Address:
House of Commons
London SW1A 0AA
Date
Dear…..
I am a member of your constituency and a fully qualified Psychoanalyst registered with the United Kingdom Council for Psychotherapy, (UKCP)/The College of Psychoanalysts-UK [as appropriate]. I work in (NHS, private practice, organisational setting…..or I am a trainee on a UKCP validated course)
I am writing to express my concern about what appears to be a lack of comprehension, equity and transparency in the current Government initiative to regulate the talking therapies. This task has been given to the Health Professions Council (HPC) and its partner Skills for Health (SfH). There are a number of serious problems with this initiative and, despite a great deal of correspondence between the various professional bodies concerned and the HPC and SfH, the key concerns have not been addressed. There are basically two main problems:
a) Psychoanalysis is profoundly different from other psychological therapies in its aims, methods and ethics, yet it is being bracketed together with totally incompatible therapies, with the resulting risk of a serious hampering of professional activity and a fostering of a significant public misperception of psychoanalysis which will have a range of repercussions for the profession.
b) The work of HPC and, in particular, SfH, has not respected the diversity of the professional field, and has failed to remain transparent and democratic. They have failed to listen to the views of the profession and take these into account in their deliberations.
To clarify these points further, I have sketched the central difficulties below:
1) Psychoanalysis is a diverse field comprising many different schools and orientations, with different techniques and trainings. Most schools of psychoanalysis do not see their work as involving healthcare, and their ethics are deeply opposed to most of today's outcome-driven therapies which aim at the removal of symptoms. Analysis is about a long-term exploration of the meaning of one's history, and its results, as Freud emphasised, can never be predicted or promised in advance. What the patient consciously asks for and what the analyst aims at are often not compatible, and this is a well-known and well-documented aspect of analytic work.
2) The HPC/SfH initiative is based on a view of all forms of therapy as healthcare service provision, a model which effectively removes a recognition of unconscious factors in the patient. It sees all therapies as techniques that are applied, services that are bought, as it were, by the patient. But psychoanalysis is not something that can be applied: it is created in each analysis by the patient and the analyst together, with the bulk of the work done by the patient. Each analysis is different, and is driven by what the patient brings and how they develop this. HPC seeks to impose a model on a diverse field which may well suit certain forms of therapy but does not subsume the particularity of analytic work. These points have been spelt out in detail for HPC and have indeed been recognised in other countries. The French government, for example, have recognised the difference between psychotherapy and psychoanalysis, and this difference is reflected in current legislation there.
3) The government has said that as part of the process of reviewing possible regulation of talking therapies it is embarking on a consultation programme to define National Occupational Standards for counselling and psychotherapy through the 'Skills for Health' project. According to the Department of Health, 'Skills for Health' will be the basis for professional standards to inform entry to the HPC and will conduct an in-depth consultation process. However, this consultation process has been neither transparent nor democratic. User groups that contacted SfH have not been consulted, written commitments to include representatives have not been honoured, and the relevant working parties set up by SfH have not been formed on a democratic basis, a fact admitted to by SfH. These working parties in fact contain more than 90% of members from one minority political grouping which represents a highly partisan view of psychoanalysis not shared by most practitioners. Written requests to release information as to the composition of these groups under the Freedom of Information Act, which SfH is bound by, were eventually responded to, outside the 21-day requirement, and the documents we received are now being carefully scrutinised by the Board of Governors of The College.
4) We are concerned at the level of misunderstanding and misinformation currently circulating about the talking therapies and psychoanalysis in particular. For example, a House of Lords discussion of 5/2/07 led by Lord Alderdice contained so many erroneous and directly misleading statements and profound misunderstandings that therapy organisations wrote to Alderdice asking for apology and correction.
5) As a more general issue, it is a matter of great concern that HPC has been systematically expanding the notion of 'good character' as it has been traditionally used in the professions. All our organisations are already bound by strict codes of practice which clearly prohibit any form of exploitation of patients, yet HPC has given itself the power to bar someone from practising their professional activity for reasons that are highly dubious: non-payment of a debt or downloading (adult) pornography from the internet may of course result in someone losing their job with a particular employer, but it is to go beyond the limits of law to make these criteria for being barred from a professional activity such as psychotherapy or psychoanalysis. HPC is buying into a sanitised image of a 'health professional' here, whereas psychoanalysis has no such pretensions: analysts are often chosen by patients precisely because of their human flaws and doing an analysis involves recognising the fallibility of one's analyst.
The inclusion of psychoanalysis alongside other psychotherapies will have serious, detrimental effects on our profession. Psychoanalysis is not about healthcare and it makes no promises of cure to prospective patients. It is not a mechanised procedure that can be applied, but is invented afresh in each analysis by patient and analyst working together. Given that these points are clear to patients, it is surely a matter of informed choice to then decide to embark on analysis or not. Analytic organisations have strict codes of practice and ethics that protect patients, and a redrafting of such codes by HPC and SfH risks changing the very nature of our clinical work and the conditions of practice.
I would be most grateful if you would, as a matter of urgency, make enquiries into this situation to clarify the Government's intentions regarding the possible inclusion of psychoanalysis into the range of therapies that HPC have been instructed to regulate. I would be pleased to supply any further information you may wish for.
Thanking you for your attention.
Yours sincerely,
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