If I had been in any doubt that the December 4 2008 Health Professions Council Professional Liaison Group [PLG] was an historic moment, this was confirmed by the responses to the eIpnosis report on the event. Or rather two responses in particular. Malcolm Allen, CEO of the British Psychoanalytic Council [BPC] emitted an A4 page of personal abuse. Marc Seale CEO of the HPC asked among other things whether my metaphor connecting the PLG with the Vichy government’s collaboration with the German invasion of France in WW2 was intentionally offensive.

Neither chief executive of these two important psychological organizations seems to have asked themselves whether such a metaphor from someone like myself with a long history of chronicling events in the field, might not constitute a legitimate analogy. And even, if they were capable of absorbing it, perhaps a nourishing reflection of what they and the PLG were doing.

But then if you read, or better still listen to the eIpnosis report of this first PLG meeting you’ll appreciate that ignoring dissent was a very large part of the business of the day (for new readers, it was a meeting that began the capture by the state of the UK psychological therapies).

Marc Seale’s CEO response to the eIpnosis PLG Report perhaps reflects internal HPC promptings. The BPC’s CEO shooting from the hip looks to be a straightforward attempt to diss the messenger.

Neither of the chief executives challenged the specific content of the report. Neither executive thought to ask about the main title borrowed from a colleague, Administering the Kiss of Death. Perhaps in some upside down form of logic they see the HPC as administering the kiss of life to an unhealthy field. Inaugurating a future for the psychological therapies replete with ethical incongruence and values degradation seems much more likely. And my guess is that several people in the PLG know this in their hearts but are committed to unenthusiastic accommodation and/or dare I use the term - ‘collaboration’.

I want to argue that taken together, the pair of CEO complaints point to two important and over-arching considerations. Reputation and legitimacy.

The BPC is strong on reputation, not least, as I suspect the reputation that comes from NHS patronage, now I hear under threat, and, see this conference programme, by association with ‘famous people’. And I have no doubt there are BPC members who are committed to deeply caring work. However, coupled with this, there have been decades of intensive self congratulation that, due to their historic (Freudian) lineage, the BPC constitutes the gold standard by which all other ways of working with the human condition must be judged.

Early in the last decade, the soon to become BPC psychoanalytics, claiming ‘seniority’ status tried to insist on being accepted as a ‘security council’ to the UKCP’s lesser mortals; through Lord Alderdice’s Psychotherapy Bill 2000 they attempted to capture control of psychotherapy. Both failed. But they don’t give up. More recently the BPC has followed through on this arguably ruthless imperious style with the apparently successful capture of the National Occupational Standards [NOS] for the psychoanalytic psychotherapies which, see opposite, has the generic, ‘psychological therapies’ at the top of each of its pages. Lord Alderdice and Peter Fonagy either chair or sit on, key Skills for Health Reference Groups notable for their exclusivity and discrimination. Last year's NHS-focussed away-day at the Savoy Centre launching Improving Access to the Psychological Therapies [IAPT] was sponsored by the BPC. Two of the PLG members, if we count Peter Fonagy, are BPC delegates while the BACP with its tens of thousands of members, has just one place at the PLG table.

The BPC doubtless feels that all of this has enhanced its reputation but for those of us excluded from its machinations, at the cost of its legitimacy. While claiming to command the higher reaches of compassion, empathy, transferential subtlety and ethical probity in relations with patients, the BPC also feels free to ruthlessly bully, coerce and even abuse those who dissent from its attempts to expand or sustain its hegemony. And, as some BPC registrants argue, to ignore its members and fail to keep them informed. A hegemony inside which appears to nestle a curious lacuna. Mysteriously absent from the upcoming PLG fights about title is the title ‘psychoanalyst’. Are the psychoanalysts of the Institute of Psycho-Analysis, who as I have been given to understand, are the source of the claimed lineage–based seniority-style legitimacy of the BPC, to be regulated via the HPC? And, if not, why not?

The BPC, while claiming to protect clients’ interests has long seemed to eIpnosis and others to be devoted to the sustenance and propagation of a quasi-authoritarian institutional culture. If you think this is some outsider anti-authority pathology take a look at the two articles (box opposite) which chronicle the caste relations in the communities that make up the current BPC.

Alongside this eIpnosis guesses, there has more recently been a fairly desperate struggle to survive the ideological invasion of NHS psychoanalytic psychotherapy work by the ‘evidence-based’, r.c.t.-derived pharma-style forms of validity that NICE guidelines require.

It’s a tough place for the BPC to be – protecting a reputation founded on seniority and struggling to retain its legitimacy in the face of this ideological invasion. Despite doubts at every level and growing doubts, (apparently three of the key psychoanalytic trainings are currently unable to assemble a cohort of trainees between them) the lure of increased influence has meant that the BPC have decided corporately to support anything coming from Government.

The apparent result? Classical psychoanalysis embracing technocratic forms of inquiry and 'service delivery' as exemplified for example by this IAPT Toolkit and this set of Analytic/dynamic Competences. A quite acute, and we might guess soon to be chronic, example of a reputation mired in ethical incongruity (and values degradation?).


The HPC is a horse of a different colour. Its legitimacy, much though some of us may decry it, is founded in law. It has a constitution written by lawyers for lawyers.

Its reputation is, however, another matter.

Insofar as the HPC chose to regulate the psychological therapies, for some observers this constituted an invasion of them by a love-free ideology. A tick box culture. A culture of domination. One that features, through its ‘fitness to practice’ hearings, as a colleague has called it, a 21st century ‘stocks’ experience of public shaming and humiliation. For at least one member of the public known to eIpnosis, HPC ‘client protection’ has turned out to mean protection of a registrant from the damage that their actions entailed. And as the
eIpnosis PLG report reminds us, in the last year there has not been a single complaint from a member of the public. There has however been a weekly stream of what appear to be employer-generated ‘fitness to practice’ hearings, all of them of HPC registrants whom the HPC had previously endorsed as meeting their educational standards. Certainly not a training standards success, this.

Add to this the unelected membership of the PLG and the wilful conduct of its first meeting (they have eight days in which to settle the future ethical congruity of the whole of the UK’s psychological therapies), and the HPC’s reputation begins to look profoundly values-incongruent. Psychological therapies=love, care, compassion, empathy, support, improvisation and innovation. Regulator=coercion, control, enforcement, punitive sanctions and tick-box style audit and surveillance.

The December 4th PLG meeting demonstrated this disjunction very clearly. The HPC was confidently celebratory in its corporate, alienated bureaucratic style and its openly coercive manipulation of the Group’s regulatory agendas. It claims transparency but in the December 4th meeting, it studiously and blatantly ignored dissent from its pre-ordained task of recommending how to regulate the psychological therapies.

Informed and compellingly argued approaches that have invited the HPC to think even a little 'out of the box' and to consider adopting/adapting Australian or US versions of regulation have met with total rejection. Why? Because the HPC/PLG regulatory process has a technocratic trajectory for which such mature and constructively nuanced mid-course corrections are beyond discussion. ‘Regulators don’t negotiate’ another regulator once told me. And yet the HPC believes, if we push the notion a bit, that this trajectory is the only one that will launch the psychological therapies into state orbit.

If lift-off is achieved, such an orbit for the psychological therapies will be held in place by a fixed set of coordinates, the HPC's legal definitions of standards, competences and ‘fitness to practise’. After blast-off they will move the psychological therapies into rotating, like actual satellites, under the force of legal gravity around the HPC 'Dark Star'. Here is a taste of life in a US version of such an orbit.

Staying in orbit around the HPC will require a psychological therapies culture which clings to the ‘facts’ of r
ecorded outcomes, IT data entry systems, baseline measures, patient satisfaction questionnaires, signed therapy agreements, audit forms, protocol and guidelines for care groups, service summaries, well written case notes, and compliance with legal definitions of competencies and ‘fitness to practise’. Oh yes, and CPD.

What happens to the ecology of the psychological therapies? The diversity of styles/modality? Their grounding in the all-important elements of relationship, compassion, love, caring, and the subtly transferential nuances of relationship; the literally embodied mêtis that ethical psychopractice entails? They already feature in this orbital picture only as potential danger, as spin to persuade everyone that this is really what clients need. But while practitioners are pulled into state regulated orbit, clients will remain earthbound, variously enjoying or suffering the vicissitudes of the human condition and wondering now and again why state regulated professional help seems so constrained and distant.

Is this exaggerated? Taste the reputations and legitimacy of the BPC and the HPC for yourself. Show up for as much as you can manage of the next several days of the Professional Liaison Group meetings. January 28/29, March 3/4, April 29, May 26/27 2009; 10:30am Kennington Pk. Rd., London SE11. A radicalizing experience I promise you.

Show up also for the daily HPC ‘fitness to practise’ hearings too. You can taste the quality of these meetings on Janet Low’s HPCWatchDog blog

All these HPC meetings are held in public. To organize a place at the PLG meetings (essential) email Colin Bendal Colin.Bendall@hpc-uk.org or call him on +44 (0)20 7840 9710 To attend the ‘fitness to practice’ hearings contact Ebony Gayle:Ebony.Gayle@hpc-uk.org tel +44 (0)20 7840 9784

If after all this you have the appetite for it, the trigger for this piece, Administering the Kiss of Death - a Vichy Moment is here, the HPC complaint about it is here, my response to the HPC is here. The BPC’s ‘Open Letter’ can be found here, and a colleague’s unsolicited response to it is here.

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This eIpnosis editorial reflects on two reactions to the following eIpnosis Report
The inaugural meeting of the Health Professions Council Professional Liaison Group for Counselling and Psychotherapy Regulation. December 4 2008
Administering the Kiss of Death - A Vichy Moment
eIpnosis REPORT
All I have is a voice to undo the folded lie.
W.H. Auden
eIpnosis is edited, maintained and © Denis Postle 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, 2009

The British Psychoanalytic Council and the Health Professions Council -
Reflections on Legitimacy and Reputation
eIpnosis Editorial