- Covid-19 Coronavirus Guidance - See the Covid-19 Hub
In order to ensure the guidance that we publish around the Coronavirus public health crisis is easy to find and navigate, we have created the Covid-19 Hub.
Please check the Hub for any future updates.
- 19th February 2021 NCS Open Letter to The Health and Social Care Select Committee
The NCS recently wrote an open letter addressed to The Health and Social Care Select Committee in response to the request for submissions regarding Children and Young People’s Mental Health. You can read it below:
- 11th February 2021 - NCS response to PSA Strategic Review Consultation
Please find the Society's full response to the PSA's Strategic Review Consultation here.
- 11th December 2020 - Consultation with the PSA
You will be aware that the Society holds an Accredited Register with the Professional Standards Authority and has done since 2012.
In our survey of 2018 an overwhelming number of our members supported the Accredited Registers programme and the Society continues to consider the programme to be the best way of delivering public assurance, as well as providing well deserved recognition for our members.
We and the other Registers have recently been meeting with the Professional Standards Authority and discussing the future of the programme as it enters its second decade.
The Authority has just launched a major public consultation on the future of the programme. Full details can be found here:
The key points in the consultation centre around how the programme could possibly be strengthened, giving more status to Accredited Registers and delivering more integration between Accredited Registers and our national health and social care programmes.
The main focus of the consultation is:
- How should we determine which occupations should be included in the scope of the programme?
- Should we consider the effectiveness of occupations in decisions about accreditation?
- Should there be greater consistency of standards of competence across Accredited Registers, in particular for individual occupations?
- Should we take into account proportionality and risk?
The Authority wishes to ensure the programme can:
- Support the delivery of NHS healthcare and social care workforce plans in England, NI, Scotland and Wales. This includes a greater contribution to personalised care for patients and to the Covid-19 recovery in health and social care. The pandemic has highlighted the need for greater integration of health and social care, and of the value of mental health care delivered by unregulated roles.
- Become a requirement for employers using healthcare practitioners in unregulated roles in the UK, and social care in unregulated roles in England
- Support innovation and be able to respond quickly to change. This is an advantage that voluntary assurance has above statutory regulation.
These are big questions. Of particular interest to members will be the question around consistency of standards for individual occupations. How might consistent standards be delivered in counselling, for example, while still assuring the diversity and complexity of the profession?
Another big question is over considering the “effectiveness of occupations.” To set some context here, members may be aware that a wide variety of complementary therapies (homeopathy, for example) are engaged with the AR programme. There are opposing views as to whether this is appropriate. On the one hand, the argument in favour states that offering an AR programme for complementary therapies ensures that practitioners are held to account and that complaints can be made. On the other hand, the argument against states that, where there is no evidence for a therapy, it is harmful to give what members of the public may consider to be a “seal of approval” from the AR programme.
Why this is a big question for counselling and psychotherapy is how is “effectiveness” to be assessed? Is it the same as evidence based or evidence informed practice? For counselling and psychotherapy these are loaded questions and we trust that the Authority will, of course, continue to view counselling and psychotherapy as a whole with many modalities and approaches, many of which are not appropriately assessed in a narrow empirical manner. We have no reason at present to believe otherwise.
Also of great interest will be that the Authority wishes being on an Accredited Register to be a requirement for employers using healthcare practitioners and practitioners in social care roles.
In the consultation document, the Authority references the concept of setting up a licensing body in order to ensure that unsafe practitioners could no longer practice. This, if applied to counselling, psychotherapy or hypnotherapy would see a fundamental shift from a voluntary scheme to one in which you held a licensing requirement to practice and your license could be revoked; for example in the event of a complaint. This, it is mooted, would be less of an imposition on practice than full statutory regulation while offering greater public assurance
The Authority also refers to a potential future for “umbrella bodies” where professional associations, perhaps, feed in to a centralised body for each occupation. Following current models, this could see, for example, NCS membership being a route to gaining your “umbrella body” licence. We are engaging with the Authority as to how this might work, but there would be a central role for current Accredited Registers.
The Society will shortly launch its own consultation with our members on the Authority’s proposals, so that we can submit to the Authority our members’ democratic views and be guided by your voices as things move forward.
We would like to end this bulletin with a note of reassurance to our members. We have been dealing with the Authority since 2010 and throughout that time, as a regulator they have been flexible, fair, professional and supportive. We have every confidence that the Authority will engage with Accredited Registers, and indeed Registrants, fairly and openly, that they will listen to concerns, and we trust that the AR programme will emerge in a strengthened form beneficial to our members in the long run.
- 9th October 2020 - SCoPEd Members' Update
Since April 2018 the Society has raised fundamental questions about SCoPEd and we referred in August 2020 to the issues with its Second Iteration. You can find all previous letters in this Important News section of the website.
In August we also stated that the collaborating partners appeared willing to consider including the wider profession and that together with 4 other Accredited Register holders, as previously stated, we invited concrete proposals for this.
We are now in the position to update our members on further developments.
The originating partners of SCoPEd have offered the NCS, together with the ACP, ACC, PTUK and Human Givens Institute, the possibility of participation in the project. The details of what this participation will mean are still being finalised and we await the outcome of discussions on various issues such as governance.
While remaining aware of the widespread opposition to SCoPEd as expressed by a large number of our members, the Society is willing to participate in the project subject to our full understanding of exactly what that will entail, and also, importantly, subject to our members' final approval of the outcome.
While we will attempt to influence and engage with SCoPEd in as positive way as possible, and to achieve as much positive change as possible, things remain unclear on a number of issues- for example, as to whether the widening of other Accredited Registers' participation in SCoPEd will allow for retrospective change to the current form of the project.
Whereas the Society agrees with the concept of common standards, it remains to be seen in which direction this project will evolve, and what impact the wider inclusion of five further Accredited Register partners will have on its final shape.
We continue to note particularly for example the concerns raised by the person centred community and remain concerned about the direction of travel that the project in its current form sets out for person centred counselling. We are seeking to safeguard this vital aspect of the counselling profession to ensure that any eventually agreed standards fully respect, understand and protect person-centred counselling. It is vital that common standards do not lead to a homogenisation or diminution of modalities in the future.
We are also engaged in the end result of the “scope” of SCoPEd. The project's rationale has been presented as largely about certain aspects of the workplace and specifically about ensuring counsellors and psychotherapists can integrate properly into the wider NHS "psychological professions" workforce.
If a shared set of standards can indeed increase work opportunities for our members then the Society is duty bound to explore this and report to you, our members, on any potential benefits.
However, fundamental questions remain about whether SCoPEd should simply be a mechanism for these specific workplace issues - such as for example "workplace certification", rather than a total overhaul of our membership grades or even further, as previously suggested, a fundamental change in the use of core titles such as "counsellor" and "psychotherapist." All these issues remain to be explored and you will have a say.
Our acceptance of participation in this project is primarily motivated by the need to ensure our members’ future unrestricted access to all aspects of employment opportunity - something you have asked us to view as the highest priority. We acknowledge that, with or without our participation, SCoPEd is likely to impact employer choices in the long term and it is our responsibility to protect our members’ rights and opportunities to work now and in the future.
The NCS did not create SCoPEd. However, If explicitly shared standards lead to further opening of opportunities for our members then you have the right to make a decision on whether the Society adopts these standards when we are in full possession of the facts.
The question of whether the eventual benefits of the NCS adopting SCoPEd in some form outweigh the arguments against such an adoption is for you, our members, to decide. We promise to ensure that all our members' views are heard and that our members understand all the arguments before making your decision.
In the meantime we will engage with this project in good faith alongside both the originating and new Accredited Register partners, and keep you informed on a regular basis as and when progress is made.
- 16th September 2020 - Open Letter to the Health and Social Care Select Committee
An Open Letter from the National Counselling Society:
Addressed to The Health and Social Care Select Committee: Rt Hon Jeremy Hunt, Rosie Cooper, Dr Luke Evans, Barbara Keeley, Sarah Owen, Laura Trott, Paul Bristow, Dr James Davies, Neale Hanvey, Taiwo Owatemi, Dean Russell
Dear Committee members,
We are writing from the National Counselling Society, one of the leading professional bodies for Counselling and Psychotherapy in the UK, to raise our concerns about the provision of counselling in the community. We ask your committee to look into this matter and would be more than happy to work with you to find ways to address this crisis. We are members of the APPG on a Fit and Healthy Childhood, chaired by Baroness Benjamin, and actively lobby for equal access to mental health services for all those in need.
There is an increased need for counselling to be made more readily available in the community following the emotional and psychological impact of Covid-19, Lockdown, and Bereavement. There is little or no funding for counselling services in the community, yet the demand continues to increase. There is a desire to provide emotional based counselling as opposed to the use of drugs for a number of issues.
Unfortunately, there is no co-ordinated approach or policy for the funding of primary care counselling. GP practices either have to use funds from their existing budgets or seek extra funding from their CCG. Whilst it has been shown to be cost effective in the long run to use counselling as an early intervention (Mental Health In Childhood, page 26-27), it has an immediate impact on the GP practices budget. It is estimated that approximately only half of the General Practices in England provide counselling services and support.
Claire Murdoch, NHS England’s national director for mental health said in 2018: “Joining up talking therapy services in primary care settings is another big step forward for our patients and a key plank in putting mental health at the centre of the long-term plan for the NHS. We are on track to deliver 3,000 therapists in primary care, with over 800 in surgeries at the end of last year and this handy guidance should convince those practices that are yet to take the plunge of the benefits.”(Mental health therapists in GP practices could be the norm, NHS England, 2018)
In 2018 NHS England published Guidance on co-locating mental health therapists in primary care and in the General Practice Forward View (2016) committed to investing in an extra 3000 mental health therapists in primary care by 2020. However, this investment was to be in the expansion of IAPT services and for the use of one of the IAPT specific modalities. Whilst the expansion is welcome, we are finding that experienced counsellors are losing their jobs within the NHS setting because they do not practice certain IAPT modalities. Thus the expansion appears to be at the expense of well-trained, qualified counsellors and psychotherapists who have a vital role to play in the community.
Indeed, current NICE guidelines recommend that clinicians should consider counselling for people with persistent subthreshold depressive symptoms or mild to moderate depression, and state that for all people with persistent subthreshold depressive symptoms or mild to moderate depression who are having counselling, the duration of treatment should typically be in the range of six to ten sessions over 8 to 12 weeks.
The General Practice Forward View had a stated goal to have an average of one full time mental health therapist for every 2 – 3 typical sized GP Practices. Putting aside the definition of a Mental Health Therapist and the benefits of person-centred counselling, this stated goal still fails to provide the funding for a growing mental health pandemic that the NHS has identified. The Guidance on colocating mental health therapists in primary care states, “the number of patients needing help with mental health problems is increasing. A survey of more than 1,000 GPs by charity Mind (June 2018) found two in five appointments involved mental health, while two in three GPs said the proportion of patients needing help with their mental health had increased in the previous 12 months. Research also shows that every week one in six adults experiences symptoms of a common mental health problem, such as anxiety or depression, and one in five has considered taking their own life at some point.”
We ask your committee to look at how targeted funding can be provided to General Practice surgeries to allow them to increase the availability of talking therapies for their patients.
Our members, and those on other Accredited Registers for Counselling & Psychotherapy, are already expert at providing the kind of support recommended in the NHS’ current advice. There are tens of thousands of highly experienced practitioners able to fulfil that need immediately.
The Accredited Registers programme provides assurance that those on the Register are qualified, supervised, insured, and that the Register holders themselves have evidenced that they meet the rigorous standards needed to hold such a Register. This is an initiative set up for the Department for Health and run by the Professional Standards Authority who also have oversight for Statutory Regulators; it is a legitimate programme that is already recognised within the NHS.
PSA Accredited talking therapy Registrants represent a valuable national resource, many with years of experience. We would like to see their skills being fully utilised to help those struggling with their mental health, and in turn protect our health service now and in the years to come.
- 28th August 2020 - Open Letter to NICE & the NHS
An Open Letter from the National Counselling Society
Addressed to Dr Adrian Whittington, National Lead for Psychological Professions at NHS England, Judith Richardson, Acting Director of Health and Social Care at the National Institute for Health and Care Excellence (NICE), and Amanda Pritchard, NHS Chief Operating Officer
We are writing to you from the National Counselling Society, one of the leading professional bodies for Counselling & Psychotherapy in the UK, to address some serious concerns that have been brought to our attention regarding talking therapies provided by the NHS.
As stakeholders within the IAPT programme we believe it is our duty to ensure that the programme is functioning to the best of its ability, respecting the skills and expertise of the practitioners that have been employed to provide the service, and acknowledging the excellent training and continual development that Registrants on Accredited Registers have undertaken.
It is pertinent at this point to provide a snapshot of talking therapy in the UK, including what we need, what we have, and how best to unite those two things.
We’re sure you’re aware that a recent release from the Office of National Statistics (ONS), updated on the 18th of August 2020, shows that:
- Almost one in five adults (19.2%) were likely to be experiencing some form of depression during the coronavirus (COVID-19) pandemic in June 2020; this had almost doubled from around 1 in 10
(9.7%) before the pandemic (July 2019 to March 2020).
- One in eight adults (12.9%) developed moderate to severe depressive symptoms during the pandemic, while a further 6.2% of the population continued to experience this level of depressive symptoms; around 1 in 25 adults (3.5%) saw an improvement over this period.
- Adults who were aged 16 to 39 years old, female, unable to afford an unexpected expense, or disabled were the most likely to experience some form of depression during the pandemic.
- Feeling stressed or anxious was the most common way adults experiencing some form of depression felt their well-being was being affected, with 84.9% stating this.
So what should we be doing about that?
Current NICE guidelines recommend that clinicians should consider counselling for people with persistent subthreshold depressive symptoms or mild to moderate depression, and state that for all people with persistent subthreshold depressive symptoms or mild to moderate depression having counselling, the duration of treatment should typically be in the range of six to ten sessions over 8 to 12 weeks.
Current advice from the NHS about what people should do if they are worried about coronavirus includes talking about our worries and staying connected with people.
The NHS Long Term Plan indicates that more funding will be allocated to mental health services over the next five to ten years, to “enable further service expansion and faster access to community and crisis mental health services”.
The situation is clear: we need to be providing six to ten sessions of counselling to those diagnosed with anxiety and depression. Furthermore, given that growing mental health services is a stated priority for the NHS, now is the time that we should be developing what we’re offering to the nation.
Our members, and those on other Accredited Registers for Counselling & Psychotherapy, are already expert at providing the kind of support recommended in the NHS’ current advice. There are tens of thousands of practitioners able to fulfil that need immediately.
The Accredited Registers programme provides assurance that those on the Register are qualified, supervised, insured, and that the Register holders themselves have evidenced that they meet the rigorous standards needed to hold such a Register. This is an initiative set up for the Department for Health and run by the Professional Standards Authority who also have oversight for Statutory Regulators; it is a legitimate programme that is already recognised within the NHS.
I trust you agree that all of the above makes sense, however we continue to receive reports of experienced counsellors losing their jobs in the NHS because they do not have the one particular accreditation or training (i.e. Counselling for Depression (CfD)).
NHS services are being told that counsellors who have not completed the specific IAPT Counselling for Depression training should not be offered work within the NHS because they could be "dangerous", despite holding more significant qualifications and having had years of experience in supervised clinical practice.
We urge you to consider that:
- There is no conclusive evidence that the particular trainings and accreditations currently favoured by IAPT are any guarantee of safe and effective counselling practice, nor that PSA Accredited Registrants are not equipped to provide the support so many now need.
- There is currently a large pool of safe, capable, registered counselling practitioners available at this time of unprecedented need for mental health support.
- It is unacceptable in the current climate, and in the future, to significantly impair overstretched services by including only practitioners holding a particular accreditation or those CfD trained.
PSA Accredited talking therapy Registrants represent a valuable national resource, many with years of experience, going to waste. We would like to see them given the acknowledgement and respect that they deserve, and being called on to provide their services immediately within the NHS to all those struggling with their mental health. We believe that doing anything less than this is a huge disservice to our entire nation, and look forward to supporting the NHS in rolling out a programme of support effectively using the Accredited Registers.
- Almost one in five adults (19.2%) were likely to be experiencing some form of depression during the coronavirus (COVID-19) pandemic in June 2020; this had almost doubled from around 1 in 10 (9.7%) before the pandemic (July 2019 to March 2020).
- 6th August 2020 - National Counselling Society Statement on Second Iteration of SCoPEd
In commenting on the first iteration of the SCoPEd project, whose claim to “set common standards for the profession” has been made by its three collaborating partners, the NCS in April 2018 made two key points:
- There were serious issues with a project apparently subscribing to hierarchical differentiations in our profession based upon three tiers of professional (counsellor, advanced counsellor and psychotherapist) which were assigned distinct competencies or “abilities”. Our member survey in 2018 revealed an admixture of competencies across the three potential tiers which did not match with the proposed standards. And:
- The exclusion of Accredited Register holders and other stakeholders from any meaningful participation in this project, rendered it incapable fulfilling its stated aim of setting profession-wide standards. Our conclusion was that any attempt to set standards for the profession must be accomplished by the profession, failing which SCoPEd is an internal exercise for those who wish to participate – albeit an exercise with, no doubt, far reaching consequences.
We have been asked by many members to comment on the second iteration of SCoPEd. We can confirm that we have been contacted by both UKCP and BACP to talk about SCoPEd and have had several informal discussions with BACP. These discussions have been mutually respectful while differences have been acknowledged.
On 21st July, the collaborating partners held an online meeting at which ourselves and other Accredited Register holders were present to discuss SCoPEd. We were invited to comment on the specifics of the second iteration.
We were concerned that this meeting was called only a few days after the second iteration was reached. We wish to place these concerns on record, particularly the lack of time to consult with colleagues or members. However, we do recognise the meeting as a sincere attempt at engagement by the collaborating partners.
A representative of the Professional Standards Authority was present in an observer capacity, and has also agreed to attend a meeting of the Partners for Counselling and Psychotherapy which will discuss a wider range of views.
During this meeting, we declined to comment on the details of the second iteration of SCoPEd when invited. This is because we do not see our role, or any benefit to our members, in being consulted in a context of exclusion. Other Accredited Registers present agreed.
We reiterated our position that SCoPEd is, at present, an internal matter for the three author organisations, albeit with widespread impact. If they wish to set standards “for the profession” then we believe that the correct method for this is, eventually, via the AR programme with participation from other stakeholder groups. Such standards could then, in principle, be adopted with the consent of the profession as a whole.
We continue to invite the SCoPEd authors to take the leap of faith required to include the wider profession. The collaborating partners now appear willing to consider this and this was discussed in the online meeting. Accordingly we and 3 other registers have jointly written to the collaborating partners asking for concrete proposals on this by the end of September, with the intention of establishing and adopting a structure for an inclusive approach by the New Year.
Our members have widespread concerns about SCoPEd and it is helpful now to frame some of these in view of the second iteration. The main questions raised by our members are as follows:
- How can we understand “Therapist A B and C” without context? Titles have been removed and we are left with “Therapist A, B and C.” However, BACP have confirmed that titles will be added back later in a form to be agreed by the 3 organisations. However, without understanding the intentions of mapping the three “tiers” onto membership grades or titles like “psychotherapist” it is impossible to gauge the effects of the project. Fundamental to SCoPEd would be a prior understanding of what this actually means for registrants, accredited counsellors, psychotherapists etc. What grades will these tiers connect with? What titles? What work? It is impossible to arrive at an informed view of the impact of SCoPEd without this understanding.
- Will there be an evidence based Impact Assessment? SCoPEd requires an Impact Assessment before implementation. Issues of power, work and social capital remain unaddressed. We note introduction of “gateways” which will enable therapists to progress from A to C. This feels like progress from the first iteration. But how much will this cost in practice in time and money? Who will be able to afford it? What jobs apply to which levels? Will this make getting work at Tier A easier or harder? How will this impact remuneration? Will it actually deflate wages? Is getting from Tier A to Tier B cheaper, easier and quicker than moving from “Registrant” to “Accredited” – or more expensive and harder? What about membership fees? Will the pressure to volunteer increase or decrease? It is normal practice in regulation to require an evidence based impact assessment to fully understand the impact of proposed changes on professionals before those changes can take place. This is especially important because it impacts human rights such as the right to work and have a professional life. Regulatory changes, even voluntary ones, must demonstrate that any impact on those subjected to it is proportionate to their rights and livelihoods.
- Will SCoPEd have unintended consequences for ethical practice?. For example, how do complaints processes and Codes of Practice fit in with SCoPEd? Does a Tier A therapist reported for using a Tier B ability (e.g. addresses “unconscious processes” cf 3.6.a) risk sanctions for attempting to work “beyond their capacity”? Can a Tier A therapist use a Tier B ability, or would they face sanctions? If this scenario was an ethical breach, SCoPEd in its second iteration could appear restrictive to, and unreflective of, lived practice. If it is not an ethical breach, then we acknowledge that all these abilities are in fact mixed in each individual practitioner, then how are the different tiers of practice to be meaningfully assessed or mapped onto ethical frameworks?
- How can we support SCoPEd without a clear end goal? What are the fundamental benefits for the profession (rather than the benefits accruing to the collaborating bodies by agreeing a mutual recognition scheme)? If it is jobs then which jobs? NHS workforce? If it helps with regulation, then how? What model of regulation is envisaged?
- Why aren’t standards set via the AR programme instead? Why not just work truly collaboratively to agree common standards within the only common framework that has ever been set up for this profession?
- How can we understand “abilities” or competencies without context? A Tier A therapist can “undertake team work”, but not have an “active role” in a team or express a professional opinion. (cf 1.12.) What’s the context here? A private clinic? A hospital setting ? A college? Private practice? Without context the current language appears to be distilled and decontextualized and, as has been noted, could actually cause offence (“you can’t express an opinion because you’re Tier A”). What’s the context of these abilities? Would language such as “service levels” make more sense? Or language about professional journeys? There is a need here for better communication of context and intention.
- Why does SCoPEd appear not to be modality neutral – particularly in regards to person-centred counselling? How would a person centred counsellor progress to Tier C when many of the abilities are framed in a manner which person centred counselling simply does not use? Do you have to change modality to access higher tiers? How are all modalities to be safeguarded?
- How can SCoPEd account for individual practitioner experience? Practitioners are individuals. As our previous members’ survey showed, members from all Scoped iteration 1 tiers professed and admixture of abilities across the range of mapping columns which Scoped provides. How is individuality and individual development taken into account? In reality, what happens to practitioners who can do 100% of column 1, 40% of column 2 and 30% of column 3? How does that work? How does Scoped provide for individual differences and acknowledge that the wide variety of individual practitioner experience which may not be easily reflected in their training?
The above represents a sample of our members’ most often repeated key concerns.
The Society will continue to engage with the Collaborating Partners and our members on all of the above. We will continue to signpost all aspects of the SCoPEd debate to our members.
August 6th 2020
- 1st March 2019 - Survey Results on Key Issues and Policy
We have surveyed our members for their opinion on key issues regarding the profession. The full report can be read below, including how the Society has responded to our members voices.
- 1st March 2019 - SCoPEd Consultation Response
Letter to BACP, UKCP and BPC Re: SCOPED
To Whom it May Concern;
The National Counselling Society has now concluded a consultation with our members on competencies within counselling and psychotherapy. Full details can be found HERE on our website.
Members were asked a series of questions on proposed competencies for the profession based upon the framework established by the Scoped consultation. Members were asked to consider which competencies should be reserved to “advanced counsellors” which we defined as those having received our Professional Accredited grade (or equivalent) and/or for psychotherapists. We sought to establish how our membership at large views their actual competencies to practice in specific areas.
Our methodology was to list those competencies which your draft SCOPED document reserved to advanced counsellors and/or psychotherapists, and ask our members to express their professional judgement as to whether these competencies should be so reserved.
Our members’ professional judgement as to the competencies which actually apply in counselling and psychotherapy do not support the draft Scoped document.
On the contrary, in essence as our consultation demonstrates, the competencies reserved by that document for psychotherapists or advanced counsellors are actually, on the examination of professional counsellors’ actual lived experience, competencies which hold true for qualified counsellors also. Our members’ view is that the differentiation of these competencies into three purported levels is contrary to how the profession actually works.
We invite you to reproduce our consultation exercise with your own members to take their detailed views on the draft competencies on a question by question basis.
In addition, it is worth alluding to our many members’ who have stated that this kind of competency framework has no resonance with their practice or modality. We recognise this and reconfirm that our conducting this exercise was not the prelude to adopting such framework.
The Society takes instruction from our members on matters of policy, and we view our consultation with them as instructive in this regard. On instruction from our members, therefore, the Society does not believe there is an evidential basis for distinguishing three tiers of professional competencies along the lines of “qualified counsellors, “advanced counsellors” and “psychotherapists”. Our members confirm that, irrespective of professional title or membership grade, that they are able to demonstrate competencies across a framework without generally reserving those competencies.
The Society therefore considers that your draft competency framework creates artificial distinctions not reflective of practice or training, and clearly contrary to the expert evidence already set before the HCPC by BACP in 2009.
The Society reconfirms its position that while we would welcome common standards across the profession, this can and should be achieved through the Accredited Registers programme, reaching common agreement amongst all Register holders and other important stakeholders, in full consultation with members and trainers, that can be communicated to the Professional Standards Authority. It is only through such an inclusive approach that any “public confusion” would be fully addressed and the maturity of the profession be communicated to the wider world.
Accordingly we invite you to participate in a new, inclusive approach to set out common standards agreeable to all.
National Counselling Society
- 8th February 2019 - SCoPEd: AN OPEN LETTER TO BACP by the NATIONAL COUNSELLING SOCIETY
Read our full response in the below document.
- SCoPEd: Open Letter to BACP (1MB)
This document requires the free Adobe Reader software (or another, compatible PDF viewer).[link opens in a new window]
- SCoPEd: Open Letter to BACP (1MB)
- Members Survey on Regulation – The Results
What do our members think?
We asked our members for input about an important issue facing our profession.
The Society consulted our members to determine if there is a settled view amongst our membership regarding the issue of counselling regulation.
The last time we asked our members to comment on this issue was prior to the then proposed statutory regulation of counselling via the Health and Care Professions Council approximately ten years ago. At the time, our members, by a substantial majority, opposed HCPC regulation. The NCS, alongside other organisations, were successful in challenging the plans, including via a successful Judicial Review. A change of Government then led to the decision to create the Accredited Registers programme.
However, we have now worked under the Accredited Registers (AR) programme for six years. The programme has had time to develop and so we are able to look at the results and weigh up the pros and cons of the programme.
In addition, there are still those who support statutory regulation. For example, in the wake of the Government’s survey on conversion therapy, some Members of Parliament made renewed calls to regulate counselling via the HCPC in order to prevent counsellors from offering this therapy. In addition, there are those who pose the question “how do you stop an unsafe counsellor from practising?” This is a question which needs to be addressed by those supporting a voluntary scheme.
It is important for us, therefore, to understand the views of our current membership in order to ensure that our policies take into consideration your voice and views.
Below are the options we set out to our members for the possible options of regulation in the future as we saw them, with some pros and cons by each option.NB the pros and cons are offered as views commonly shared by proponents and opponents of the options whilst debating the issue, and do not necessarily reflect the views of the Society.
We included a brief impact assessment with each option which helps explore how the option could work in practice and how it could affect you as a counsellor or psychotherapist.
Option 1: Keep the AR programme as it is, as a voluntary programme
Impact: You can choose whether or not to join any organisation. Unsafe practitioners can't be stopped from practising unless they commit a criminal offence.
- Popular scheme with counsellors
- Protects diversity of practice and experience
- Keeps the profession at the heart of regulation
- Risk assessment of counselling is low risk with low numbers of non-compliance
- Profession has already invested vast resources in the scheme (as well as public money)
- Anybody removed from an Accredited Register is published on the respective Accredited Register's website and cannot join another related Accredited Register under standard 10e
- The profession can't prevent a struck-off counsellor from practising
- The responsibility is on the public/client to source ethical counsellors
- Accredited Registers can have widely different ethos
- Not enough standardisation of practice
- What happens when two complaints procedures produce different outcomes?
- Maintaining a voluntary scheme vulnerable to the wrong sort of regulation in the future.
Option 2: Keep the AR programme, but make it compulsory for counsellors to be on an AR.
Impact: You will have to be on an Accredited Register to practice. Unsafe practitioners can be stopped from practising by being removed from the AR programme (complaints are likely to have an independent process to ensure registrants can't be removed unfairly).
- Gives counsellors a choice of Register, even when compulsory
- Keeps the profession at the heart of regulation and allows good standards to flourish
- Protects the title "counsellor", "psychotherapist" etc
- Prevents struck-off counsellors from practising
- Ends the need for a debate on statutory regulation
- Need for standardisation of different registers' complaints processes
- Not enough standardisation of practice
- Need to ensure that Accredited Registers' decisions are open to independent review and appeal
- Primary legislation required
Option 3: Keep the AR programme voluntary but with a "negative register" e.g. the DBS scheme
Impact: You can choose whether or not to join any organisation. Unsafe practitioners can be banned from practice by being barred or added to a "negative register." This process would be independent of the profession.
- All the pros of the AR programme as already described
- Prevents unsafe counsellors from practising
- Has been discussed by the Authority
- Decisions removed from the profession
- Too complicated - why run two processes.
- DBS scheme not set up for private practice
- DBS scheme would need primary legislation to adapt
Option 4: Keep the AR programme voluntary but create a new over-arching licensing body
Impact: You can choose whether or not to join any organisation, but need to obtain a separate license to practice. This would be easy to obtain but would incur additional costs. Unsafe practitioners can have their license revoked and thus can be prevented from being able to practice. This process would be independent of the profession.
- Potentially low cost and easy to obtain
- All the benefits of the AR programme as already described
- Licensing could be extended across all health and social care professions
- ARs can refer complaints outcomes to licensing body
- Licensing body can act on its own, e.g. after criminal complaint
- New licensing body would require time and money to create
- Is there political will and funding for a new creation
- An extra layer of red tape for counsellors
- How to juggle AR complaints with licensing body complaints
- Is there political will or funding for a new licensing body.
Option 5: HCPC regulation
Impact: You will have to register with the HCPC and ensure that your qualifications and continued practice meet the standards they set. This would incur a fee to the HCPC. Unsafe practitioners can be prevented from being able to practice by removal from the HCPC register. The AR programme would end with standards and complaints done by the HCPC rather than professional associations.
Details – Members were surveyed and given the option of making their top 3 choices in order of preference. Left to right = 1st choice , 2nd choice , 3rdchoice , No opinion
Members were also given the opportunity to make individual comments, and we have included a wide range of comments made anonymously.
I strongly vote and urge for NCS to do something .perhaps Option 5 is the way forward, to join the forces with HCPC as at the moment BACP is monopolizing everything. Wherever I go for work or seminars or CPD, if I am not BACP or HCPC accredited, public looks upon with a little credit or respect on NCS. We need a strong pathway and this is possible with HCPC.
The current DBS scheme is not a full proof method - it needs to be maintained to have any value and also a person could 'offend' just after receiving the DBS .therefore, although helpful, it will not solve this problem and adds another red tape layer of complication. If a counsellor works within an organisation it is probable that they would have a DVD via the organisation anyway.
In addition much emphasis on qualification may emerge with any new legislation. Whilst I believe in suitably qualified counsellors, the emphasis shifts to just that rather than an ability of the person to be totally congruent and more importantly to have worked sufficiently on their own issues in training. I see many clients who have seen other qualified counsellors who have not acted in congruent way, leaving the client confused and hurt.
Option 1: would prefer this to remain but it has flaws and it leaves it open for future pushes for regulation.
Options 2: seems to be a positive step up from option 1 but would need standardisation.
Option 3: how would clients access the 'negative register' information for private therapists? Clients are not always capable of looking for this information, they don't always use the professional organisation websites to find therapists as it is.
Option 4: this looks like a positive option as far as clients are concerned as the therapist would presumably have a physical form of this license to show to them or organisations. I liked the idea that it could be extended across other health/social care professions. My concern that stopped me listing this option as my first choice was the time/money that would be needed to implement. If this idea was pushed forward would it be used by the government as a way to push the HCPC regulation through instead.
Option 5: is just a no!
Whilst I don't favour regulation I agree there is definitely a large movement towards it.
The HCPC register is geared towards healthcare professionals and counsellors/psychotherapists don't appear to meet all of their "health care" criteria.
I am strongly committed to our profession not being overtaken by the medical model - which I fear HCPC will inexorably move towards.
I think it's really important that all the membership bodies are visibly seen to have equal status by the public.
I am also against any MB being allowed to promote itself as 'the leading body of our profession'.
It would be good to introduce something that will iron this out and prevent any MB from assuming an inflated sense of authority.
I do think we should have to be PSA registered to practice.
I would like to be known as a PSA Snr Accredited counsellor/psychotherapist who is registered with NCS.
I am still unclear as to how this can happen.
I think it's important to be able to keep the diversity within our profession as this allows for counselling to creatively move forward and progress.
I am not against being licensed or DBS checked if it will help counsellors to increase their professional status.
I definitely don't want to see HPCP regulation.
I feel that with any big decision like this that the emphasis should be on the safety of the customer e.g. clients, particularly as where counselling is concerned we commit to doing what is in the best interests of the client.
As the accredited register is already in operation and is common across all counselling associations e.g. BACP, UKCP etc., we already have something in place that acts as a standard and shows any potential client that the counsellor has received appropriate training. The only bit missing is that it is not compulsory for counsellors to be on this register to practice.
Therefore making it compulsory for any counsellor to be on an accredited register seems to me to be the simplest, most cost effective way for the profession to become more regulated, without the need for lengthy, costly and complicated new rules and regulations.
My view is that the current AR scheme works and works well. Unless there is compelling evidence to change something (which I haven't seen produced by anyone) why change something that is actually working, the allows for a degree of flexibility, that is affordable and for which there is NO evidence that it is being abused.
Options 4 and 5 seem to allow counselling to become dominated by the HCPC and medical model. I strongly prefer options that allow variety in counselling practice, and recognition that the counselling relationship is an important aspect of the work. I prefer self-determination by counselling professions.
I feel it would be more prudent to putting in effort to ensure the public ask the right questions and ask for evidence regarding each counsellor. Most counsellors would want accreditation and to practice in a professional manner and be happy to share their training route, supervision, CPD, Insurance, accreditation.
There will always be those few, as in any industry, who are dishonest. Educate the public to do their research into their prospective counsellor and the right questions to ask.
I found it hard to prioritise my 3 preferred options as they all had valid pros and cons, plus weighing up potential benefits for therapists/organisations and clients could work in opposition at times
Option 1 is not an option.
Option 3 likewise - it only excludes people who were on it in the first place - the problem is primarily people who are not / cannot be on an AR.
Feel the HCPC regulation option would not eradicate unsafe practitioners but would discriminate against some or many good practitioners who did not meet the HCPC Qualification standards set.
Option 2 would be my preferred choice. It maintains the standard of the profession as those who are struck-off cannot continue to work. I think it is vital that the profession is kept at the heart of regulation to ensure there is a real understanding of our role and that those who are currently practising effectively and ethically are not penalised by new legislation which may require a higher level of qualification.
I would like to positively NOT choose options 4,5 (i.e. it is not that I have no preference) - this form does not allow me to indicate that.
I think the existing AR program is a good thing. Especially the NCS has an excellent service for its members. I don't know how this could be improved through more regulations.
I know counsellors and therapists who do this work for years, but still I would not feel safe with them.
Putting more and more regulations does not necessarily improve therapeutic quality, since regulations will never be able to really value the true personal development of a counsellor or therapist.
Option 5 is really the only option I favour. I have only stayed 2 other options because I have to.
A lot of work has gone into the present system. It is not perfect, but neither are the other options. I think diversity of practise is a key issue. Counsellors work in very different ways, as befits their personality and experience, and a range of ARs facilitates this. I believe that spending a lot of time, effort and money on other approaches is wasteful, because it will not make things a lot better. As the saying goes: "If it is not broke, don't fix it".
Both Option 3 and Option 4 require either a significant adaptation (Option 3) or significant work to create (Option 4). Both, I'm sure would require extra cost to set them up and maintain. This would put further pressure on counsellors to fund these I suspect.
Option2 is the only viable and sensible Option especially given the work that has already gone on over the last few years to reflect on and create the accredited voluntary registers with all their positive elements..
I believe that the introduction of licensing for counsellors would help weed out those who are deemed unsafe/unfit to practice.
Option 5 would be a disaster for the future of counselling, for both clients and practitioners.
My main concern with option 4 is that other professions under the same regulation will be able to sway policy and may not understand the principles at the heart of our proffession
IMHO its a question of balancing public protection with therapeutic flexibility and public choice. I think option 2 is the only one that really offers this; assuming that the status quo will not remain.
I think you are taking the wrong approach in looking at what suits counsellors - I think this needs to be viewed through the lens of the client and offer maximum protection to them, In addition I also feel that the counselling is not cuurrently given the same level of respect as other professions and this would change if the profession comes under HPCP
Being brought under the HCPC shows we wish to be considered equal to all the other protected health professionals and are prepared to be treated the same as they are. The message and confidence that gives clients far outweighs any inconvenience we may have. Graduate entry should be the minimum with courses approved independently and retrospectively by the HCPC. The BACP can then be put out of its misery.
I choose compulsary AR programme, on the proviso that this maintains existing choice, and potentially broadens choice. The current PSA requirements seem absolutley enough as they are, and leaves room for increased diversity of AR providers.
I would prefer statutory regulation of the profession and protected title. That said I doubt whether any future government could afford to invest in statutory regulation of the profession. I consider that employers would be more interested in employing counsellors if we held statutory titles.
As a social worker I am regulated by the HCPC. It is cumbersome, expensive and overly bureaucratic and does nothing to support practitioners, only punish them. I would be totally against having to register with them as a Counsellor.
I like the idea of separate licensing in addition to AC register. It feels as safe and as structured as possible without the potential negative restrictive cons of full governement regulation.
If there must be change, as seems to be the case surly option two would serve the profession best as it maintains our present form of regulation but as you said makes it compulsory for counsellors to be on an AR. If acceptable a win, win for service users, practitioners and for the profession as a whole.
I feel the current AR programme is working well but fear further regulation in the future, therefore I feel it would be better to move to a compulsory scheme while we still have influence over our own profession. I don't believe titles need to be protected, I believe public awareness of the AR needs to be increased so that clients can make their own informed decision as to who they work with.
I feel that statutory regulation is needed. I don't believe that it will impact diversity and creativity in the field. I believe that the profession will be taken more seriously at a time when I see counselling provision being replaced with 'wellbeing and 'signposting services. Counselling has become too general a term and something that can be incorporated into other professionals roles rather than a specialist intervention by skills practitioners
Anything that attracts extra cost will be very hard for therapists - it is already a tough market to be in and in many cases unless there is an additional source of income, impossible to survive on a therapists income alone.
I am qualified in a range of fields on on various registers. My concern is unintended consequences. Over regulation could become problematic for many charities offering counselling. I am already HCPC registered psychologist and it has only protected specific titles - anybody can still call themselves a 'psychologist'. A new over-arching licensing body would lead to less practitioners being members of professional bodies. The current PSA system works (& do note that the PSA regulates HCPC).
Titles need protection. There must be legislation to prevent unqualified people practicing. This could enable equality across the bodies which there is not at the moment. May also bring a minimum standard and quality of training.
I am definitely not in favour of the licence option. I believe Counsellors have enough to pay for as it is with ongoing CPD, insurance and register memberships. We also have a lot of paperwork to keep on top of as it is and I feel that the licence option will increase this future potentially causing more stress and burn out.
In Conclusion – Our thoughts
NCS members in general appear to support the Accredited Registers programme as it stands, but a majority of respondents wish to go further and make the programme compulsory (put it on a statutory footing) in order to further protect the public. Whereas 44% of members are happy (first or second choice) to maintain the status quo of this voluntary programme, we have a clear indication (81% first or second choice with 53% first choice) that our members view making the Accredited Registers programme compulsory is their preferred direction of travel.
As a member-led organisation, this survey will be put to Society Council for ratification that the Society’s official policy on regulation shall be to support the adaptation of the existing Accredited Registers programme from a voluntary programme into a statutory requirement of practice.
The Society believes that this approach will best balance equality and diversity in counselling and allow many different approaches to publish, with the ability to prevent unsafe counsellors or psychotherapists from practice and protect the public where necessary.
- June 2018 - Update regarding SCoPEd
We have received a response to our further request of an inclusive approach to SCoPEd project. Unfortunately, we are disappointed to see that it seems the collaboration are unwilling to discuss with the wider profession, we shall continue to monitor developments and of course provide updates ourselves.
11th June 2018
Thank you very much for your email setting out your further concerns about the SCoPEd project.
As you know this project evolved from work already being undertaken as part of the collaborative work between BACP, BPC and UKCP. Our three organisations have been working together for some years as part of a formal collaboration – the CCPP. This project is one of several things we are working on together.
ScoPEd is not creating anything new – it is an evidence-based research project mapping existing competences and professional standards. So, the project will set out what already exists. We hope that in the future a wide range of bodies will find the generic competence framework useful.
Thank you for getting in touch. We appreciate your feedback.
Chief Executive BPC
(signed on behalf of the SCoPEd Steering Group)
- May 2018 - Response to open letter regarding SCoPEd
Following our open letter (which can be found further down this page), we have now received a response from the SCoPEd collaboration.
Thank you for your letter which was discussed at our Steering Group meeting on 25 April. We are pleased to hear that you recognise what an important piece of work this is but it is not exactly as you state. The project evolved organically from the collaborative discussions between our three professional bodies over the last few years and is specifically to map the current landscape, expressed in evidence-based generic competencies and then to identify any gaps or areas where further clarification is needed using the Roth and Pilling methodology. It is not about developing standards. We have researched the evidence comprehensively and systematically, and continue to do so, in order to ensure that a complete a picture as possible is drawn.
Once the Expert Reference Group has completed its work there will be a consultation with practitioners and external stakeholders. Although the exact form of the consultation has yet to be decided, it will be presenting the work done so far and asking for feedback and input on any further gaps or omissions.
Chief Executive BPC
(signed on behalf of the SCoPEd Steering Group)
The response concerns ourselves and we are very surprised that the response letter claims that the SCoPEd project is not intended to set standards for the profession. It specifically states on both BACP and UKCP websites that 'BACP, BPC, UKCP are jointly working on a groundbreaking project to set out the training requirements and practice standards for counselling and psychotherapy', in the very first sentence, as well as the below statements;
'There was complete agreement between BACP, BPC, and UKCP that a proactive leadership role was needed in the development of generic standards for the counselling and psychotherapy professions.'
'The project is systematically mapping existing competencies, standards, training and practice requirements within counselling and psychotherapy.'
Clearly, the publically stated view of two of the scoped collaborators is that this project is seen by them as a fundamental attempt to "set standards for the profession" without prior consultation or consent with the profession at large.
Accordingly, we have renewed our request in our previous letter for an end to the non-inclusive, ringfenced and top down approach to professional standards, and call upon the collaboration to engage with us and all other interested parties within the profession, to move the profession forwards to an inclusive and democratic approach based upon the good of all.
- April 2018 - Society Response to SCoPEd project
You may have seen the recent announcement by BACP, UKCP and BPC working on a project to set out the training requirements and practice standards for counselling and psychotherapy.
‘Counselling and psychotherapy are not statutorily regulated. Professional bodies can apply for their own registers to be accredited by the Professional Standards Authority (PSA) under its Accredited Registers programme.
The PSA sets standards for organisations that hold a register in a health or social care profession, and the focus of their programme is public protection.
The PSA-accredited registers in the field of counselling and psychotherapy each has its own distinct standards of training and practice. There are also no agreed common entry or training requirements to enter the field.
This causes confusion for the public, for clients/patients, for employers and commissioners of services about what training and experience to expect when employing a counsellor or psychotherapist.
There is also confusion amongst those who are considering training in this field as there are disparate standards, with a wide range of courses available at differing academic levels geared to different client groups and professional roles, and sitting within different qualifications frameworks’
Whilst we agree there need to be minimum standards for any registrant working with the public, we are concerned that there has been no consultation or discussion amongst fellow Accredited Register holders, training providers, organisations or importantly its members – despite the collaboration being near completion on their project.
We wanted to make you aware we have responded with the below open letter. We shall also be in contact soon with training providers and members to further discuss this important issue.
We welcome any training providers and organisations to add their details in support, members or not. Please do contact the office, details will be updated in due course.
Re : SCoPEd project
We write to you concerning your stated intention to develop “generic standards for the counselling and psychotherapy professions”. You write that “the PSA-accredited registers in the field of counselling and psychotherapy each has its own distinct standards of training and practice. There are also no agreed common entry or training requirements to enter the field. This causes confusion for the public, for clients/patients, for employers and commissioners of services about what training and experience to expect when employing a counsellor or psychotherapist.”
Our view is that any project to set common standards should be fully inclusive from the outset, with full and equal participation by all Accredited Register holders in talking therapies, alongside other stakeholders such as the Psychotherapy and Counselling Union, Alliance for Counselling & Psychotherapy, Awarding Bodies and training organisations.
It will, surely, only cause further “public, client and employer confusion” for three of the current Accredited Register holders to agree their own new set of standards without reference to the AR programme, especially when NHS guidelines are now focussed on recommending the programme as the one supported by Government.
In addition, we feel that any new setting of standards should be done with full democratic participation by the memberships of stakeholder organisations, using a member-led approach, rather than a top-down approach.
Without these safeguards in place, the SCoPEd project will not succeed in setting standards for the profession, but rather, will be an internal exercise conducted on behalf of particular organisations for their own ends, conducted to the exclusion of many. You are of course, welcome to set standards for yourselves – but not to claim that these should be imposed on, or represent, the profession as a whole, without having equal participation and full support from the wider profession.
We are also concerned that the project could lead to further homogenisation, over -regulation, and further control mechanisms being applied by professional associations on their members. Instead, we would seek to enshrine equality, diversity and the heart of counselling and psychotherapy in any further attempts to define standards. A mechanistic, technical and manualised understanding of therapeutic work can never do justice to the reality of how we practice. We believe a pluralistic approach respectful of diversity, variety and individual client choice is fundamentally important, whilst of course maintaining standards and public safety.
We are also concerned that, unless handled sensitively, any such project could easily lend itself to takeover by a corporatist style of regulation where the profession risks fundamental change with no benefit to counsellors, psychotherapists, or their clients. Do we really want even more prescriptions and controls on practice than there are now?
You speak of the need to avoid “public confusion”. We are not aware of any great public confusion. In the employed sector, counselling in any case has been to some extent bypassed by IAPT where a very limited number of approaches are used in a very prescribed way. This has led over time to a fundamental under valuing of counselling and psychotherapy in its richness and diversity. What we are aware of is the public wishing to preserve choice with access to therapy in a timely manner – to select the practitioner and approach that is right for them; to be able to see value in the therapeutic relationship above and beyond issues of professionalisation. We are also aware that counsellors and psychotherapists seek to preserve choice and diversity, and feel that there already exist robust and appropriate standards which allow a place for individuality, creativity and vocation alongside public protection and good practice. These can be fine tuned by the profession as a whole.
There are already existing standards and reference points including the QAA Benchmark Statement on Counselling and Psychotherapy, The Framework for Higher Education Qualifications, the Regulated Qualifications Framework, Skills for Health National Occupational Standards and the UCL CORE competence frameworks which are not “owned” by any one professional body. These, together with the standards adopted by individual professional bodies, are surely sufficient.
While any organisations are, of course, welcome to collaborate and devise their own standards, what is concerning is that, at the very time that the Accredited Register programme has begun to flourish and allow all register holders to meet, cooperate, and learn to improve standards and governance with the assistance of the Authority, your collaboration threatens to ringfence your own memberships from the wider Accredited Register community, not to mention missed opportunities for equal participation from other stakeholders. The chance to set standards as part of, rather than taken away from, the Accredited Register scheme would have far greater benefits for the entire profession.
We support minimum standards for the profession – if they are, indeed, created by the profession as a whole. The risk of setting standards in a vacuum is that it is seen as an internal political exercise. This risks greater confusion – not less.
With support of -
Jeffery Thomas and Monika Jephcott, PTUK
Tony Ruddle on behalf of Association of Christian Counsellors
Dominic Davies, Pink Therapy
Andrew Samuels, Former Chair, UKCP. Professor of Analytical Psychology, University of Essex
Alliance for Counselling and Psychotherapy
Psychotherapy and Counselling Union
Professor Michael Jacobs
Gail Evans, Programme Director at The Academy: SPACE
Leigh Smith, Heartwood Director
Karl Gregory, Severn Talking Therapy
Kathy Raffles, Kathy Raffles Counselling Services
Marie Easden, Chrysalis Courses
Nathalie Asmall, BACP Accredited and Iron Mill College tutor
Professor Stephen Joseph, University of Nottingham
Dr David Murphy, University of Nottingham
Dr Sue Price, University of Nottingham
Lindsay Cooper, Assistant Professor of Counselling, Course Leader BA (Hons) Humanistic Counselling Practice University of Nottingham
Dr Katy Wakelin, University of Nottingham
Laura Davies , University of Nottingham
Dr Laura Monk, University of Nottingham
Kris Black MBACP, UKCP CSTD, IAP, MISA, LLB (Hons)
Denise Gregory MBACP (Accred)
Phil Turner MBACP (Accred)
Amanda Young Dip Counselling
LouAnne Lachman MBACP (Accred)