Statutory Regulation Update

Westacott, M., 2008. Statutory Regulation Update. Reformulation, Winter, pp.3-4.

As many of you will be aware we are now moving swiftly towards the statutory regulation of psychotherapists and counsellors. It is likely that the regulation of applied psychologists will be completed in the first half of 2009 and then psychotherapy and counselling will follow in late 2009 to early 2010. Last week we submitted our response to the Health Professions Council (HPC) “Call for Ideas” document, which was sent to all stakeholders in August. This document asked for our views on a number of issues such as protected titles, the structure of the register and the appropriate level of training for entry to the different parts of the register. Our response is on the ACAT website in a new section where updates on statutory regulation and related issues will be posted.

With respect to protected titles we have argued for the titles of “Psychotherapist”, “Psychological Therapist” and “Counsellor” to be protected by law. This is broadly consistent with the position taken by the UKCP and proposes that title descriptors, such as Psychoanalytic or CAT Psychotherapist, should be decided by the professions and not by government. This is the best position in terms of preventing a reduction of the current breadth of psychotherapy to a handful of categories decided by the HPC and has broad support across the various psychotherapy organizations represented in the UKCP.

The title of “Psychological Therapist” describes a level of post-qualification therapy training less than that of psychotherapist but nevertheless substantial. It is intended to describe our Practitioner training and also other similar trainings, such as the one year post-qualification programmes in CBT and analytical psychotherapy that are currently available. For CAT courses, the minimum requirement for practitioner training will continue to be two years, so the one year criterion we have proposed in the document is designed to include psychological therapy trainings in addition to ours.

You may have noticed from this that the HPC will be regulating not only psychotherapists but other levels of training as well. Many CAT Practitioners will continue to practice under their core mental health training and may not wish to register under an additional category, such as “Psychological Therapists”, particularly as this will incur an additional annual charge. Some of you may however wish or need to do this, particularly if you do not have a core health training, and so the category of Psychological Therapist would be your point of entry to the register as a CAT Practitioner if this is adopted. The UKCP are making a very similar argument but proposing that this part of the register is referred to as “Psychotherapeutic Counsellor” rather than “Psychological Therapist”. After lengthy discussion within ACAT Committees and with CAT Trainers and Supervisors we decided to propose the latter descriptor as psychotherapeutic counselling does not adequately describe the work of most Practitioners.

There is of course a risk that the HPC may decide to adopt titles with protected descriptors, such as “Systemic Family Psychotherapist”. We know that the HPC is going to be informed by the work of IAPT on developing competencies within particular treatment modalities. The HPC is a separate body to IAPT, reporting to a different part of government, and the extent to which their decisions are based on IAPT work is unclear, it depends on who you ask. The modalities currently defined and being worked on within IAPT are as follows:

  • Cognitive behavioural therapy
  • Humanistic / person-centred / process experiential therapy
  • (which is largely Rogerian)
  • Psychoanalytic / dynamic psychotherapy
  • (psycho- has been dropped from psychodynamic)
  • Systemic family therapy

I have also recently heard that a fifth category of “pantheoretical therapies” is being proposed, but I have no further information on this as yet.

There are a number of obvious omissions from this list. The word integrative does not appear, nor are constructivist, psychodynamic, interpersonal therapists or gestalt therapists clearly represented. Through our involvement in the UKCP HIP Section (Humanistic and Integrative Psychotherapies) we have argued vociferously for the inclusion of Integrative psychotherapies in the list of modalities for which competencies are being developed. HIPS has held meetings with members of the IAPT group such as Tony Roth, Stephen Pilling and Peter Fonagy, to argue this position but so far there has been little headway and the term integrative seems to be viewed as a form of eclecticism from which it is difficult to produce modality-specific competencies (which is the narrow remit of the IAPT project).

There are a number of things we can do at this stage. Firstly, we can continue our protest through our representatives in HIPS and the UKCP Political Strategy Group. We also have representation on two IAPT committees and can argue the CAT case within these. Secondly, we can lobby government directly so that they are aware that we do not fit comfortably into any of the proposed modalities without losing our distinctiveness. Lobbying can be an expensive and time consuming business, so the way we approach this must be realistic (anyone with experience of this please get in touch). The Strategy Group we have set up in ACAT to look at these issues will develop a plan of action for this for the forthcoming months. Some of you will already have been involved in the recent political lobbying campaign through your membership of the UKCP.

A third possibility open to us is to think about broadening our base and joining the cognitive behavioural modality of the UKCP in addition to remaining in HIPS. This would give us more choice in terms of which modality we wanted to join when qualifying (either or both) and could be helpful if the HPC decides to use a small number of protected titles that excludes integrative therapies. Currently the CBT section of the UKCP is small with just one member organisation (Association of Rational Emotive Behavioural Therapists AREBT). I think we have little in common with this organization, but such a move could give us the opportunity to establish a cognitive relational voice within the UKCP, distinct from the more Beckian CBT represented by the BABCP. Other possibilities have been considered, such as joining the psychoanalytic section, but there are problems here in terms of the amount of additional personal therapy hours that Practitioners would need and the fact that we would be a very small voice within this large UKCP section. At present, this is just a proposal and I would welcome your thoughts and feedback on the issue (please email me through the ACAT office). We will also be discussing and consulting on this further with the membership before any decisions are made.

There are some things that we can do now to prepare for the forthcoming move to statutory regulation.  For any of you who have completed a Practitioner or Psychotherapy training course but have still not been accredited by ACAT now would be a good time to start working towards this. In our response to the Call for Ideas we have argued for a four year grand parenting phase after regulation comes in, but the current statutory requirement is for just two years, and this might be adopted. If you are an accredited Practitioner or Psychotherapist when the register opens then you should move smoothly onto the register without any difficulty. Otherwise, you will have to go through a more lengthy application process within the grand parenting phase.

As part of regulation the HPC will be looking at CPD, both how we as an organisation promote and monitor this and also the records of individual registrants when their registration comes up for renewal, which will be every two years. It is therefore important to keep a CPD log, whether you use the ACAT system, other systems such as the British Psychological Society one, or your own individual format. ACAT has recently been reviewing the amount of CPD available across the country and we are currently exploring ways of increasing this in terms of geographical spread and number of training events on offer. It is likely that CAT CPD will be just part of your broader CPD log linked to your core profession and area of practice.

I think that is about it for now. I will post any further updates and related documents on the website and there will be a further bulletin in the next Reformulation.

Mark Westacott
Chair, ACAT
28 October 2008

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Full Reference

Westacott, M., 2008. Statutory Regulation Update. Reformulation, Winter, pp.3-4.

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