CRITICAL REVIEW

DEVELOPMENT OF A FRAMEWORK FOR THE IMPROVED REGULATION OF THE PROFESSION OF PSYCHOTHERAPY
UKCP submission to the Department of Health OCTOBER 2005

UKCP's Love Affair with the State:
The Second Decade - Science as Decoration

Late last year, parallel with the joint mapping exercise it conducted with the BACP, the UKCP undertook some work, that the DoH had also paid for, on restructuring itself. In a perhaps characteristic omission in the report ipnosis reviews below, no mention is made of the size of the financial support, or how it was spent, or indeed why a trade association with 80 members needed to have tax payers finance its internal metamorphosis into a regulation-ready institution.

Ipnosis guesses that neither James Pollard, whose name is on the outer cover, and the numerous other staff and volunteers from the modalities who wrote the report will warm to what ipnosis has to say. Be assured that ipnosis accepts your good will and benign intentions are not in question; however the expectation in your text of a robust response is something ipnosis has taken very seriously.

The document opens with a statement of aims:

The aim was to:

· Improve levels of co-operation between UKCP and other bodies in the field of
psychotherapy and counselling
· Separate the regulatory functions that exist within the UKCP and its member
organisations from the non-regulatory
· Addressing any anomalies in the way it is structured prior to handover of
voluntary regulatory functions.

It all sounds very reasonable. Unless you think regulation will be a disastrous mistake.

This report addresses all three of these aims within the context of preparing the
profession for statutory regulation and against the criteria set out by the HPC.

Preparing the profession for statutory regulation. Keep in mind that these people claiming ownership of the profession of psychotherapy are registered; supposedly ethically sound practitioners who might be supposed, due to the benchmark quality of their training, have a sense of how power can be abused by institutions. Not least the extent to which all professions have a tendency to become a conspiracy against their clients.

The project being reported on is to be regarded as:

…work in progress.

Because for the project of making UKCP fit for regulation it will be:
…necessary to encourage debate and discussion within the profession.

Don't hold your breath. On the evidence so far it seems likely that UKCP's approach to the debate and discussion, both within its membership and in the excluded or dissenting psychopractice communities, will continue to be that of systematically ignoring to death anything that even remotely contradicts its preset course.

The report moves on to grasp the nettle of the HPC's requirements for regulation.
For example:

HPC criterion 4:

The profession must have at least one established professional body which accounts for a significant proportion of that occupational group.

And no prizes for guessing who claims to satisfy this criterion. Interesting the use of the word 'significant', a very loose and flexible signifier. UKCP is a fifth of the size of the BACP but it is still we must suppose, significant. Dissent against regulation however is apparently insignificant and yet, despite no sign of an evidence-base for the harm due to psychopractice in the UK of the kind the DoH regards as essential in psychological medicine, the anecdotal evidence of it is regarded as sufficiently significant to merit state regulation.

Perhaps aware of these potentially terminal anomalies, the report reassures us that:

These comments are made from a UKCP perspective.
The comments are offered respectfully and in the knowledge that other organisations in the field are robust organisations capable of speaking for themselves.

Yes indeed, and ipnosis is doing that right now.

Gearing up its Department of Dubious Claims, the report asserts that

Significant progress has been made in the in taking forward the debate about key issues, for example over the relationship between psychotherapy and counselling and the relationship between different elements of psychoanalysis and psychoanalytic psychotherapy.

…frameworks for dialogue have been developed…

…which will produce results if they are utilised.

Ipnosis tends to see this kind of statement as a trance induction which seeks to disallow discrimination in the reader while implanting a suggestion, in this case, of a psychopractice unity that is manifestly missing. For instance, no one listening to the anguish in psychoanalytic circles about the fine grain of regulation, or hearing the silence in the room at a recent training conference, when the BACP representative outlined why they saw no reason to insist that all counselors in training had personal therapy, would believe that there is 'significant' unity across the psychopractice occupations regarding regulation.

One of the HPC criteria says:
the profession must apply (ipnosis italics) a defined body of knowledge.

NB knowledge is something that is applied. The HPC falls at this hurdle as a regulator since it clearly doesn't understand the facilitative nature of psychopractice. More on this below.

The report tells us that:

If there is to be a consistent process of linking titles, methods, and training there needs to be a thought through, consistent, and economical framework for structuring the profession…
…anomalies need to be addressed and local particularism needs to be overcome.

Hmm. Especially the local particularism of psychopractice communities, and individual practitioners who have yet to find a voice, who refuse to be part of any project to weld psychopractice onto the state.

In another dubious claim, the report says that it:

…reviews the structure of the profession of psychotherapy, its distinct knowledge base, the relationship between the scientific approaches of psychotherapy,

Aha. Scientific. Here we get to the nitty gritty of being acceptable to the DoH, or the HPC, or some made to measure Mental Health Council. Science is mentioned no less than forty times in this document. If you are a counsellor or a psychotherapist, does that match the extent to which you see your practice as scientific?

And as last year's example of mapping 'research' showed the 'scientific' methods so far are old paradigm 'power over' research on people. Not the participatory research that could be expected from a community supposedly subtly nuanced around the ethical dimensions of power.

Why is fullout participative research that parallels actual much (most) psychopractice not used? Because the findings of such research are unpredictable and might produce results that contradict the prevailing institutional agendas. And so questionnaires will be what we will see. And more bean counting and no doubt a continuing obsession with the taxonomy of psychotherapy schooling.

Here are two further examples of this document's spurious scientific gloss.

…counselling, psychology and psychoanalysis, and the range of scientific approaches within psychotherapy.
Psychotherapy is a distinct profession to counselling, and evidence demonstrates that there are a number of sub-groupings supported by a researched scientific base.

Finally there is the continued mistaken presumption, that input regulation is the way to ensure client accountability.

Any regulatory structure will need to reflect this diversity and ensure recognition of an appropriate training route required to achieve statutory registered status.

This is contrary to research, for example from Dan Hogan, and IPN's 12 year experience which shows why output accountability is essential.

When writing to the DoH, sound confident, make magnanimous gestures, and hope nobody really looks at what is going on behind the institutional front…

This report recognises the conterminous relationships of psychotherapy, psychology, psychoanalysis and counselling and makes recommendations for a regulatory structure that recognises and is responsive to these.

…And then make a claim that demonstrates that suggests it has reinvented hubris.

The profession of psychotherapy is in a position to move towards statutory regulation.

What a pity then that:

Questions remain about the Regulator, which will need to work effectively with the complexity of the profession of psychotherapy and the neighbouring professions of psychology, psychoanalysis and counselling.

There are indeed questions about the Regulator (note the capital letter) or whether there will ever be a Regulator. Here is yet another trance induction, assert the distinctness of these occupations, call them 'professions', and (for people whose political discrimination is shaky) it makes it so, makes it seem a done deal.

The report then runs through the first six of the ten HPC criteria for regulation.
And recommends research on the relationship between psychotherapy, psychology, counselling and psychoanalysis to ensure that registration routes are made available. Here again is an unquestioned commitment to input regulation. Trainers train i.e. they have ownership of input to psychopractice. Their approach to regulation is to propose regulation rooted in what they do, i.e. training, rather than ongoing quality assurance of the situation downstream of their training. Which we might suppose is what clients actually need.

Happily unique input registration routes will be available because:

Each of these groupings are able to demonstrate a degree of homogeneity and a degree of scientific difference. (Ipnosis italics)
[UKCK recommends] That statutory registration is made on the basis of there being a generic recognition of the activity of psychotherapy (psychotherapist).

Yes but wouldn't registration/regulation by the HPC or a Mental Health Council be State regulation not statutory regulation?

In a hint of the deep fissures in the psychopractice field, the report admits that work will need to be undertaken on:

…the relationships between psychoanalysis and psychoanalytic psychotherapy and the most appropriate location of these professional groups within the regulatory structure.

Also that research be commissioned, presumably by the DoH,

…to consider greater emphasis on research of the efficacy of the range of psychotherapies beyond those that are more naturally suited to the medical model of the randomised control trial.

And as ipnosis fancies, so as to ensure that, because science has such high status (in the DoH)

…the relationship between the scientific base of psychotherapy and ethics is
taken into account in identifying the appropriate regulator.

Further down the page the report assures the DoH that:

…training standards are reviewed to ensure that supervised clinical work forming part of the training includes work that will develop an understanding of serious psychiatric disorder.

Oh yes, be sure have your copy of DSM IV to hand when you go to supervision. As though 'serious psychiatric disorder' were not a highly contested notion, not least by dissident psychiatrists such as John Read (Routledge 2004) who have come to see psychiatry as a scandal. Yet again, unaware collusion with a medical model of human (mal)functioning.

After items wondering if it wouldn't be a good idea to research the need for personal therapy in training and the value of CPD, the report gets down and ugly.

UKCP has expressed serious reservations concerning the appropriateness of the HPC as the regulator.

This is October 2005 but the report was being written during the middle of that year.

It is possible that there will be a significant reorganisation of the HPC or a broader reorganisation of the regulatory structure for the health professions as a whole.
The report notes the negative response of the British Psychological Society to the consultation on the proposal to regulate 'Applied Psychology' through the HPC. The BPS had concerns that parallelled some of the concerns that have been expressed by UKCP.

The report recommends a Mental Health and Development Council operating within the Council for Healthcare Regulatory Excellence (CHRE). A notion that for some, including ipnosis, denotes continuing unacceptable deference to a medical model of psychopractice. And we would want to ask, who are CHRE? How are they appointed? What is their brief?

With yet another scientific flourish, the report reminds us that:

The purpose of the regulatory structure is to protect the public, ensure good practice, and promote the scientific development of the professions.

This scientific development doesn't as of this moment, ipnosis reminds the reader, include adequate, or even any research, to establish an evidence-base demonstrating that there is significant harm due to psychopractice in the UK. 'Public protection' is yet another long-standing trance induction intended to disallow dissent.

And none of the many psychopractitioners I know would remotely consider their practice as scientific, even, so far as the positivist science of 'research on people' was concerned, actively contradicting its findings and supposed high status.

In a foggy series of sentences worthy of a Chinese imperial court, the report says that:

…there are organizations that have an identity derived from attaching significance to difference which are relatively minor
…there are organisations which have an institutional interest in blurring distinctions that are fundamental to the field.
…The process therefore needs to proceed in part by the testing of the viability of
models.
…The methodological and intellectual over-lap of a number of professions does not justify a leap to the abandonment of the fundamental distinctions between the different professions.
…a key principle to be applied is that all those involved deserve to be
treated with respect.
…treating with appropriate scepticism both claims to similarity and claims to distinction.
…within the framework of this attempt, it follows that no one individual or organisation is a prior authority.

This, process or protocol, whatever it might be, is nonetheless claimed to be:

…essentially a democratic process in which individuals and organisations are staking their own claims, to be judged by the community as a whole.

And also, DoH take note, it is scientific.

This is consistent with scientific method and the requirement for “evidence-based practice”.

Science is once more wheeled onstage, apparently as arbiter of what really matters around regulation but actually this is scientism, science as decoration, see the next paragraph.

Respect is necessary but a prioritisation of evidence over the self-referential authority of an individual or a group is the starting point of the whole scientific enterprise.

Yes, lets have respect, let's even look into having George Galloway as a regulator, But let's also be aware that this sentence, like several ipnosis has earlier pointed to, abuses science by using it as decoration. Ipnosis found this misuse of science strongly reminiscent of the transcendental meditation movement, which thirty years ago similarly used science as decoration to enhance its appeal to scientific illiterates.

And there is more.

The HPC is surely right to identify the status of a profession as a science, or the status of science within a profession, as a key issue.

If you are a registrant of organizations such as for instance Psychosynthesis and Education Trust, Institute of Psychosynthesis, Chiron Centre for Body Psychotherapy, Centre for Transpersonal Psychology, British Psychodrama Association, Karuna, Spectrum, London Association of Primal Psychotherapists, Re-Vision, or any of the others, note what is being asserted in your name,

As though uncertain of the continuing efficacy of earlier trance-inductions, the report tastefully brings on stage one UKCP frequently used in the 90's:

It is likely that the regulation within the European Union will be of increasing significance to psychotherapy in the future.

Then having rejected the HPC's legitimacy as a regulator, the report moves on to discuss its ten commandments as though they were updates from the Moses originals.

…the ten criteria set out by the HPC for applicant professions are useful questions to address.
1. Cover a discrete area of activity displaying some homogeneity
2. Apply a defined body of knowledge
3. Practise based on evidence of efficacy
4. Have at least one established professional body which accounts for a
significant proportion of that occupational group
5. Operate a voluntary register
6. Have defined routes of entry to the profession
7. Have independently assessed entry qualifications
8. Have standards in relation to conduct, performance and ethics
9. Have Fitness to Practise procedures to enforce those standards
10. Be committed to continuous professional development (CPD)

Note the use in item 9. (this is psychotherapy we are talking about) the use of the word enforce. If training 'standards in relation to conduct, performance and ethics' are adequate in the training organizations, why would there be any need to enforce these standards? As ipnosis and Hogan <link> would argue, input regulation of psychopractice sites accountability in a way that guarantees malpractice, whereas output accountability, as IPN demonstrates, is overwhelmingly likely to minimize it.

The UKCP of this report often seems to be endlessly preoccupied with taxonomy, with the minutiae of boundary disputes between its members. Is this perhaps a reflection of the inner turf wars that have been its history for decades?

Curiously, perhaps because of a lack of creativity and innovative out-of-the-box thinking, it seems to recommend, or at least point to a way of resolving these internecine disputes, by looking to a European model of what psychotherapy is. Apparently the European Association of Psychotherapists (an organization which ipnosis recalls not long ago was anathema to the UKCP) has adopted as a working definition the definition of psychotherapy used in Austrian law.

§ 1. Definition of the profession of Psychotherapy
(1) The practice of psychotherapy is the comprehensive, conscious and planned treatment of psychosocial, psychosomatic and behavioural disturbances or states of suffering with scientific psychotherapeutic methods, through an interaction between one or more persons being treated, and one or more psychotherapists, with the aim of relieving or removing symptoms, disturbed behavioural patterns and attitudes to change, and to foster the maturation, development and health of the treated person. It requires both a general and a specific training/education.

|Apart from the self referential awkwardness of having 'psychotherapists' and 'psychotherapeutic' inside a definition of psychotherapy and the medicalizing presumption of 'treatment', here again, but not meriting comment, is 'scientific psychotherapeutic methods'.

In a later scan of possible ways of defining psychotherapy we find another version, this time home-brewed:

…treatment is comprehensive conscious and planned and it is based on scientific psychotherapeutic methods.

A curious claim that seems to belie the facts on the ground. Is it really so that UKCP registrants from Psychosynthesis and Education Trust, Institute of Psychosynthesis, Chiron Centre for Body Psychotherapy, Centre for Transpersonal Psychology, British Psychodrama Association, Karuna, Spectrum, London Association of Primal Psychotherapists, Re-Vision, etc have gravitated to giving 'treatments' based on scientific psychotherapeutic methods? Or had they not noticed?

Further preoccupation with the taxonomy of psychopractice sub groups leads us to a discussion of the acceptability of counselling, which the report claims is:

…more directly focussed on solving problems than psychotherapy.

However:

Many counsellors have developed a practice that in intent is akin to, or even indistinguishable from, psychotherapy.

This evidently makes some in the UKCP very unhappy:

An issue here is whether counsellors who practice as psychotherapists should not in fact state clearly that this is what they are doing.

UKCP's obsession with categoric exclusivity for psychotherapy, a project surely doomed to failure, makes them even more unhappy when facts on the ground contradict it's obsession with tight boundaries:

Attempts to resolve the problem of the status of counselling by the assertion that it is indistinguishable from psychotherapy is profoundly unhelpful to this process of clarification.

And we have research to prove it because it is:

…clear from IMP [Interim mapping Project] that there is very widespread acceptance in practice of the distinction between counselling and psychotherapy check

Even though as ipnosis knows very well, there is also a widespread lack of distinction between psychotherapy and counselling. But the research was designed to identify distinctions and that's what it found.

A hypothesis worth investigating is that counselling is felt to be useful to many
individuals and institutions precisely because of the nature of the intent and perceived to be acceptable because it is safe as a result of the limits of its intent. There is a greater risk, if delineations are too blurred, that an individual might approach a counsellor seeking limited help with a particular problem and find that they are drawn into deeper work for which the counsellor's training may not be sufficient and for which the framework available may not offer adequate support.

UKCP then continues this patronizing grinding of its institutional angst over what seems to be perceived as the contamination of psychotherapy by counselling, with the suggestion that:

It may emerge that some of those who currently practice as counsellors would more accurately, and therefore with greater clarity for the public, be practising, at least part of the time, as psychotherapists.

…the consideration of methods and training standards is confused by attempts to simply conflate psychotherapy and counselling.

However let's not get too worked up about this, one UKCP hand doesn't necessarily know what the other is doing, on p50 of this report there is the fundamentally contradictory claim that:

UKCP has taken the important step of recognising the links between psychotherapy and counselling. To this end it has created the Psychotherapeutic Counselling Section.

It is of course open to the practitioners of other professions to seek to practice according to psychotherapeutic methods as they understand them. Some appropriate borrowing of psychotherapeutic methods by other professionals is greatly to be welcomed. The practice of these professionals in regard to their levels of training is a matter for their own professional bodies as would be any other similar conduct. This will not be prevented by an indicative statutory regulation of the title psychotherapist.

This huffy, patronizing haughtiness about potential transgressions pauses the discussion on counselling, but only for the moment.

After some prolonged gathering of the virtues of psychotherapy, we come to the following remarks. Again note the genuflection in the direction of science.

Psychotherapy training is aimed at the understanding of the whole of the problems of treating psychosocial, psychosomatic and behavioural disturbance or states of suffering within a particular scientific methodology.

However, in this continuing, if tedious competition for territory, counselling is a poor relation:

…the acquisition of distinct skills which may be useful in a range of contexts and which would cumulatively equip someone to be a counsellor is not the basis of psychotherapy training.

Even though not much is agreed between the larger institutions of psychopractice within UKCP version of psychotherapy, there are settled groupings, meaning presumably the modalities.

Each of these groupings is able to demonstrate a degree of homogeneity and a degree of scientific difference.

In this formal recommendation to the HPC, here again science is used as decoration. Take out the word 'scientific' and read the paragraph again.

As most psychopractitioners know (and welcome):

The body of knowledge upon which psychotherapy rests is itself a series of overlapping bodies of knowledge.

But sadly, there are

profound epistemological differences within the profession.

…and it is possible but difficult to…

…distinguish between major fault lines and minor distinctions.

But we can still try. And even go on to launch the contradictory but entrancing claim that:

The profession is within sight of the development of a coherent and workable framework.

Except for the inconvenience that up to now no firm knowledge base has been established:

One unitary alternative to this approach creates an image of the knowledge base and the consequent practice and training requirements that is too general to form a coherent basis for a profession.

Rejected. Because as the report details, it would lead to lowest common denominator practice.

A second alternative unitary approach sets training standards at a high level in relation to one or more modalities

But then for reasons that are not at all clear, the report says such regulation would work, apparently because the regulator wouldn't be able to tell whether the practitioners are dogs or horses.

A third alternative is to recognise a range of groupings so numerous that even a reasonably well-informed observer could only be confused.

Who is this reasonable well-informed observer? Why should the multiple distinctness of psychotherapy practitioners be a problem? Other than to a training organization trade assocation that seeks to generate and control psychopractice through buying into a state regulated monoculture?

Sadly and regretfully, the report admits:

There are many groups that are very anxious to promote their own particular identity and accordingly wish to achieve a level of distinction that is not appropriate within the broad framework. That it is not appropriate represents a judgement, but it is precisely this kind of judgement that will have to be made if a regulatory structure is to be established.

Yes indeed, and who keeps gate for the gatekeepers? Who judges the judges?

After twenty pages in which the UKCP's five modalities set out their stalls vis a vis regulation, we come to a section of the report entitled:

The Profession must support a practice based on evidence of efficacy

And here once more we come to the curious brotherhood of science and psychotherapy.

The term “scientific” appears both in the HPC requirements and in the EAP definition of psychotherapy.

In response to this observation, the report pulls three arbitrary, if pre-existing, notions about psychotherapy out the psychopractice hat:

There is an overlapping debate about psychotherapy as a profession, psychotherapy as a specifically health profession, and psychotherapy as a science.

Some of us would add psychotherapy as education, psychotherapy as personal development, psychotherapy as experiential inquiry, psychotherapy as spiritual quest. But they would distract us from the UKCP's intent here, which appears to be to erect a sufficiently credible piece of window-dressing that will convince the DoH that, among at least the psychotherapy community, the UKCP are sensible, rational civilized citizens who will keep such 'wild' human matters as being born, surviving schooling, begetting children, bereavement, getting old and dying etc from getting in the way of the audit culture glacier. Science has been good at that.

At the heart of scientific method is “the radical notion that our understanding of ourselves should be based on experiment and observation, rather than merely speculating about things”

That's right but one of the clear findings of the history of science is that institutions commonly develop science that magically turns out to support their political agendas.

UKCP's 20 year history of fear-based trance inductions that attempt to corral psychotherapists who were havering about the value of registration, let alone regulation, doesn't inspire trust that they will be any more even-handed in the commissioning of new research. Ipnosis would argue that the evidence points to the reverse, that any UKCP driven research may be reasonably taken to imply a scientific agenda of coercion, elegant, civilized and reasonable, but coercion nonetheless.

Every new science has to develop its own methodology and as it develops to some extent redefines what we understand science in practice to be.

It is true that positivist, 'power-over' research on people, the science of randomized trials, is unappetizing for psychopractitioners. But where are the signs that anyone in either the UKCP or the BACP knows what alternative research with people, action research, or cooperative inquiry is, let alone how to do it?

This would be an approach to science that might match the personhood of the people who come as clients and those of us who meet them as practitioners, and might be reliably independent of the commissioning institution. Which perhaps is why it doesn't happen, except in IPN, which ipnosis has long seen as being structured as a large cooperative inquiry in which the outcome is continuing accountability in the IPN member groups.

A page or two further on, there is the beginning of a hint that science might be an obstacle rather than a lubricant for regulation.

The human sciences encounter an epistemological problem…

Of the human sciences psychotherapy faces this problem most acutely.

The perception that knowledge (including 'objective knowledge') is generated inter-subjectively and is subject to that intersubjectivity is fundamental to psychotherapy.

No human science is more immersed in this problem than psychotherapy because it is precisely concerned with the generation and re-generation of subjectivity.

Yes but. But the notion of psychotherapy as a human science is still presented here as entrancing, as though it were uncontested, with the intent to conflate science and psychotherapy. We mustn't do this blurring with counselling and psychotherapy but it is OK with science and psychotherapy.

Handily, the report, while expressing its doubts in a discreetly gentlemanly tone, sees this as sharply problematic for the regulation project.

A major concern about the Health Professions Council is that having developed primarily to serve professions intellectually based in the natural sciences it will have little comprehension of these problems

And it adds that:

A subsidiary concern is that it might be used to support those who wish to sustain an alliance of thought with authority but masquerade as scientific.

Yes indeed. But set your own house in order before trying to entrance us with what Bad Others might do. Helpfully, for those practitioners outside the UKCP's exclusivity, “an alliance of thought with authority that masquerades as scientific” is a very cogent way of expressing the danger ('concern' is a corporate euphemism) that clients are potentially exposed to by the whole regulation project.

The section continues this 'scientific' discussion with a sideways attack, presumably on one of the fractious psychoanalytic factions that have yet to sign up to the UKCP vision.

How are we to understand the almost religious maintenance of the terms first proposed by Freud to structure the analytic experience? Was Freud really the first, and did he really remain the only theoretician of this supposed science to have introduced fundamental concepts? Were this so, it would be very unusual in the history of the sciences.”

Ouch!

Progress has been made, but more is needed, in developing a framework for promoting a scientific attitude that respects the inter-subjective foundation of the profession and is consistent with its present state of development.

Yes, ipnosis would sign up to that but not unless it is an attitude rooted in 'power with', participatory research with people. This doesn't sound all that likely because the coercive conflation of science and psychotherapy continues:

For the scientific development of psychotherapy it is essential to resist four unhelpful pressures: firstly an excessive dominance of (self-promoted) authorities over evidence, secondly an over-commitment to positivism, thirdly an excessive negative reaction to positivism, and fourthly a reluctance to structure the profession in a way that recognises and supports different scientific methodologies.

'Excessive dominance of (self-promoted) authorities over evidence'. Hmmm, isn't this exactly the reason why so many of us object to UKCP's decades long imperialism and denial of evidence that contradicts it? And why only an excessive dominance? Can we take this to mean that normal dominance, i.e. bullying, is OK.

The authors of the report are troubled that HPC criteria for regulation separate 'psychotherapy as science' and 'the ethics of psychotherapy' without any indication of the links between these two issues.

In considering a regulatory framework for psychotherapy it is essential to understand the links between science and ethics which exist in all sciences but are unavoidable in psychotherapy.

Freud's solution was to focus on health.

Trouble is…

Health is to a considerable extent a social construct, especially in the field of mental health.

It is, indeed, a social construct, and 'mental health' is a related construct from which many psychopractitioners seek to disconnect themselves but which, via a 'mental health council', UKCP is happily promoting as the preferred institutional way forward.

A few more erudite quotations and a sidelong glance at Freud and Lacan lead us to the filling in the sandwich. A statement with which ipnosis can at last whole-heartedly agree.

It is not good enough to say that the profession can regulate itself but the regulatory process needs to be protected from the oversimplifications of those who, with their unquestioned positivist assumptions and materialist thinking, presume that the regulation of all professions is the same.

It can not be relied upon that the appointment of professional experts by an institution will protect the process from the complacent, narrow and uninformed assumptions of that institution.

Yes indeed, especially if such institutions have the kind of coercive history that has brought UKCP to its current role of 'putting together the pieces', that were not in need of its attentions, as Mowbray (Transmarginal Press 1995) cogently argues.

However, referring back to its alarm about HPC's inadequate integration of science and ethics, the writers of the report take yet another opportunity to underline the power to entrance of 'the scientific', i.e. science as decoration, when they ask:

That the relationship between the scientific base of psychotherapy and ethics is taken into account in identifying the appropriate regulator.

The report goes on for another 30 odd pages, but as with mathematical proofs and other aspects of science, and indeed people, there is a point where enough is enough.
Ipnosis hopes that in lieu of spending best part of a day reading the UKCP document, this review will prove enough for you.