|September 18 2007 | LEGAL | ARCHIVE | IPN | CONTACT | HOME | CONTENTS|
A Report arising from the Psychological Therapies Reference Group Meeting 18th September 2007
The deep misunderstanding over the last 15 years or more in key officials of the mainstream accrediting bodies (where are they now?) about the nature of political power, has led to their wish for state regulation to be in process of being granted. But not in the form they sought.
A year ago in September 2006, the BPS was under direct threat of being regulated in the first of a possible domino sequence of SR capture. A defensive paperwork castle, the Psychological Professions Council [PPC], chief architect and contractor, the BPS, was cobbled together in the space of a few weeks. This documented plans for an attempt to try to side-step the HPC in a way that would retain the mainstream bodies' authority over the psychological therapies. Under pressure of possible extinction they had, perhaps for the first time, seen the value of strength in numbers.
Let's not forget that the 36pp PPC proposal was yet another attempt to assert regulatory control over the whole of UK psychopractice without consultation with those of us outside their doors. As I recall, other interested stakeholders in the psychopractice landscape, if they knew about the PPC at all, had less than two weeks to study and contribute to it.
Then and now the PPC seemed a distress-driven initiative. The mainstream bodies' panic derived from their realization, still not publicly named, that state regulation via the HPC would comprehensively undermine their grip on their 'professional' territory. Which, as Ipnosis never tires of saying, was appropriated from a psychopractice prairie that had no need of their registering attentions.
In getting their wish for the state to take control of the nation's subjectivity, the BACP, UKCP, BPS, BPC et al look certain to be reduced to practitioner welfare organizations. A state of being happily more likely to be hubris-free than their previous life of psychopractice-trade associations-vested-interest-lobbying-for-state-endorsement-of-their-probity-as-a-boost-for-market-share. A view that as persistent Ipnosis readers will be aware has been extensively argued and published and 'ignored to death'.
But has it?
Ipnosis was recently sent a copy of the DoH's response to the PPC proposal and heh! a lot of what has been said here and by colleagues about the deficiencies of statutory regulation of psychopractice in the hands of existing mainstream accrediting bodies is echoed in this very critical 18pp DoH text dated 25th July 2007.
In acting to regulate psychopractice, the government is making a huge mistake, but if for the moment we step over that perception, here is a document from the DoH that tells us a lot about the state of play in which our occupations swim. Because the DoH response in effect announces that the PPC is dead in the water, I'll limit this brief review to generic elements and what they tell us about the DoH and its stepchild the HPC.
Let's start with the terms of the DoH's rejection of the nine bodies proposal for a Psychological Professions Council as the state regulator of all practitioners work.
The proposal is judged to be:
Flawed in its understanding of regulatory processes
Flawed in not consistently promoting public safety
Based on largely unsubstantiated criticism of the Health Professions Council (HPC) system and a misunderstanding of the requirements of statutory regulation common to all regulated professions.
Perhaps because of the defensive haste with which the PPC proposal was put together significant aspects of it provenance were only too apparent to the DoH.
The Government also agrees with the analysis of why previous proposals to regulate these professions have failed, including representation of vested interests, and enhancing the status of professional associations. However the Government's view is that elements of these flaws remain apparent in this proposal…
In response to the PPC desire for a single specialist regulatory body, the DoH says:
No justification is given for this. Given the history of failure to agree roles, competencies, standards, and interface between these professions, a single specialist regulator could be inappropriate because it could establish a system of roles and standards based on professional vested interests, not on service users' and providers' needs. This would not serve the public interest.
Further on there is a very important statement of what shapes the government's position vis a vis regulation of psychopractice though lacking any reference to evidence for the assertion:
There is no doubt that applied or practicing psychologists, psychotherapists, and counsellors meet criteria based on risk and potential harm which indicate their need for statutory regulation. (Ipnosis emphasis)
In a paragraph that speaks, as a government should, of its representation of all parties the government rebuts the PPC claims to represent and deliver very high standards:
It may be the professional aspiration that all should reach the highest level of practice and training, but that view may not be shared by service users, service providers, education providers or commissioners, whose views must inform the decisions of the regulator.
A statement which would suggest that the DoH claims to inhabit a fictional universe where intrapersonal, interpersonal and political power is always evenly distributed.
A little further on the DoH recovers a laudable sense of reality.
The Government does not agree that standards of proficiency should be unduly linked to levels of academic award, rather that they should be competence-based reflecting the competences needed to perform the role safely and effectively. Setting award-based standards may serve the profession's interest more than that of the public. 4.5
Sadly this cogency soon lapses with the following assertion about the need for centralized control of psychotherapy training that displays symptoms of chronic TMM disorder (technocratic modernismic myopia), a disability which has been only too apparent in the DoH in recent years.
The Government agrees that consistent application of standards and of educational quality assurance, externally verified so as to provide objective assessment of consistency, is important for public protection. In its view this is best achieved by a single system operated by the regulator itself, since setting standards of practice and training is a core regulatory function that cannot be delegated.
And if we were in any doubt, here is a reminder that the DoH vision of what they are doing is 'law enforcement'.
The statutory regulator must both set standards and apply them to police the profession. Being responsible for both activities is the best way of ensuring that it acts fairly, transparently and consistently.
That the HPC is to say the least, short on merit, or that the object of the PPC was to avoid being under the thumb of it, should not blind us to the fact that the nine bodies who wrote or signed up to it invited the state fox into the psychopractice henhouse. They sought (and still seek) regulation by the state.
Slow to learn, they and their registrants, who continue to keep themselves very poorly informed about the power relations in their field, together with the DoH, still seem in denial that the state regulation of psychopractice is an oncoming disaster, roughly equivalent to the fastfood hamburgerization of food and eating.