Chair’s Letter, October 2009

Westacott, M., 2009. Chair’s Letter, October 2009. Reformulation, Winter, p.3.


Since I last wrote to you in the spring a great deal has been taking place in the world of psychotherapy and the issue of statutory regulation is now well and truly upon us. I am going to try and summarize some of these developments and also set out what I think will be some of the possible ways forward for us over the forthcoming months. As I write, there is a great deal of uncertainty about; for example over who will become the next Chair of the UKCP, how the Health Professions Council (HPC) will react to feedback it has received as part of the recent consultation, and whether in fact the anti-regulation lobby will seize the day and regulation by the HPC will be delayed or even off the agenda for a while (some of these questions may be answered by the time you read this). All of this of course is set against a backdrop of enormous political uncertainty and mistrust as the current labour administration moves into its final months. The impact of this uncertainty on us in ACAT has been to make the task of just keeping abreast of all these developments an enormous one. It is also limiting our ability to make some decisions until we know how the broader landscape will lie in a few months time. In saying this, it is possible at this stage to set out some of the options and we certainly need to be thinking carefully about the dilemmas and possibilities that lay ahead.

We know that statutory regulation by the HPC will not come into force until 2012 at the earliest. However, two recent developments have caused the issue of regulation to become the current focus of discussion. The first is the publication by the HPC of its consultation document on the statutory regulation of psychotherapists and counsellors along with draft standards of proficiency for these two groups. The second issue has been the election campaign for the Chair of the UKCP where one of the candidates, Andrew Samuels, has been mounting a campaign against state regulation by the HPC which has been gaining in support.

Let’s have a look at these developments in more detail. In September I circulated the HPC consultation documents to all of you. The consultation is now closed but the link to these papers is here: http://www.hpc-uk.org/aboutus/consultations/. Some of the proposals were as expected. For example the proposal that the generic term “psychotherapist” will be protected and specific descriptors like “analytic” and “cognitive-behavioural” will not was anticipated. This proposal is good news for us as we will not have to try and fit ourselves into a therapy modality predefined by the HPC. The HPC will not be interested in modality as far as registration is concerned. More problematic is the proposal that there will be just two protected titles: “psychotherapist” and “counsellor”. As you may remember, we had lobbied the Professional Liaison Group (PLG) of the HPC for a third title of “Psychological Therapist” to be recognised and the UKCP had also asked for the title of “Psychotherapeutic Counsellor” to be a third protected title. Our rationale for this was that “Counsellor” was not an appropriate title for our CAT practitioners and we wanted to achieve statutory recognition for CAT at both the practitionerand psychotherapist levels. It now looks as though this proposal for a three part register has not been accepted which is going to present us with difficulties (or possibly opportunities depending on how you look at it – I’ll come to this in a minute).

Alongside the general consultation document, the HPC has published draft standards of proficiency for psychotherapists and counsellors. These, very rightly, have been widely criticized, particularly for their lack of psychological sophistication, over-reliance on a medical conceptualization of clients and therapy, and for their attempt to differentiate the work done by counsellors and psychotherapists and introduce a hierarchy into the psychological therapies that is harmful and outmoded. The UKCP has coordinated a detailed response to this on behalf of all member organizations and you can read this here: http://www.psychotherapy.org.uk/health_professions_council.html. Other organizations have also provided excellent and highly critical responses, particularly the British Association for Counselling and Psychotherapy (BACP) whose response you can read here: http://www.bacp.co.uk/regulation/. The BACP have now decided to take an anti-HPC regulation position based partly on these consultation proposals. ACAT has contributed to the UKCP response and is also sending two representatives (Cynthia Pollard and Eva Burns-Lundgren) to a meeting with the Shadow Health Minister, Anne Milton, in Westminster next week to voice our concerns.

Following recent conversations I have had with Carmen Ablack (one of the two candidates for UKCP Chair and someone who has worked closely with the HPC) my understanding is that the current draft standards of proficiency are likely to be revised, possibly substantially, in the wake of this criticism. The HPC are due to report on the consultation in November, so we should have news of any revisions very shortly. One of the dilemmas presented to us by the standards as currently written is that it may well be that our CAT practitioners would meet the minimum standards set by the HPC to be become registered as psychotherapists. This issue was raised at the recent ACAT supervisors and trainers annual meeting in London and, as you would expect, a number of views were expressed although the view that dominated was that we should work towards achieving psychotherapist level recognition for our CAT practitioners.

This issue is a complex and difficult one and at this stage we need to gather more information together before I can accurately put the various options to you. There are clear tensions between needing to protect and promote the positions of practitioners but also preserving the path to psychotherapy training as delivered by IRRAPT. Some relevant considerations are the fact that high intensity IAPT therapists might (we are still checking this out) be recognised as psychotherapists following their training and after making up some additional therapy hours. This has already been highly criticised by some psychotherapy accreditation organisations such as the BACP. It is also unlikely that the UKCP would accept this level of training as qualifying for psychotherapist accreditation within its colleges. On the other hand we do need to stay competitive, promote the work done by practitioners and not lose ground to other therapies such as CBT. The BABCP psychotherapy training requirements for CBT therapists are currently very similar to our CAT psychotherapy ones (here is the link: http://www.babcp.com/members-/accreditation/ ) so how this is going to sit with the high intensity IAPT accreditation I do not know (if anyone does can you please get on touch). Given the complexity of this, Council has set up a focus group to consider the issue and report back on options. The members of this group are Hilary Beard, Inigo Tolosa, Maddy Jevon, Jason Hepple and me. Please get in touch with anyone in this group if you have any comments, questions or suggestions.

One of the possible ways forward on this issue would be for training courses to develop a number of different routes to psychotherapy accreditation. Earlier this month we met with members of the UKCP and representatives from CBT and ACT (Acceptance and Commitment Therapy) to form the new Cognitive Psychotherapies College (CPC) of the UKCP. One of the first tasks of the new college will be to look at the standards of education and training for counsellors, psychotherapists and psychotherapeutic counsellors (the UKCP are going to preserve this third title) in the new college. These will need to be consistent with the UKCP generic standards of training but we will have more scope now to develop a number of possible training routes. CAT has a leading role in the new college and we have representation on the Colleges and Faculties Committee of the UKCP which will allow us to be much more influential in the wider organization.

Just to say a bit more about the UKCP. The new college will be one of around eight colleges that will form the UKCP after December 5th when the new constitution comes into force. There will also be a new college for psychotherapists working in higher education and one for people working with couples and sexuality. ACAT now has dual membership in the UKCP - we are in both HIPS and the CPC. At the present time this is clearly more relevant to CAT psychotherapists as only they are UKCP registrants. We might want to explore this issue with the UKCP in future. On December 5th the names of all psychotherapist members of ACAT will be copied to the CPC from HIPS. As a psychotherapist your name will therefore appear in both registers. Would you please let Susan van Baars know as soon as possible if you do not want your name to be copied to the CPC. There will be no additional cost for dual membership in the first year although there may be a small administrative charge in later years if you belong to both. This is still under discussion. In terms of the HPC and statutory regulation it does not matter whether you belong to one or both groups as when the UKCP register is transferred to the HPC in 2012 everyone will be moved across irrespective of college membership. The HPC will have no interest in this.

The new college has been called the Cognitive Psychotherapies College and contains two member organisations; ACAT and an organisation that includes therapists who identify with CBT, including Acceptance and Commitment therapists and Rational Emotive Therapists. It brings us into dialogue with therapists working in quite diverse cognitive traditions, which is in addition to the contact we already have with colleagues in HIPS who are mostly humanistic or integrative. Importantly, I think, it gives us an opportunity to seize some of the cognitive relational ground before this is lost to CBT. The new interim Chair of the CPC (until elections can take place next year) is Mark Webster, who is a CAT, CBT and ACT therapist, and I am particularly looking forward to having further discussions with people working in the third wave of cognitive therapy (e.g. mindfulness based cognitive therapy and Acceptance and Commitment Therapy). It is an opportunity to have dialogue and explore commonality but also to show how our analytic and dialogic heritages set us clearly apart from cognitive therapy.

Related to this issue of our relationship with cognitive psychotherapies, one recent suggestion was that we should seek membership of the British Association for Behavioural and Cognitive Psychotherapies (BABCP). This is the organisation that accredits IAPT workers and other CBT therapists and it was felt that it would be a safer home for ACAT in the current climate. It has also been suggested that it would improve our chances of getting research funding and obtaining recognition of CAT therapists by health insurance providers (we have started to take up this issue with the UKCP). The proposal has so far been discussed within various ACAT committees and at the Trainers and Supervisors event and the reaction has been mixed. Many of you have also sent me emails about this which have similarly been mixed and also passionate at times. It is almost certainly the case that if we took this route we would have to leave the UKCP, so it is a large step for us and one that would require much thought. I think we need to keep hold of it as a possibility but as we are currently committed to the UKCP I do not see this as offering an immediate way forwards.

I want to continue with the UKCP theme but discuss the second recent development that has caused statutory regulation to rise to the top of everyone’s agenda. This is the issue of the UKCP elections and the campaign led by Andrew Samuels against state regulation by the HPC. It is important to note here that Professor Samuels is not against regulation per se, just the current proposals to regulate psychotherapy and counselling by the HPC. There are two websites worth looking at here. The first is that of the Alliance against State Regulation: http://www.allianceforcandp.org/pages/ and the second is Andrew’s own website: http://www.andrewsamuels.com/. Both sites have detailed information with various links to related documents and provide some compelling arguments against regulation by the HPC.

As you know, in ACAT we have not adopted an anti-HPC regulation position and have worked with HIPS and the UKCP to influence the decisions made by the PLG. The decision of Andrew Samuels to run for Chair of the UKCP was a surprise to many, particularly as he has no experience of UKCP structures and committees and is very much a polemicist who disagrees with much that the UKCP stands for. I do find many of his arguments convincing in principle but I also feel that the public are not going to buy it. Most of the user group websites and blogs are against regulation within profession and are suspicious of the anti- HPC regulation movement (here is an example of this: http://www.guardian.co.uk/society/joepublic/2009/jul/01/counselling-psychotherapy-state-regulation). I do think though that there are better systems of regulation – the Australian one being an example – but so far we have felt that for ACAT to take an anti- HPC regulation position would not be in the best interests of our members, many of whom work in the NHS and will need to be registered as psychotherapists when statutory regulation comes into play. We should of course keep our position under review and open to revision as circumstances change.

Very interestingly Andrew Samuels has just made a legal challenge to the HPC, the basis of which is concern over the legality of the HPC’s decision making process. The arguments are set out clearly in the document sent by his solicitors to the HPC and it will be interesting to see how the HPC responds. The letter from his solicitors is here: http://www.andrewsamuels.com/files/bindmans-to-hpc.pdf.

For us in ACAT all of this means a great deal of uncertainty since after the UKCP elections we may have a UKCP Chair who has campaigned on an anti- HPC regulation ticket (we will know the outcome of this election by the time you read this). Also, given the legal challenge to the HPC and the likely regime change about to take place in Westminster questions are raised over the timescales for statutory regulation and even whether it will in fact happen at all - I suspect the answer to this is yes and that we need to continue preparing for it. I think at the moment it is a case of watching this space and hopefully I will have more certain news in my next letter.

Finally I just want to say something about Skills for Health and the development of National Occupational Standards for CAT. As you know, Skills for Health has been developing national occupational standards in four modalities: 1) CBT, 2) Psychodynamic and Psychoanalytic Therapy, 3) Systemic and Family Therapy and 4) Humanistic. The sets of occupational standards (called NOS) will be used by commissioners and others in the NHS to fund training and develop services. Integrative therapies have been excluded from this project despite considerable lobbying by the HIPS section of the UKCP over the past year (here is the link to the relevant section of the Skills for Health website: http://www.skillsforhealth.org.uk/competences/competences-in-development/psychological-therapies.aspx) As you may also remember, we have been lobbying the Department of Health and other key players to support the development of a specific CAT NOS and have gained considerable support for this proposal from across the board. However, a letter sent to us by Lord Alderdice, Chair of the Skills for Health National Reference Group, makes it clear that there is currently no money available for developing further NOS and that no other competency frameworks will be developed this side of the general election. Other psychotherapy organisations, such as Interpersonal Therapy (IPT), are currently developing their own NOS at a reasonable cost. We have had some discussion in ACAT about the possibility of doing this and are currently costing it out. If the finances look right I think we must pursue this option as it will ensure that CAT is on the NOS map. The development of a CAT NOS is also seen by many as essential for our survival in the NHS. We will need to bring in external consultants to work on this to ensure the NOS are consistent with national standards and give them credibility.

This brings me to the end of this letter. I hope it has helped clarify some things and also shown where our energies in ACAT are currently focussed. Your feedback over the past year has beenbeenead, so please keep this coming in.

With warmest regards

Mark Westacott
Chair, ACAT

Full Reference

Westacott, M., 2009. Chair’s Letter, October 2009. Reformulation, Winter, p.3.

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