherapies NOS is here (not yet) plus a call for responses. No one at the meeting knew how Fonagy and Alderdice, let alone others on the SfH committees had been appointed.
Curiously, in a brief discussion of this stance of the SfH, one of the UKCP persons present insisted that SfH were 'neutral', i.e. their approach to psychological standards and competencies was value-free. His appreciative description of SfH's intricate dissolution and recombination of the mêtis of the psychological therapies raised a chuckle in eIpnosis, it mirrored the process enacted in the production of the Sav**oy Declaration.
A helpful overview of who does what at the ostensibly independent, value-free SfH pointed to the strong connection with the NHS who had commissioned them, and further connected Steve Pilling of SfH with responsibility for writing NICE Guidelines. Alongside this there was the equally useful prompt that all of this bureaucratic effort had a cost/effectiveness frame, SfH would do only what they could afford to do.
However a useful corrective to giving SfH undue power in these matters came from the realization that the HPC's parallel development of standards and competencies was slated to be complete some time before the SfH work; and that relations between SfH and HPC were notable for their lack of enthusiasm. Also, eIpnosis recalled, Marc Seale had told us that they were not at all committed to living with the NOS that SfH developed.
The Person Centered Assocation and others present were very concerned about the statement on the petitions-to-the-Prime-Minister website excluding the Integrative and Humanistic modalities of the psychological therapies from the grace and favour of the DoH. Not surprisingly, this casual dismissal of thousands of practitioners had generated a lot of traffic, not least within the UKCP and BACP. We were reassured that this statement had been recognized as a mistake but one which could not be directly admitted, (Prime Ministerial status etc., etc). From a BACP perspective it was claimed to be just an honest mistake by a junior person. The notion that the junior must have been repeating what s/he had heard in the office was dismissed as paranoia. Might not the Prime Ministerial exclusion also be evidence of the continued dominance in SfH/DoH of a BPC/Alderdice/Fonaghy axis?
A major doubt about the value of State Regulation came once again from the Association of Christian Counsellors who have a huge percentage of members that are unpaid, unregistrable volunteers. Despite this contradiction they appear to continue, inexplicably, to offer solid support for SR. Around this discussion there was an informed suggestion that, taking a broad definition, there were between 55k and 250k people working in the psychological therapies, many of them in voluntary roles.
The Guild of Psychotherapists reported on a poll of the CPJA UKCP section who had usefully asked for their members attitudes to SR (will they be followed by the rest of UKCP and even, heaven forbid, BACP?) 25% were in favour, 47% were opposed to it, and 25% didn't know (from a 30% response). A poll of Guild membership matched this. Alongside this contribution they noted that In their dealings with SfH, they had become convinced that SfH had a mental block around acknowledging that personal therapy was an essential ingredient for any 'skills base' And they asked, how might groups join together to make a unified opposition?
We heard more from the BPS about the routes into the HPC. 1. Transfer from an existing register. 2. Via an approved qualification. 3. Grandparenting. The latter, set to cost £440, was perceived as yet another severe challenge to the voluntary sector.
The essence of this meeting did seem to lie in its fragments, however strategic overviews favoring positive outcomes for SR were much in evidence towards the end, as on previous occasions, mostly from the BACP corner… 'the train is leaving the station, are were we on it?', 'continuing engagement is essential' and 'oppositional attitudes' of which there were at least four institutional voices at this meeting, were mistaken/unhelpful. The BACP did seem intent on waving aside the extent of the substantial disquiet that permeated the whole of the meeting in favour of recurring instances of the 'power of positive thinking' including even such notions as 'mental capital'. What would we suspect as practitioners if, in the face of likely self harm, a client kept doing this? Denial? Of deep, even health-damaging disquiet? Perhaps even institutional uproar and individual overload?
Might not such uneasiness derive from awareness that, as they are forced through the eye of the needle of the HPC, training and standards and competencies distilled from present practice cannot fail to mutate in years to come into revised training and standards and outcomes that the state will define as essential. Medicine and education were mentioned as examples. As the Guild of Psychotherapists reminded us, if we accept state regulation, what kind of ethical future are we bequeathing to the profession in years to come?