9th November 2006

Healthcare Professional Regulation : Public Consultation on Proposals for Change

We are responding to the invitation in the above Report of 14th July 2006 requesting submission of representations by 10th November.

By way of a preface to our representations, we would like to record that The College of Psychoanalysts has never been convinced that a sound case has been made for compulsory regulation of those professions concerned with the psychological therapies or that such regulation is in the public interest. These professions have, for some years now, been effectively governed by voluntary regulatory bodies. The principal ones are UKCP and BACP whose existence is now widely known and members of the public frequently ensure that the practitioner they intend to consult is eligible for registration with one of them. Public awareness of what it means to be registered is now heightened. In these circumstances, it is difficult to understand why the government should wish to compulsorily regulate, via procedures that are suitable only for those employed in the public services, practitioners who are largely in private practice and, as a group, relatively free of complaints by members of the public. It does seem possible that, if the current policy for compulsory regulation is pursued, the government may produce a rod for its own back.

Having registered the above caveat, it would be misguided not to acknowledge the widespread wish for compulsory regulation that now exists among many practitioners from the professions concerned. The College is a professional body for psychoanalysts and a learned society for the discipline of psychoanalysis. We are not directly concerned with issues of regulation and play no part in the current regulatory process. Nevertheless, The College continues, on behalf of its members, to take a close interest in all proposals for compulsory regulation and is an active member of the Regulation Reference Group set up to enable these issues to be discussed by both the existing voluntary regulatory bodies and a number of professional organisations in the field.

The College agrees with the position taken by some of the organisations within the Regulation Reference Group that the current proposals for compulsory regulation of those who practise the psychological therapies via HPC are neither in the interests of members of the public nor the professions concerned. In relation to this issue, we would like to make the following specific points:

• The proposals of the above report fail to address the reasonable concerns of those bodies that are currently advocating regulation of the psychological professions, because those proposals are oriented almost exclusively to practitioners who work in the public sector (and in particular the NHS) whereas research has established that between 60% and 70% of practitioners work outside the public sector and mainly in private practice.
  
  
• The above concerns can only be addressed if the psychological professions are regulated by a body other than HPC. An example of how such alternative regulation might operate is set out in the draft proposals for a Psychological Professions Council (PPC) which are being submitted separately by the voluntary regulatory bodies. This is a very new proposal and all its aspects, including the proposed name, are still subject to full discussion and consultation with representatives of all the categories of practitioner that would be concerned. The PPC document is therefore referred to only as an illustration of how and along what lines a more suitable regulatory body might be formulated and function.
  
• It is essential that the government also takes into account the views on these matters expressed by 'user organisations' that have an interest in the question of regulation of the psychological professions and who may also wish to submit their own separate representations concerning regulation.

It is hoped that the above comments will form a useful contribution to the consultation process and that the views expressed here will be taken into account when further proposals for regulation of the psychological professions are considered.

Yours faithfully,

Jacques China

President
The College of Psychoanalysts - UK

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