Marc Lyall
Skills for Health
Goldsmiths House
Broad Plain
Bristol
BS2 0JP

8th July 2008

Dear Marc Lyall,

I am writing on behalf of The College of Psychoanalysts - UK to raise our concerns about the involvement of Skills for Health in the work of formulating competences and national occupational standards for what have been termed the psychological therapies. That project is, of course, a precursor to the proposed introduction of regulation by the state, via the Health Professions Council, as promoted by the government through the Department of Health. It seems clear that these proposals are intended to include the discipline of psychoanalysis with which The College is principally concerned.

We have had correspondence with you and, indeed, a very helpful meeting, with regard to the plans of SfH to set up the necessary project infrastructure, including the Strategy Group, as well as the National and Expert Reference Groups and, in particular, the Psychodynamic Psychotherapy Modality Working Group.

We have already voiced our concerns about the undemocratic and unrepresentatative manner in which all of these groups have so far been set up. Your recent disclosure to us, pursuant to the Freedom of Information Act, of documents relating to the setting up of these groups, has done nothing to alleviate our concerns about these matters. It is clear that there are considerable gaps in the disclosure of the documents that we are entitled to see. The content of some of the documents that have been disclosed gives rise to the most serious cause for concern.

I enclose a detailed document that lists the considerable gaps in disclosure which I will be asking, there, for you to address and deal with separately. I want, in this letter, to bring to your attention, in particular, the contents of only one of the documents so far disclosed. I am referring, here, to Peter Fonagy's email to you of 17th February, concerning the composition of the Psychodynamic Psychotherapy Modality Working Group, in which Fonagy states the following in regard to The College:

The College of Psychoanalysts is a largely Lacanian organization (French psychoanalyst - Lacan - intellectual superhero but clinical and ethical problem, ultimately dismissed from the rank of the international psychoanalytic movement) with a mixture of other sub-groups and about 200 members belonging to the UKCP. It has to be represented because they are very vocal. You have appointed 2 members of the College of Psychoanalysts to the Working group (Atkinson and Barratt) - it [sic] think this is more then [sic] enough.
The Psychoanalytic consortium and Jason Wright are the same group (check http://www.psychoanalysts-cpuk.org/professional%20forum.html). They are deeply opposed to and concerned about regulation. They do not have the same training standards as the British Psychoanalytic Council but would require regulation. So having two of them in there will be a challenge for Anthony. They are very much against evidence based practice and might try and sabotage the process. Let us hope not.

Prior to the above, it had already been agreed by SfH that the Modality Working Group would include two representatives from The College.

Nevertheless, the result of the above comments was that your offer to include two representatives from The College was not honoured. Under normal circumstances, it would have been for us to decide who those two representatives should be. Atkinson and Barratt are indeed members of The College. However, they are members of the Modality Working Group, not as members of The College but in their capacity as members of the newly formed Council of Psychoanalysis and Jungian Analysis. Indeed, one of them has refused, even on an informal basis, to fully disclose to us the nature of some of the deliberations of the Working Group that he has attended, precisely because he is not there to represent The College. These two individuals are not authorised to speak on behalf of The College. Our intention was always to ensure that two members of the Board of Governors should represent us on the Modality Working Group. Neither Atkinson nor Barratt is a member of our Board.

It is very regrettable that, in deciding membership of the Modality Working Group, your organisation has obviously allowed itself to be influenced by the above statement which is highly partisan and tendentious as well as, possibly, defamatory of some of our members. The statement is also inaccurate and misleading. It is not true that The College is a principally Lacanian organisation, whatever that might be. Membership of The College is drawn from right across the profession of psychoanalysis and includes registrants of both UKCP and BPC. Neither is it true that The College and the Psychoanalytic Consortium are the same group under a different name. The College is a professional organisation whose membership comprises individual practitioners from across the entire spectrum of the diverse discipline of psychoanalysis. Our membership comprises practitioners, some of whom are registered with UKCP and others with BPC. Some are registered with both. The Psychoanalytic Consortium is a federation whose members comprise, not individual practitioners but some of the training organisations of UKCP only, except that The College is also an institutional member of that body.

Neither is it true to assert that either organisation is "deeply opposed to……….regulation". We are, however, very concerned about and opposed to regulation by the state, along the lines that are currently being put forward. Our approach to any discussions would remain what it has always been, namely to look at any proposals openly and attempt to determine whether they are compatible with the discipline of psychoanalysis.

It is very worrying that SfH has, apparently without due scrutiny, allowed itself to be heavily influenced by Fonagy's extraordinary views. Had you taken a more careful look at what he said and claimed, you would have realised that he is in fact disingenuous in what he states. For example, the attack on Lacan is entirely ad hominem.

Within the worldwide psychoanalytic community, Lacan is generally considered to be the most important psychoanalyst after Freud, Jung and Klein and his work is taught in almost every major psychoanalytic institution today. Throughout the world, Lacanian practitioners make up more than 60% of the psychoanalytic community. It is, therefore, nonsense to suggest, as Fonagy does, that his work does not form part of the international psychoanalytic movement. Lacan certainly left the International Psychoanalytical Association (IPA) and yet, on an international scale, Lacanian training organisations today far outnumber those groups affiliated to IPA, which happens to be the particular body to which Fonagy is affiliated. It is worth observing here that an analyst such as Jung, who also parted company with the IPA, is today taught and closely followed by, amongst other organisations within the UK, the Society for Analytical Psychology, a leading member of BPC. Apparently, Fonagy and his kind do not hesitate to form alliances and sup with what they might otherwise consider to be the Devil, when it suits the pursuit of their political objectives.

At the present time, the whole of the process undertaken by SfH, in relation to psychoanalysis at least, has been largely in the hands of and almost entirely under the control of a narrow group of practitioners associated with BPC. That group is not, however, representative of psychoanalysis but only of a limited area of that discipline in this country. There is a very clear and insidious attempt by that group to monopolise the discipline and attempt to force all practitioners to practise in accordance with their understanding of psychoanalysis only, as if they were the sole arbiters and guardians of the discipline; which,very clearly, they are not.

The College, long ago, received a written assurance from the Department of Health that it would be a party, in its own right, at all of the discussions intended to take place in regard to regulation. I enclose a copy of a letter The College wrote to the Department of Health, dated 22nd December 2005, setting out in detail the nature of its position within the psychoanalytic field. I also enclose a copy of the response to that letter by the Department of Health, dated 10th January 2006. As a result of the assurances contained in that response, The College has been a participating member of the Regulation Reference Group, set up at the direction of the Department of Health and has played a thoroughly constructive role in those discussions throughout. In doing so, it has fostered good relations with all of the other organisations participating, including BPC and the other voluntary regulatory bodies. The College had and would, if allowed to participate, continue to have every intention of playing a similar role within the deliberations of the SfH Modality Working Group.

The College is deeply concerned about the draft NOS that have recently been circulated in regard to the psychodynamic and psychoanalytic modality. I enclose a critique which illustrates and sets out details of the basis for those concerns. It is entirely wrong and against the principles of natural justice that those practitioners represented by The College should now be excluded from full representation at the formal deliberations about these matters. It is also, arguably, an infringement of their human rights.

Although these issues are dealt with much more fully in the enclosed critique, I would like to draw your attention, very specifically, to just one point of principle that best illustrates the fundamentally unsuitable nature of the NOS as currently drafted. The documents you have so far produced are peppered with references to developmental considerations. Such considerations are irrelevant for some forms of psychoanalysis: in particular the Phenomenological tradition. It would be fundamentally wrong and almost certainly illegal, if NOS provisions come about that preclude, for example, phenomenological practitioners from practising psychoanalysis as they understand it. It is interesting that Fonagy is a particular advocate of developmental models of psychoanalysis about which he has written in depth. However, psychoanalysis is not confined to these and it is unthinkable that those models that do not subscribe to a developmental perspective should in future become, in effect, illegal modes of clinical practice. Only an organisation such as ours, which is constitutionally committed to pluralism within the discipline of psychoanalysis, can ensure that such fundamental errors do not arise within your deliberations.

The College proposes to deal with this situation in a number of ways. Firstly, we will now raise with the Department of Health the issue of our exclusion from the Modality Working Group, which clearly flies in the face of the assurances we received from them earlier.

There remain, nevertheless, two serious questions that, sooner or later, may have to be dealt with before the courts. The first is the wholly unrepresentative manner in which the various SfH groups have been set up. The second is the biased nature of the draft NOS proposals that are now being circulated within the profession, without any adequate opportunity for proper consultation with and discussion by individual practitioners. Both situations now require a full exploration with you about how they might be put right. That would be a constructive approach. In the absence of such an approach, however, The College wishes to make it clear that, in the event of proposals affecting the discipline of psychoanalysis emanating from SfH that do not meet the concerns of every area of psychoanalytic practice, then we will have no hesitation in applying to the courts for judicial review and will, if necessary, request that all your deliberations so far be set aside; that new properly representative bodies be set up; and that new deliberations start afresh within that new framework, in order to ensure that every aspect of the psychoanalytic spectrum of practice is addressed, in a manner that is fair and fully representative.

We will not hesitate to take these issues before the courts of the land, if we find that there is no other way of resolving them. I hope that, nevertheless, you will now be prepared to engage in reasonable discussions that properly address the concerns that we have raised in this letter.

Yours sincerely,

Darian Leader

Professor Darian Leader
President
The College of Psychoanalysts - UK

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