1. What are your views about how the Register should be structured for psychotherapists and counsellors?

Historically, there has been a tradition of regarding psychotherapists and counsellors as belonging to different professions in the UK and other English-speaking countries. The same is not true in the countries of continental Europe, where those who would in the UK practise as counsellors, practise in European countries as supportive psychotherapists. For some years the principal voluntary regulatory body for counsellors, BACP, has claimed to regulate psychotherapists, as well as counsellors. More recently, the principal voluntary regulatory body for psychotherapists, UKCP, has claimed to regulate counsellors, as well as psychotherapists.

Despite the above, there is one important distinction to be made between those who practise as psychotherapists, compared with those who practise as counsellors. The former usually make clear, through their professional title, the modality within which they work, based on significantly different aims and objectives of psychological treatment and rooted in very different and often incompatible areas of theory, whether of inter or intrapsychic phenomena, childhood development, personality or psychopathology. This is rarely the case for counsellors because there are far fewer theoretical divisions within that area of clinical practice and, consequently, it is rarely important for these practitioners to distinguish the type of counselling they offer, although it is fair to point out that BACP has begun, more recently, to categorise counsellors in terms of their modality of working.

The current initiative by HPC, therefore, offers the possibility of presenting to the public a single profession under a single Part of the Register called Psychotherapists, in which there might be various protected professional titles describing the principal modalities of psychological therapy, one of which should be suitable for those who currently practise as counsellors. The alternative to this would be to treat psychotherapists and counsellors as two different professions and for each to have its own Part of the Register: presumably one under a Part of the Register called Psychotherapists and the other under a separate Part of the Register called Counsellors.

2. Which titles should be protected and why?

While the professional titles psychotherapist and counsellor might be adequate to describe two separate Parts of the proposed HPC Register, there is an argument that, in order to protect members of the public, they should be aware of the form of psychological treatment they will be engaged in and, therefore, that more precise professional titles might facilitate such protection.

The term counsellor is ambiguous and, like the term psychologist, requires at least an additional descriptor e.g. psychotherapeutic counsellor. The shorter descriptor therapeutic is equally ambiguous and would also be inadequate.

The issue of professional titles for psychotherapists is more complex.

We agree that a plethora of protected professional titles should be avoided.

The question of modality professional titles for psychotherapists is a difficult one. The following list represents one possible schema of modalities, into which those who currently practise the mainstream modalities of psychotherapy might be expected to fit:

Cognitive Behavioural/Cognitive Analytical Psychotherapist
Humanistic/Integrative Psychotherapist
Hypnopsychotherapist
Psychodynamic Psychotherapist

These modalities might be further refined into client groups, for instance:

Child Psychotherapist
Family Psychotherapist
Group Psychotherapist

Each of the above professional titles amounts to a different specialisation, almost all of which are based on significantly different modes of practice and rooted in very different and often contradictory areas of therapeutic and/or psychological theory. Some would argue that to remove any indication of that specialisation and theoretical background is unhelpful for members of the public in making an informed choice about the particular type of psychological intervention that feels right for them. Specialisation is an important aspect of the medical profession and, without any indication of specialisation, members of the public would be poorly informed in relation to the medical treatment they seek and receive. The same might hold true for psychotherapy. An indication of the significance of these distinctions is that those who make referrals for psychological treatment within the NHS would have precisely the above categories of psychotherapist in mind in making a referral that appears to be appropriate for the person being referred. For one patient, one form of psychotherapy might be appropriate and for another, even a superficially similar individual, another very different form of psychotherapy might be more appropriate. Referral requires specialist knowledge but, in accordance with current ethical practice within the NHS and elsewhere, should always be undertaken following a degree of consultation and informed consent with and from the patient in question. The above categories of modality might greatly facilitate that process.

UKCP, as the largest voluntary regulatory body for psychotherapists, has always been at pains to recognise this diversity of specialisation, which existed long before the days of voluntary regulation. It might be against the public interest for those specialisations to cease to be recognised by HPC, purely in the interests of simplifying the process of regulation. To do so might also amount to the suppression of a rich diversity of psychological treatment that has existed, in some instances, for over a hundred years.

The above categories could possibly be reduced by categorising child, family, group, humanistic and psychodynamic psychotherapists under the single professional title relational psychotherapist. Nevertheless, the important question would then remain: the type of relational psychotherapist that is being considered. There would be fewer professional titles but public choice would be impoverished without further enquiries being made, which not everyone would be capable of pursuing.

An alternative to the above, which we prefer, would be to have psychotherapist as the only protected professional title under a Part of the Register for Psychotherapists and to have psychotherapeutic counsellor as the only protected professional title under a Part of the Register for Counsellors. This would not preclude those registered as a psychotherapist or, indeed, a psychotherapeutic counsellor from using, in addition, some other professional title to describe their specialised modality of work, even though this would then be one that is not a protected professional title.

A further variation of this preferred alternative might be to have a single Part of the Register for Psychotherapists under which there would be just two protected professional titles: psychotherapist and psychotherapeutic counsellor. Again, such a solution would not prevent practitioners in either group from using, in addition, some other professional title to describe their specialised modality of work which is not a protected professional title.

3. What criteria might be used in considering which voluntary registers should transfer and which should not?

Rather than having regard to rigid criteria for considering which voluntary registers should transfer and which should not, it would be more helpful to take into account the registers of those voluntary regulators that have made already a significant contribution to the regulation of practitioners. The two that stand out are UKCP and BACP whose registers should, without question, be transferred. However, there are other voluntary regulatory bodies with smaller and more specialised registers, such as that of BPC, which should also be transferred.

If it is necessary to have criteria for this purpose, this should be limited to organisations that publish registers and who have adequate criteria and procedures for membership and/or registration, as well as procedures for dealing with complaints from members of the public against their registrants.

4. If you represent a voluntary membership organisation, are you able to provide us with information about:

• the number of members and the extent to which this number is likely to overlap with membership of other organisations;

The College of Psychoanalysts - UK has 140 members. All of them are members of other well-established psychoanalytic organisations, either in the UK or abroad. Most of them are, in addition, registered with either the United Kingdom Council for Psychotherapy or the British Psychoanalytic Council.

• arrangements for determining entry to membership;

Applications for membership of The College of Psychoanalysts - UK are first considered by the Membership Committee of The College, to determine whether a prospective applicant meets the published criteria for membership of The College. Eligibility for membership is then determined by the Board of Governors of The College after consideration of the recommendations of the Membership Committee.

• and arrangements for considering complaints about members?

The College has a Code of Professional Conduct which imposes on all of its members mandatory standards of professional conduct. Any complaint that a member is in breach of that code is heard by the Professional Conduct Panel of The College.

5. How long should the grandparenting period be open for and why?

We can see no good reason why the grandparenting period should exceed the two-year period currently provided for by law.

6. Are there any other matters which the PLG should consider in recommending appropriate grandparenting arrangements?

The current provisions of some of the voluntary regulatory bodies, such as UKCP, is that individual practitioners are merely registrants of those bodies, rather than members thereof. It is very important, in connection with the grandparenting arrangements, as well as the transfer to HPC of membership lists, that such arrangements should be extended so as to enable those who are eligible for registration with such bodies - but who have chosen not to be so registered - can subsequently be registered as appropriate with HPC, should they so wish.

7. We would welcome any information about:

• the number and names of existing qualifications leading to the practice of psychotherapy and counselling;
• types of qualifications including the academic level or academic awards of those qualifications;
• the structure of qualifications including theoretical content and practical experience; and
• quality-assurance processes including existing internal and external quality-assurance mechanisms.

We have knowledge only of qualifications relating to practitioners within the psychoanalytic modality, awarded by various training organisations within that modality. The College is a post-graduate organisation and does not run a training programme of its own. Membership of The College is open only to those practitioners who have already undergone a suitable psychoanalytic training or who possess a suitable qualification or are otherwise considered suitable to practise psychoanalysis. All members of The College have undergone a training in psychoanalysis with one of the psychoanalytic training organisations accredited to UKCP or BPC or of a comparable organisation abroad.

It depends, of course, on how the term qualification is defined. In answering this question, we have assumed that an answer is sought in terms of the equivalent of an academic qualification, rather than in terms of a qualification that confers a professional title and licence to practise e.g. psychotherapist. Furthermore, we can answer this question only in relation to the discipline of psychoanalysis. On this basis, none of the training programmes leading to qualification as a practitioner of psychoanalysis in the UK has a specific name qua qualification. The qualifications are to practise psychoanalysis, using a variety of established professional titles, following a suitable course of training, of which there are many. All such training programmes are regarded as being at post-graduate level. They all have the following features in common:

Personal analysis with an acceptable psychoanalytic practitioner.
Successful completion of a training course relating to psychoanalytic theory and clinical practice or the equivalent thereof.
Sufficient psychoanalytic clinical practice under supervision during training.
Written presentations during training of clinical work with one or more patients and/or presentation of a final paper relating to both theory and clinical practice.

All of the training programmes of the training organisations affiliated to UKCP or BPC are subject to regular quality-assurance processes supervised by UKCP or BPC.

8. What issues should the PLG consider in determining the threshold level of qualification for entry to the Register?

We support the objectives of HPC to provide for a threshold academic award of a standard that reflects the current standards of training within psychotherapy and counselling, on the understanding that this might change over time and that individual programmes at levels above the threshold level may also be approved from time to time. We also support the objective that any proposals brought in by HPC should be sufficiently inclusive to enable as many practitioners as possible to be regulated, while ensuring that appropriate standards are maintained for protection of members of the public. We also support the idea of a lead-in period to enable existing education and training-providers to make any necessary changes to their existing programmes.

9. What existing standards or other work should the PLG take into account in putting together draft standards of proficiency?

We can speak only for psychoanalysis. In our view it is vital that HPC should attempt to understand the unique features of psychoanalytic treatment and take these features fully into account in putting together draft standards of proficiency that are to apply to practitioners of psychoanalysis. For example, unlike other modalities of psychotherapeutic treatment, it is vital that any psychoanalytic practitioner should undergo a training analysis that mirrors, so far as may be practical, the psychoanalytic treatment their future patients will experience. Only such a training analysis will enable a practitioner to gain the necessary understanding of the dynamics of the unconscious processes and unconscious conflict that they will later encounter with their patients. Only by encountering their own unconscious conflicts and other unconscious phenomena will they be able to help their patients to understand theirs. No other modality of psychotherapy attributes a comparable indispensability to this feature of their development during training.

It may well be possible to agree generic standards of proficiency, provided the adoption of these does not obstruct the psychoanalytic process and provided there is scope for further standards of proficiency that apply specifically to psychoanalytic practitioners.

10. Do you have any further comments?

Again we can speak only for psychoanalysis. We have never been opposed to regulation, provided this is in a form that does not damage, or indeed render impossible, the clinical practice of the discipline of psychoanalysis. We have always had doubts about whether the state is capable of providing a suitable regulator of psychoanalysis. Nevertheless, we wish to co-operate fully in the exploratory process now begun by HPC, in order to determine for ourselves, following the conclusion of that process, whether regulation of psychoanalysis by HPC is indeed compatible with the aims of psychoanalysis: a discipline of world-repute that has had, arguably, a far greater influence than any other discipline on the practice of psychotherapy in the world today. Our aim is that this heritage should be preserved and not destroyed within the UK, a country in which psychoanalysis has flourished; in which the wider fields of applied psychoanalysis have influenced and continue to influence many other disciplines; and in which psychoanalysts have sought and continue to seek refuge, in order to practise their profession when this has become impossible in their country of origin.

22nd October 2008

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