Kamalamani - Therapist and mentor in Bishopston, Bristol
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The debates surrounding the regulation of counselling and psychotherapy are complex. One aspect that is often overlooked is that many therapist are already regulated! I am already regulated, through being a member of the BACP, adhering to their code of ethics and, were a complaint made against me, subject to their complaints procedure. What is unfortunate at present is that - in some of the mainstream media at least - anyone who is seen to be questioning HPC regulation is assumed to not care about the tragic cases of client abuse that do and have occured at the hands of malpractising therapists. It is not my experience that those who are anti HPC regulation are disinterested in client safety. In fact, I find that it is exactly the opposite. Those I know and work with, who are anti HPC regulation, are concerned that client safety and the opportunities for effective therapeutic work are unlikely to be enhanced by HPC regulation of therapists. If anything, client safety and client choice is likely to be severly limited by HPC regulation in a post-regulation landscape, where the therapies may become increasingly medicalised, more narrowly defined, in line with the other health professions and where the complaints procedure may be far less effective than the existing arrangements in place for those therapists aligned with the BACP, UKCP and other bodies (I am a member of the BACP) or more transparent, accountable alternatives. Last week (early October 09) the BACP opposed the current proposals for state regulation via the HPC (see Therapy Today, October 2009, pg 56 and online http://www.bacp.co.uk/regulation/).
There is currently much debate and uncertainty in the counselling and psychotherapy fields as to the nature of state regulation which is likely to be implemented, and the future in a post-regulation environment. Some therapists appear to accept regulation as a fait accompli, given that so many other sectors are or have been regulated (e.g. the education, health, and financial sectors), particulary if they work in a health care - particuarly NHS - setting. Some seem unaware of the moves towards regulation. Some are anti any form of regulation. Some are opposed to the current HPC proposals for regulation. I am one of those people who is opposed to the current HPC proposals and am a supporter of the Alliance for Counselling and Psychotherapy.
Why am I oppposed to the current HPC regulation of counselling and psychotherapy?
I am deeply concerned about the way in which the counselling and psychotherapy fields are increasingly being identified as part of the medical field; defined from the 'top down' and in many incidences, driven by government agendas and budgets which are concerned with the management of services, rather than the interface with clients, the main focus in my work. For those of us working in private practice, with individuals paying fees and choosing to come for therapy, this medicalised agenda seems far less relevant, appropriately and timely, given that we are not health workers, working outside of a governmental context. In fact, I have had clients in the past who choose come to see me precisely because I operate outside the bureaucracy and systems of the NHS, which is a vitally important factor in their choice of therapist.
The current HPC 'draft standards of proficiency' for counselling and psychotherapy are in many instances completely at odds with the ethos, philosophy and practise of my original BACP approved training course and my practise as a therapist. The proficiences speak the language of clients as 'service users'. 'Diagnostics', 'treatment', 'audit procedures', 'audit trails', 'quality assurance and improvement programmes', 'outcome measures', 'the principles and applications of scientific enquiry', and even 'hazard control and particularly infection control' are deemed to be relevant, important activities in this work. These descriptions may be more fitting to an NHS context, I don't know, as I have never been employed as a therapist in the NHS. What I do know is that they bear little resemblance to the work I have been trained to do. As a result of reading the HPC's proficiencies, I seriously question that they are the most suitable body to be regulating the counselling and psychotherapy fields, given the proficiencies they propose and how they seem to bear little resemblance to the work of many of the counsellors and psychotherapists I have talked to about this.
My BACP approved training was Humanistic and integrative, teaching me how to work relationally with clients, with a very very strong awareness of working confidentially, ethically and negotiating safely, drawing upon several different Humanistic orientations. It was not about diagnosis, treatment and making people better. It was not about doing things to people as service-users. I do not come from a health professions background, I come from a postgraduate social science background, with considerable experience of teaching, training, facilitation, managing and mentoring with people in the public, private (small business, rather than corporate sector), and not for profit sectors and a spiritual development context. To claim I have a background in health and am trained as a health worker would be to mislead the public and potential clients, hence my dis-ease at the thought of becoming registered with the HPC and their language and their conception of therapy, as defined above. So at present, I struggle to see how the HPC proposals will have a positive influence upon counselling and psychotherapy work and cannot see how the HPC are the appropriate body to be regulating these sectors, given their limited knowledge and understanding of the work involved. In fact, it seems unfair to ask the HPC to regulate this field, given that it is so far removed from the lion's share of the other sectors they currently regulate, which are medical, treatment-based sectors.
So that is a brief explanation as to why I am opposed to the current proposals. As a therapist in private practice, this is a bit about how I work, including some points illustrating how I aim to co-create the conditions (with my clients) to work in a confidential, risk-managed and boundaried way with clients who come to see me:
• I work in a private practice setting, not an NHS or other institutional setting. It is not clear to me, provided I continue with all of the important activities below, as to why I should also need to register with the HPC, particularly given that I am working with individuals on a voluntary, fee-paying basis and do not work for the state.
• I am a member of the British Association for Counselling and Psychotherapy (BACP), and have been since 2002. I adhere to their code of ethics and am subject to their complaints procedure, both of which new clients are aware of when I start working with them.
• I work relationally with clients, and building a positive, respectful, boundaried relationship between us is what underpins the therapeutic work. I evaluate with clients how effective our work is on a constant basis, with clear contracting around the theme/nature of the work and inviting feedback from clients as to what's working well and what they want to change in the work going forward. For me, this ongoing dialogue and rapport is a foundation for ethical, 'live', care-ful client work.
• I have regular, high-quality supervision with two very experienced practitioners.
• I participate in ongoing training and continuing professional development, so have dialogue with peers and keep my skills updated and fresh.
• I publish my qualifications, training, experience, professional membership and link to the code of ethics I follow on this website, so I can be as transparent as I can be to potential clients, giving them more information to make an informed choice about who they chose to contact and meet for therapy.
• I research and read widely in my field, particularly my areas of specialism, to ensure that I am not only up to date with current thinking, but am being reflective in the way I work, applying theory to practice and vice versa.
In my mind, all the activities above are critical in making sure I work with effectively my clients.
Frequently asked questions...
These questions and answers go into more detail about particular queries you may have. If you have a question that's not answered below, please get in touch...
1. Do we need regulation at all?
There are alot of different professional counselling and psychotherapy bodies in the UK and many therapists members of one of these. UKCP and BACP are probably the two most well known bodies, and there are several others. Not all therapists are a member of one of these (or an alternative) bodies. I can see (and hear directly from new clients) that it can be absolutely bewildering for clients to make sense of the counselling and psychotherapy fields as they stand, given that there is no one, overarching, register, or list or directory of the all the therapists and therapies.
Personally, I find it useful being a member of the BACP, particularly in terms of being kept up to date with what's going on more widely in counselling and psychotherapy. I can also see that it might help the current situation for clients, if all therapists were required to be a member of one of the existing bodies and publicised this affiliation (as many already do), making more clear the code of ethics to which they work and a procedure for making a complaint. If this were the case, and members were active in their approach to their therapy (e.g. in terms of supervision, being in regular contact with peers, ongoing CPD etc) in my opinion, there would be no need for the role of the HPC. I am also in favour of the notion of therapists publicising their qualifications and relevant experience, so clients know about their therapist's training, experience and background.
2. Why don't you just accept that your profession is going to be regulated?
Because, currently, I fear that regulation, as currently proposed, will have a detrimental, rather than beneficial, effect upon these fields and access to a range of therapy for clients. I don't think public protection will be enhanced by HPC regulation. I don't understand what the roles of organisations like the BACP and UKCP (with their codes of ethics and complaints procedures in place) will be, going forward. From a wider point of view, I don't hold with the view that regulation is necessarily in the interest of the common good. What particularly comes to mind is having witnessed first hand the increasing regulation of the the education and small business sectors. Seeing the recent turmoil of the financial sectors, which have been regulated for the past twenty years, and the suffering that has been caused by this turmoil has lead me to question afresh the myth that regulation is in the interest of the common good.
3. There's been publicity lately about mal-practising therapists, don't people need to be protected from this?
Yes, sadly, there has been publicity about therapists acting unethically lately. I agree that there needs to be a system and channels for clients who are unhappy with the actions of a therapist behaving inappropriately. This may include mediation and/or a complaints procedure, like the BACP complaints procedure, in which actions are taken and the results of hearings published in 'Therapy Today', BACP's monthly magazine.
4. How do I know you are qualified?
You can tell I am qualified by visiting the webpage detailing my qualifications. If you are still unsure, you can double check with the awarding-bodies and the associations in question.
5. Isn't it true that anyone can set themselves up as a counsellor or psychotherapist?
Yes, it is true that anyone can set themselves up as a counsellor or psychotherapist, which is far from ideal, when that means that people can set themselves up with no training, preparation or a supportive and accountable working context. My training - past and ongoing - has helped me to understand the nature of the client relationship, the nature of issues which clients may bring, understand, compare and contrast different models of personality, explore different ways of intervening and 'being' in a therapeutic role, understand the importance of applying an ethical framework in the work I do and to make good and regular use of supervision, to make sure I am doing the most effective work I can do. Of equal importance is that participating actively on therapy training programmes (or at least the ones on which I trained), required me to look deeply at my own habits, conditioning, strengths and weaknesses, blind spots and working edges and to continue to do this, as a practising therapist. That aspect was as important in ensuring that I am able to be effective in relational client work as the formal content of the training itself.
6. If you aren't regulated how will I know whether you are any good? Or that you know what you are doing?
Sadly, whether or not someone is regulated with the HPC will not necessarily be an indication of whether or not they're 'any good', given the entry levels for inclusion on the proposed HPC register. It also depends upon what you mean by 'any good'. What works well for one person may not work well for another, whether that's a particular way of working or whether it feels right to work with a particular person, at a particular time. That sounds vague! That's because it's to do with the stuff of human relationship, choice and preference, which can't, in my opinion, be easily measured or quantified in a meaningful quantitative way. The way I would invite a potential client to figure out if they thought I was 'any good' (though I wouldn't use that language, I'd say, "am I the best person to work with you just now?" and signpost them to this page, particularly if they were new to counselling) would be to suggest that they come to an initial meeting. That meeting is an opportunity for me to know whether I am the most appropriate person to work with a client, depending upon what they are bringing and my particular combination of skills and experience, and whether they feel they could work with me. From my experience, this decision is often made intuitively by clients, or supported by positive word of mouth recommendation. This meeting also gives clients a chance to ask questions etc.
In terms of knowing what I am doing, clients could check out my qualifications, meet me, talk to others who have worked with me or ask for the comments from one of my supervisors.
7. If you are asking to be paid for counselling and therapy by people who may be in a vulnerable state, why should you not be properly controlled?
I am trained and qualified, I work in accordance with the BACP code of ethics, I have regular supervision and in the case of a complaint, clients could follow the BACP complaints procedure (more of which below). My work is overseen by my supervisors and in the case of a complaint, would be overseen by the BACP.
8. What if I have a complaint to make?
In the first instance, I would hope that any client would talk to me about any grievance they had. Therapy can be risky work, given that clients are coming to work with often very deep-seated problems, and misunderstandings and miscommunications can and sometimes, do, happen. The way I work is based on effective, ongoing contact and dialogue. So if I misunderstand something a client has said, that is immediately apparent and I work to re-establish rapport and contact. If a client didn't feel able to talk to me, they could contact the BACP and follow their complaints procedure.
See more critiques of the state regulation of therapy by the HPC. Or read "Compliance? Ambivalence? Rejection? Nine papers challenging the Health Professions Council proposals for the State Regulation of the Psychological Therapies"
Or return to the main homepage.
There is currently much debate and uncertainty in the counselling and psychotherapy fields as to the nature of state regulation which is likely to be implemented, and the future in a post-regulation environment. Some therapists appear to accept regulation as a fait accompli, given that so many other sectors are or have been regulated (e.g. the education, health, and financial sectors), particulary if they work in a health care - particuarly NHS - setting. Some seem unaware of the moves towards regulation. Some are anti any form of regulation. Some are opposed to the current HPC proposals for regulation. I am one of those people who is opposed to the current HPC proposals and am a supporter of the Alliance for Counselling and Psychotherapy.
Why am I oppposed to the current HPC regulation of counselling and psychotherapy?
I am deeply concerned about the way in which the counselling and psychotherapy fields are increasingly being identified as part of the medical field; defined from the 'top down' and in many incidences, driven by government agendas and budgets which are concerned with the management of services, rather than the interface with clients, the main focus in my work. For those of us working in private practice, with individuals paying fees and choosing to come for therapy, this medicalised agenda seems far less relevant, appropriately and timely, given that we are not health workers, working outside of a governmental context. In fact, I have had clients in the past who choose come to see me precisely because I operate outside the bureaucracy and systems of the NHS, which is a vitally important factor in their choice of therapist.
The current HPC 'draft standards of proficiency' for counselling and psychotherapy are in many instances completely at odds with the ethos, philosophy and practise of my original BACP approved training course and my practise as a therapist. The proficiences speak the language of clients as 'service users'. 'Diagnostics', 'treatment', 'audit procedures', 'audit trails', 'quality assurance and improvement programmes', 'outcome measures', 'the principles and applications of scientific enquiry', and even 'hazard control and particularly infection control' are deemed to be relevant, important activities in this work. These descriptions may be more fitting to an NHS context, I don't know, as I have never been employed as a therapist in the NHS. What I do know is that they bear little resemblance to the work I have been trained to do. As a result of reading the HPC's proficiencies, I seriously question that they are the most suitable body to be regulating the counselling and psychotherapy fields, given the proficiencies they propose and how they seem to bear little resemblance to the work of many of the counsellors and psychotherapists I have talked to about this.
My BACP approved training was Humanistic and integrative, teaching me how to work relationally with clients, with a very very strong awareness of working confidentially, ethically and negotiating safely, drawing upon several different Humanistic orientations. It was not about diagnosis, treatment and making people better. It was not about doing things to people as service-users. I do not come from a health professions background, I come from a postgraduate social science background, with considerable experience of teaching, training, facilitation, managing and mentoring with people in the public, private (small business, rather than corporate sector), and not for profit sectors and a spiritual development context. To claim I have a background in health and am trained as a health worker would be to mislead the public and potential clients, hence my dis-ease at the thought of becoming registered with the HPC and their language and their conception of therapy, as defined above. So at present, I struggle to see how the HPC proposals will have a positive influence upon counselling and psychotherapy work and cannot see how the HPC are the appropriate body to be regulating these sectors, given their limited knowledge and understanding of the work involved. In fact, it seems unfair to ask the HPC to regulate this field, given that it is so far removed from the lion's share of the other sectors they currently regulate, which are medical, treatment-based sectors.
So that is a brief explanation as to why I am opposed to the current proposals. As a therapist in private practice, this is a bit about how I work, including some points illustrating how I aim to co-create the conditions (with my clients) to work in a confidential, risk-managed and boundaried way with clients who come to see me:
• I work in a private practice setting, not an NHS or other institutional setting. It is not clear to me, provided I continue with all of the important activities below, as to why I should also need to register with the HPC, particularly given that I am working with individuals on a voluntary, fee-paying basis and do not work for the state.
• I am a member of the British Association for Counselling and Psychotherapy (BACP), and have been since 2002. I adhere to their code of ethics and am subject to their complaints procedure, both of which new clients are aware of when I start working with them.
• I work relationally with clients, and building a positive, respectful, boundaried relationship between us is what underpins the therapeutic work. I evaluate with clients how effective our work is on a constant basis, with clear contracting around the theme/nature of the work and inviting feedback from clients as to what's working well and what they want to change in the work going forward. For me, this ongoing dialogue and rapport is a foundation for ethical, 'live', care-ful client work.
• I have regular, high-quality supervision with two very experienced practitioners.
• I participate in ongoing training and continuing professional development, so have dialogue with peers and keep my skills updated and fresh.
• I publish my qualifications, training, experience, professional membership and link to the code of ethics I follow on this website, so I can be as transparent as I can be to potential clients, giving them more information to make an informed choice about who they chose to contact and meet for therapy.
• I research and read widely in my field, particularly my areas of specialism, to ensure that I am not only up to date with current thinking, but am being reflective in the way I work, applying theory to practice and vice versa.
In my mind, all the activities above are critical in making sure I work with effectively my clients.
Frequently asked questions...
These questions and answers go into more detail about particular queries you may have. If you have a question that's not answered below, please get in touch...
1. Do we need regulation at all?
There are alot of different professional counselling and psychotherapy bodies in the UK and many therapists members of one of these. UKCP and BACP are probably the two most well known bodies, and there are several others. Not all therapists are a member of one of these (or an alternative) bodies. I can see (and hear directly from new clients) that it can be absolutely bewildering for clients to make sense of the counselling and psychotherapy fields as they stand, given that there is no one, overarching, register, or list or directory of the all the therapists and therapies.
Personally, I find it useful being a member of the BACP, particularly in terms of being kept up to date with what's going on more widely in counselling and psychotherapy. I can also see that it might help the current situation for clients, if all therapists were required to be a member of one of the existing bodies and publicised this affiliation (as many already do), making more clear the code of ethics to which they work and a procedure for making a complaint. If this were the case, and members were active in their approach to their therapy (e.g. in terms of supervision, being in regular contact with peers, ongoing CPD etc) in my opinion, there would be no need for the role of the HPC. I am also in favour of the notion of therapists publicising their qualifications and relevant experience, so clients know about their therapist's training, experience and background.
2. Why don't you just accept that your profession is going to be regulated?
Because, currently, I fear that regulation, as currently proposed, will have a detrimental, rather than beneficial, effect upon these fields and access to a range of therapy for clients. I don't think public protection will be enhanced by HPC regulation. I don't understand what the roles of organisations like the BACP and UKCP (with their codes of ethics and complaints procedures in place) will be, going forward. From a wider point of view, I don't hold with the view that regulation is necessarily in the interest of the common good. What particularly comes to mind is having witnessed first hand the increasing regulation of the the education and small business sectors. Seeing the recent turmoil of the financial sectors, which have been regulated for the past twenty years, and the suffering that has been caused by this turmoil has lead me to question afresh the myth that regulation is in the interest of the common good.
3. There's been publicity lately about mal-practising therapists, don't people need to be protected from this?
Yes, sadly, there has been publicity about therapists acting unethically lately. I agree that there needs to be a system and channels for clients who are unhappy with the actions of a therapist behaving inappropriately. This may include mediation and/or a complaints procedure, like the BACP complaints procedure, in which actions are taken and the results of hearings published in 'Therapy Today', BACP's monthly magazine.
4. How do I know you are qualified?
You can tell I am qualified by visiting the webpage detailing my qualifications. If you are still unsure, you can double check with the awarding-bodies and the associations in question.
5. Isn't it true that anyone can set themselves up as a counsellor or psychotherapist?
Yes, it is true that anyone can set themselves up as a counsellor or psychotherapist, which is far from ideal, when that means that people can set themselves up with no training, preparation or a supportive and accountable working context. My training - past and ongoing - has helped me to understand the nature of the client relationship, the nature of issues which clients may bring, understand, compare and contrast different models of personality, explore different ways of intervening and 'being' in a therapeutic role, understand the importance of applying an ethical framework in the work I do and to make good and regular use of supervision, to make sure I am doing the most effective work I can do. Of equal importance is that participating actively on therapy training programmes (or at least the ones on which I trained), required me to look deeply at my own habits, conditioning, strengths and weaknesses, blind spots and working edges and to continue to do this, as a practising therapist. That aspect was as important in ensuring that I am able to be effective in relational client work as the formal content of the training itself.
6. If you aren't regulated how will I know whether you are any good? Or that you know what you are doing?
Sadly, whether or not someone is regulated with the HPC will not necessarily be an indication of whether or not they're 'any good', given the entry levels for inclusion on the proposed HPC register. It also depends upon what you mean by 'any good'. What works well for one person may not work well for another, whether that's a particular way of working or whether it feels right to work with a particular person, at a particular time. That sounds vague! That's because it's to do with the stuff of human relationship, choice and preference, which can't, in my opinion, be easily measured or quantified in a meaningful quantitative way. The way I would invite a potential client to figure out if they thought I was 'any good' (though I wouldn't use that language, I'd say, "am I the best person to work with you just now?" and signpost them to this page, particularly if they were new to counselling) would be to suggest that they come to an initial meeting. That meeting is an opportunity for me to know whether I am the most appropriate person to work with a client, depending upon what they are bringing and my particular combination of skills and experience, and whether they feel they could work with me. From my experience, this decision is often made intuitively by clients, or supported by positive word of mouth recommendation. This meeting also gives clients a chance to ask questions etc.
In terms of knowing what I am doing, clients could check out my qualifications, meet me, talk to others who have worked with me or ask for the comments from one of my supervisors.
7. If you are asking to be paid for counselling and therapy by people who may be in a vulnerable state, why should you not be properly controlled?
I am trained and qualified, I work in accordance with the BACP code of ethics, I have regular supervision and in the case of a complaint, clients could follow the BACP complaints procedure (more of which below). My work is overseen by my supervisors and in the case of a complaint, would be overseen by the BACP.
8. What if I have a complaint to make?
In the first instance, I would hope that any client would talk to me about any grievance they had. Therapy can be risky work, given that clients are coming to work with often very deep-seated problems, and misunderstandings and miscommunications can and sometimes, do, happen. The way I work is based on effective, ongoing contact and dialogue. So if I misunderstand something a client has said, that is immediately apparent and I work to re-establish rapport and contact. If a client didn't feel able to talk to me, they could contact the BACP and follow their complaints procedure.
See more critiques of the state regulation of therapy by the HPC. Or read "Compliance? Ambivalence? Rejection? Nine papers challenging the Health Professions Council proposals for the State Regulation of the Psychological Therapies"
Or return to the main homepage.
Thoughts on the Proposed State Regulation of Counselling and Psychotherapy by the Health Professions Council (HPC)
Oct 2009
The government have commissioned the Health Professions Council (HPC) to as the state regulators of counselling and psychotherapy in the UK. The HPC identify themselves as a regulator, established to 'protect the public', in their words. They currently regulate fourteen different health professions in the UK. At the current time, the only therapy (as in the counselling and psychotherapy sectors) which is regulated by the HPC is art therapy. All of the other regulated therapies are health professionals, such as occupational therapists, dieticians etc.
Oct 2009
The government have commissioned the Health Professions Council (HPC) to as the state regulators of counselling and psychotherapy in the UK. The HPC identify themselves as a regulator, established to 'protect the public', in their words. They currently regulate fourteen different health professions in the UK. At the current time, the only therapy (as in the counselling and psychotherapy sectors) which is regulated by the HPC is art therapy. All of the other regulated therapies are health professionals, such as occupational therapists, dieticians etc.