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November 27th 2003

"Organisational Development issues for the United Kingdom Council for Psychotherapy following the AGM 2003."

This 16pp draft document, sent anonymously to Ipnosis, had apparently been submitted to the UKCP Governing Board and amended after discussions there. It is described as a working document for circulation to Member Organisations, in the hope that there will be discussion of the issues raised by the document both in UKCP Member Organisations and in the Sections.

The ingredients of the document were intended to form the main focus of a UKCP Chairs Day 2003, which is being held on 13 December 2003.

This is an intriguing document for those of us who have taken an interest in, and challenged, previous attempts at structuring a profession of psychotherapy so that it could be regulated by statute. Ipnosis has extracted a series of key points below, however, since such selections are likely to be coloured by ipnosis preferences and interests, reading the whole text is recommended.

In the following excerpts bold means direct quotes from the document. I have not retained the many bold emphases in the original.
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Covering letter
A covering letter for the document affirms that the UKCP needs a strategic and structural review'. 'At its recent discussion the Governing Board was unanimous that structural change is essential.

The review focuses on the need to effectively regulate and promote the psychotherapy offered by the whole range of... UKCP member groups in the public interest'. It mentions in passing that other groups may wish to be involved within the UKCP in the future however that is not the purpose of the proposed review.

Two agendas are outlined - the first is a familiar, if enigmatic call to. recognise more effectively and to empower the diversity that there is across the UKCP Sections and Institutional/Special Members.

The second is especially interesting for those of us who are sceptical of the value of professionalization of psychotherapy, and of statutory regulation in particular - the need to create a separation between regulation and the provision of services (in particular training, referral and psychotherapy services).

The covering letter goes on to remind us that regulation is inevitably intrusive and will sometimes appear unwelcome, but an open public profession requires regulation with a significant level of independence.

Perhaps aware that such independence (see below) might raise some anxieties, delegate are assured that The Governing Board is seeking to manage this development in a way that respects the core values of psychotherapy and the diversity that the UKCP has always sought to respect.

Draft Document excerpts:

The UKCP Governing Board appear to have considered three options for the ongoing development of the UKCP:

1. To continue to manage the existing structure of the UKCP as effectively as we can.

2. To develop individual registration under the Registration Board.

3. To develop institutional membership based on individual registration.

The first option seems to have been rejected unamimously by the Board which recommended the third option... it raises the possibility that the UKCP might be re-organised on the basis of a number of individual member-based institutions. These would in many cases be derived from the exisiting Sections.

The review proposal begins with consideration of the labels used in the Register to describe the form of psychotherapy a particular registrant offers.

this... involved the UKCP, and the Registration Board in particular, in developments of strategic and structural significance.

and.... The UKCP has had to develop a stronger capacity to take decisions on contentious issues in a thoughtful way.

because... label issues have the potential to be highly divisive. The current controversies are not likely to be the last. The consequence of the approach that has been adopted is that in theory the Registration Board should over time, review all the labels and establish their meaning, the specific practice to which they refer, and the training standards that apply. It is not clear that the UKCP should concern itself with the very wide variety of labels currently used in the Register.

.... The implication of this is that a different more generic labelling process for the psychotherapies should be considered.

The text re-iterated the Aims of the UKCP as
...protection of the public through the regulation of the profession and the promotion of good practice. Benefits to the profession itself are real but incidental. This is even more the case in relation to benefits to the professionals.

... anxieties about the ability to maintain this balance are real and need to be always kept in mind.

Whether it is concerned with promoting the art and science of psychotherapy, or with training standards and regulation, or with research, the UKCP is concerned with these things for the public benefit. Reform of the UKCP needs to serve this purpose.

The review moves on to consider the context in which the uKCP operates, especially the political and professional milieu

The debate about Statutory Regulation is now opening up in an interesting way. Important issues about the process have been clarified as a result of discussions with the HPC, in the Advisory Group on the Registration of Psychotherapists, and in two meetings organised by the BACP.

The developing debate about the implications of regulation is leading to stronger articulation of reservations about regulation in principle. While the document concedes the importance of these reservations, it insists that the discussion is framed by reference to the public interest, not the interests of the professionals involved.

It goe on to outline the familiar justication for professionalisation.

...The public interest argument for the regulation of any profession revolves around the protection of the public from misrepresentation and from exploitative, abusive, or negligent practice, and also to make possible more adequate delivery of the benefits of psychotherapeutic treatment through the establishment of a fully recognised profession. For all professions the regulatory process is a necessary burden.

Following this there is a bit of trance-induction... It is likely that regulation of professional activities in general will become more extensive rather than less and that it will become increasingly difficult to have credibility in offering a professional service in the field of mental health outside of an adequate framework of regulation.

The document claims that The Government, through the Department of Health (DOH) and the Health Professions Council (HPC), is disposed to register psychotherapy but it is not a high priority and is dependent upon improved voluntary organisation across the profession.

Further that The HPC has expressed a provisional view that it would be entitled to act against non registered individuals practising a registered profession even if those individuals operated under a different professional title. This has major implications. The debate to date has focused on indicative registration (protection of title) rather than functional registration. This may also have implications for the proposal that the psychologists should be registered by the HPC separately, and in the not too distant future.

A later paragraph refers to some undisclosed agency or agenda, which it is claimed, means that Ultimately there is pressure for all health professionals to be placed on a single register with appropriate professional advice being obtained at each point of the various processes. Resistance from established health professions has blocked, or at least deferred, that vision. In the meantime it is not clear what arrangements will be in place to link registers, whether statutory or voluntary, or to deal with the problem of double jeopardy.

Will a stutory register distinguish between different forms of psychotherapy? Representatives of the DoH and the HPC have expressed a strong preference for simplicity believing, with some justification, that the distinctions that are so important within the profession are lost on the general public.

Internal politics of UKCP appear to suggest that. The only way to secure agreement may be to permit existing institutional, and therefore historical and political, factors to shape the divisions that are recognised within the register.

The document begins to hint at what appears to be the necessary nature of reform for the UKCP - the separation of training from re-accreditation/regulation A statutory register will be a register of individuals with a centralised process for professional, health and conduct issues. Organisations offering professional training would be accredited by an education committee.

The view is expressed that In the likely event that it will be a considerable time before statutory regulation is implemented it is important to make the voluntary system effective. The challenge remains, as it has always been, to develop effective systems that respect and encourage the diversity of the profession.

The review then begins to point to specifics that it sees as essential ingredient for a viable form of regulation

There will need to be a clear differentiation between organisations responsible for regulatory functions and organisations directly involved in the provision of training and assessment/referral services...

... the management of professional conduct issues by organisations large enough to carry the burden of them and to build up expertise and case law...

... a higher level of lay involvement.

... and Relationships with NHS, other employers, private clients, and other professions.

... there follows some discussion of the relation of psychotherapy and thus the UKCP to the NHS and the the various protected professional domains such as psychiatry... including...

...The DoH maintains that its concern in these discussions is the protection of the public. However it is also evident that it has a powerful concern with the implications of any proposals for the NHS.

...Within the NHS there is a tendency in employment practice to see psychotherapy training as one component alongside training in a "core profession" and experience in the NHS.

... At present senior positions within the NHS tend to be held by psychiatrists. The most significant challenge to this is coming from clinical psychologists.

... A significant element to the European dimension as the single labour market develops is the requirement in some EU countries for either psychiatry or psychology as a basic qualification for psychotherapy.

If psychotherapy is considered a supplementary training this gives rise to the need to consider the value of prior training and experience in other areas of life not formally recognised as health professions.

The review document moves on to consider other institutional players on the psychotherapy turf - claiming to share many of the concerns about these matters of the (BACP) and the (BCP).

In a rather guarded paragraph, the document claims, if I understand it correctly, that if the BACP were to properly distinguish between counsellors and psychotherpaists there might be significant opportunities for co-operation with [the BACP].

It is not clear from a later paragraph whether UKCP's creation of a Psychotherapeutic Counselling Section was intended to complement or compete with the BACP, however it goes on to observe that:

... the complexity and intractability of the issues at stake with a range of organisations... point to the need for the development of an umbrella group that accepts the significance of institutional factors and identities.

A lengthy section of the document reviews the nature of [UKCP] registration and individual registration outlining some of the double jeopardy issues that arise due to parallel employment etc concluding...

... The most significant step that the UKCP could take towards addressing many of these problems is to introduce individual registration. Many of the regulatory functions would then fall directly under the Registration Board. The composition, form of election, powers and procedures of the Registration Board would all have to be considered as part of such a change.

At present the UKCP has the powers to remove a registrant from the register. However the position of a registrant as a member of an MO is less certain. The UKCP ultimately relies upon its power to take action against an MO which fails to act in accordance with a decision of the UKCP.

How would this be done?

two possibilities - develop two parallel organisations: a registering body and a promotional body. The first would be based on individual members, have a purely regulatory function, and would cease to exist were statutory regulation to be introduced. The second would be based on member organisations as at present and have ongoing functions post statutory regulation.

The first of these, which I take to be the review's preferred option, would mean that:

Individual Registration could relieve Member Organisations of the burden of hearing complaint/disciplinary and health related issues. Member Organisations would be free to concentrate on the development and promotion of their own particular vision of psychotherapy.

This would entail member organisation having a post-training relationship based on mutual interest. The continuing affiliation of registrants to M[ember] O[organisations]'s would be dependent upon the registrants valuing the connection, wanting to support the organisations work, and appreciating the services that the MO offered. It is not right that there should be a coercive element in the retention of membership of training organisations by linking this membership to the maintenance of professional registration.

A section of the review document gathers various concerns about the relation of the Sections to the 'centre' including the observations that a move towards individual registration/membership with parallel Member Institutions built out of UKCP Sections, would have a number of advantages:

...Institutions in the place of Sections would provide a stronger base for considering professional conduct issues. This would not be enmeshed with the training process, would not have to be carried out within the confines of a small organisation in which there is usually a dense personal network, and would build up a body of experience and professionalism.

...There would be a professional voice in the regulation of training which would be organised independently from those immediately involved in the provision of training. It is likely that the new institutions will develop structures to incorporate both perspectives.

The Review document concludes with a short section on the way forward in which it re-iterates the Governing Board's unanimity in rejecting the option of Continue to manage the existing structure as effectively as we can.

...and recommended the exploration of the option to Develop institutional membership based on individual registration. (with the caveat that this does not represent a firm commitment to it, or neglect of the explorations of other options).

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