08 November 2006
UK Council for Psychotherapy
2nd floor Edward House
London EC1V 7LT
I write to acknowledge receipt of your document entitled 'Report to the Department of Health: A mapping of the differential knowledge, understanding and skill of the modalities working within the overarching umbrella of the profession of psychotherapy'.
I should like to make it quite clear that the Department of Health has not commissioned this report from UKCP.
Your publication of this report at this time is potentially very damaging. It may give the false impression that UKCP has been given the sole right to map the competences and standards of proficiency for psychotherapy, immediately before Skills for Health launches its wider consultation on a competence framework which will lead to the same outcomes.
The reason for asking Skills for Health to undertake this work was their expertise in developing competences and also, importantly, their relative detachment from the professional bodies in the field of psychological therapies which should enable them to engage with as wide a range of practitioners as possible. This follows after UKCP and BACP had attempted in 2005 to map training and training standards as a way of identifying roles and competences. The outcome of this project did not provide sufficient detail to be of any use in this identification. In addition it became very clear that BACP and UKCP could not command the confidence of the whole of the professions. This led to a loss of participation by other key organisations and a risk of developing standards which might only partially reflect current practice.
As a result, the Department of Health commissioned Skills for Health to co-ordinate production of a competence framework. This will be circulated to all known professional bodies in the field of psychotherapy and counselling at the end of November 2006 and their comments invited in a consultation period extending to the end of February 2007. Those who provide and use psychological therapy services will also inform the final decision on which roles, competences and training will form the basis of statutory regulation.
Your publication of this report, even if for consultation, is therefore very premature. It contains what appears to be a definitive set of standards of proficiency for different modalities in psychotherapy. At this stage this will cause confusion amongst the field, since such standards will derive from competences which have not yet been agreed. You have also made assumptions about the level of academic training and the professional titles to be protected in law which may turn out not to be correct, since these will be based on the agreed roles identified from the competence development framework.
Other bodies may assume that the form of the profession to be regulated - the choice of modalities - and the substance of the standards of proficiency have already been decided. They may also assume that there is no need or point in responding to the Skills for Health consultation on the same subject since UKCP appears to have pre-empted that consultation.
This is not the case. I have discussed this with Skills for Health and they have decided to accept this report as a response from UKCP to their consultation. As such they will take it into account along with other responses received.
I should also make clear that eventually it will be for the statutory regulator, such as the Health Professions Council, to set standards of proficiency for psychotherapists. I understand that it is the HPC's practice to do this with input from the professions concerned, not just from one professional organisation.
I should be grateful if you would print this letter in full on the UKCP website as I do not wish there to be a repetition of any misunderstanding of the Department of Health's position as a result of UKCP's action.
New Regulation Projects Manager
Email address: Rosalind.Mead@dh.gsi.gov.uk