SCoPEd

The six SCoPEd partners are providing this update on the important work currently underway with regards to the SCoPEd framework implementation, governance and impact assessment.

The scope of practice and education for the counselling and psychotherapy professions, known as SCoPEd, is a partnership which has developed a competence framework that maps the core competences and practice standards for counsellors and psychotherapists working with adults. It was adopted in February 2023 by the following six organisations who all hold Professional Standards Authority (PSA) accredited registers:

• Association of Christians in Counselling and Linked Professions (ACC)
• British Association for Counselling and Psychotherapy (BACP)
• British Psychoanalytic Council (BPC)
• National Counselling and Psychotherapy Society (NCPS)
• Human Givens Institute (HGI)
• UK Council for Psychotherapy (UKCP)

Our shared vision is for the profession of counselling and psychotherapy to be better understood, valued and trusted by clients, patients, employers, commissioners and society.

The SCoPEd framework can be viewed on our website.

Implementation

As announced in February 2023, the SCoPEd framework has now been adopted by all six partners and activity to implement the framework across all the partners has started. This includes:

• work so all partners’ membership categories are fully aligned to the standards of the SCoPEd framework by early 2026
• agreed mechanisms to enable movement of membership categories and SCoPEd columns, where appropriate and if members and registrants wish to.

It’s important both these are in place to ensure equivalence of the SCoPEd column standards across partners’ membership categories.

The SCoPEd framework maps the minimum standards required for each of the columns and it’s important to note that some partners may have additional criteria which they require to be met.

The framework will be implemented using the column titles A, B and C. In the future, the partnership may consider changing these titles, but work on the titles would not be about identifying or creating protected titles. It would be about ensuring consistency and reducing confusion across the profession.

Impact assessment

Since announcing the adoption of the SCoPEd framework, partners have been reviewing and developing work from the impact assessment report recommendations.

To recap, the impact assessment:

• was conducted by an independent company in 2022
• comprised of interviews with various stakeholders including clients and patients, practitioners, trainers, awarding bodies, employers and commissioners, membership body staff, and the Professional Standards Authority (PSA)
• took into account a variety of viewpoints, including critical voices from those within counselling and psychotherapy, some of whom were contacted due to their specific skills and experience, including professional networking and campaign groups
• involved statistical consideration of some of the data held by partners and data in the public domain.

The impact assessment report, available to view here, prompted reflection on how the governance of SCoPEd has been structured whilst developing the framework. This has led to a decision to re-structure the governance in recognition that the framework is now adopted by all partners and the focus needs to be on implementation. More information on the new structure is detailed below.

Two of the key pieces of work, identified by the impact assessment, that the new governance structure is focused on delivering are:

• development of a minimum data set for prospective collection and publication by the partnership, to include demographic data on the make-up of the profession and using the protected characteristics identified in the Equality Act 2010 as a guiding framework
• work to enhance communications and engagement, such as establishing a partner website and a stakeholder engagement group.

The partnership will issue updates on these pieces of work as they progress.

Governance

To support the implementation phase of the SCoPEd framework, the partners have collectively agreed to restructure the governance of the SCoPEd partnership to better meet the needs of the current work.

There are four SCoPEd governance groups; the CEO Board, Delivery Group, Clinical Group and Communications Group which replace the previous groups (the SCoPEd Oversight Committee, the Technical Group, and Expert Reference Group) with immediate effect.

CEO Board
The CEO Board provides strategic leadership. It is made up of all the partner CEOs and is independently chaired. Experts by Experience (EbEs), Delivery Group members and the chairs of the Communications and Clinical Groups may also attend to offer advice and input.

Delivery Group
The Delivery Group includes a chair, a project manager and communications lead. With the exception of the chair, all members are from partner organisations. The Delivery Group is tasked with moving forward the actions agreed by the CEO Board.

Clinical Group
The Clinical Group’s main purpose is to help maintain the standards of the framework and provide advice on any future updates or amendments. It includes representatives from each of the partner organisations.

Communications Group
The Communications Group includes representatives from each of the partner organisations and is responsible for developing a joint partner communications strategy and delivering communications in relation to the SCoPEd framework, along with any associated future workstreams.

This new structure will enable the partners to continue their work regarding the SCoPEd framework, as well as other workstreams, including the NHS Pathways project, a pilot programme accredited by five of the SCoPEd partners to provide fully funded training for psychotherapeutic counselling within the NHS Talking Therapies for anxiety and depression services.

More information about these groups is available in the appendix.

Next Steps

Alongside the work already described above the partnership will also:

• consider a programme of work to raise public awareness of the SCoPEd framework
• work with stakeholders to advance the professions of counselling and psychotherapy
• continue to strengthen already established links with our partners in the NHS.

We’re looking forward to continuing to collaborate on this hugely important initiative and will be providing members and other key stakeholders with regular updates on our work in the future.

If you have any questions, please contact your membership organisation via their usual channels.

SCoPEd partner CEOs

Kathy Spooner, ACC

Phil James, BACP

Greg Ross-Sampson, BPC

Malcom Hanson, HGI

Jyles Robillard-Day, NPCS

Jon Levett, UKCP

Dear Member,

As you will be aware, in February our members voted to adopt the SCoPEd framework. We are now writing to you to provide an update on our implementation plan. By the end of the implementation period all membership categories will be mapped to the SCoPEd framework. During this process we will be updating our website and applications forms so that they match the SCoPEd framework.

Our implementation plan has three clear stages:

Stage 1: Preparation (now – January 2024)

We are now preparing for the transition period. This work includes:

• Agreeing mechanisms with our partners to allow members to move between the columns whilst the work is being finalised for full implementation.
• Creating application forms to reflect the transition process. This will be shared with members in September.
• Liaising with our accredited training providers to gather information about what they need to fully align to SCoPEd Column A, if they are not already.
• We will temporarily close our Senior Accredited Professional Registrant scheme on 1st May 2023 and our Professional Accredited Registrant scheme on 30th September 2023. Both of these will re-open for applications using the transitions mechanisms on 2nd January 2024.
  

Stage 2: Transition (January 2024 – January 2026)

• During the transition period members will be able to move membership categories using the new temporary mechanisms. These mechanisms will allow our members to evidence the training, skills and experience needed for each membership category.
• The transition mechanisms and procedures will be published in September 2023.
  

Stage 3: Integration (January 2026 – onwards)

• Entry requirements for all NCS membership categories will be fully aligned to SCoPEd. Accredited Registrant will align to column A, Accredited Professional Registrant to Column B and Senior Accredited Professional Registrant to column C.
• New schemes and routes, mapped to SCoPEd, will open, offering our members a number of different ways to move membership category.
• New accreditation routes will reflect training and experience gained through practice and CPD.
  

How does this affect "Specialist Registers"?

By the end of the 2023, the Society will have active additional Accredited Registers (known as specialist registers) in:

Person Centred Experiential Therapy
Children and Young Persons' Counselling
Relationship Therapy
Psychosexual Therapy

The additional registers will be open to all members who are on the Society's main Accredited Register, and therefore access to additional registers will require at least the membership grade of Accredited Registrant.

Members of all registrant grades can apply to join additional registers, and transition between SCoPEd columns is not affected.

The specialist registers themselves are not part of SCoPEd, but function as additional badging where members have additional experience and training in particular areas of work or modalities.

We will continue to keep you updated throughout this process. We will also continue consulting with members around SCoPEd, so that we can continue to give a voice to those who have concerns about the framework and the process. If you have any questions please email scoped@nationalcounsellingsociety.org

The SCoPEd Group had a “SOC” meeting recently which involves the chief executives of the group’s partners and its Independent Chair. The next meeting is in May.

We thought it would be useful for you to understand the next steps in the development of SCoPEd and to give a preliminary indication of when the vote is likely to happen.

Our goal is to hold our vote when we have all the information needed for our members to make a fully informed decision. We want to be able to understand the final shape of the project and hold a vote with the confidence that there would only be minor changes (if any) after the vote took place.

There are three remaining issues and areas of work which we feel will get us closer to that point:

1. The Impact Assessment. The discussion for that should occur in May with the Assessment beginning once an external expert has been appointed. We will keep everyone informed of that, and how you can contribute to the assessment.

2. Agreement on titles if possible. The intention of the project is smooth integration into the existing way the different organisations use membership grades. In practice we are already confident that if SCoPEd is adopted there will be little noticeable change to Accredited Registrant and Accredited Professional Registrant grades. Much of the change would be in the background, for example, working with Accredited Training Schools to ensure that their training explicitly maps to the competency framework.

3. Agreeing mechanisms for transitioning up the columns. This will be looking at what is taken into account in terms of qualifications, experience and so forth for a member to be able to move from Column A to B to C if they wish to do so, and how this relates to membership grades.

Once we have clarity on the above issues, we will execute the following timetable:

• We’ll write to members ensuring that you have the most up to date and relevant information
• We’ll notify members of the vote date. The vote will be conducted via an appropriate third party electoral system
• We’ll hold a “last call” for members who feel we have not provided information either for or against the project, collate any such information and circulate it to the membership at large
• We’ll give members a final opportunity to ask questions which we will answer
• We’ll run the vote allowing sufficient time for all to vote and using multiple communications channels to ensure members don’t miss out
• We’ll announce the result and explain next steps
  

Who can vote?

To be guaranteed a vote, you will have to be a either a Registrant member or Student member in good standing by the Eligibility Date.

What's the Eligibility Date?

Our Membership Services Team normally needs a certain amount of time, which varies throughout the year based on application volume, to assess a membership application. Therefore anyone that wishes to become a member and exercise a right to vote in this ballot would need to allow several weeks between their application and the ballot date to be guaranteed a vote.

We anticipate this being eight weeks before the ballot but this could change. This will mean that we cannot guarantee anyone applying to join the Society a vote if their application is submitted under eight weeks beforehand. While we'll try to process their application, we can't guarantee it. Anyone applying under eight weeks before the vote will be informed of this.

We'll continue to keep you informed.

As ever, please do continue to send questions or comment to scoped@nationalcounsellingsociety.org.

Dear Member,

We’re writing to inform you that the SCoPEd Group, which you’ve supported us being a part of, has today released the next iteration of the project, which you can view below.

Working together with other organisations on this project has been an informative and interesting journey. At all stages we have sought to represent our members’ interests as expressed to us, either via online surveys or in individual communication. Please rest assured that we have raised your interests and concerns at every group meeting. Dialogue between the partner organisations has been challenging – naturally so given different starting points, values and principles - but also respectful and engaging.

If we were to highlight some areas in which we feel we have contributed to positive change in the latest document, this would be in the areas of the academic nature of the project, the emphasis on the therapeutic relationship, and in other areas of wording and clarification.

We were aware that you, our members, had raised concerns about separating people into groups based upon academic competencies, and so we raised issues where the previous iteration embedded academic rather than therapeutic points of differentiation. We were conscious of wanting to refocus on the therapeutic relationship and ensuring that the document reflected that. We also challenged some elements of the columns where language wasn’t helping, and, for example, looked at some issues reserved for “higher” columns where we felt were competencies shared by all. The other group partners also had their own issues and points of view, and the current document is of course, the result of a group effort conducted in what we feel has been a constructive spirit.

We wish to reiterate, of course, that our members are the ones to weigh up carefully the benefits of adopting or rejecting SCoPEd. What is clearly emerging now is that, if adopted, the three SCoPEd Columns would be mapped onto existing membership grades with relative ease. We anticipate that the only one of our current grades likely to be significantly affected is that of Senior Accredited Registrant. We will provide further information about this as soon as it is known. Our other membership grades are already so closely aligned to Columns A and B that we would not anticipate any significant adjustments for existing registrants. We should also state that the gateways between the different grades, once developed, could provide a smoother and easier to understand upgrade path for registrants than our current processes.

This said, it is important that we acknowledge the significant proportion of our membership which does object to SCoPEd, and should our membership vote to accept SCoPEd, we will explore every avenue to ensure that those dissenting from the project continue to have a voice and that we explore alternative ways of offering milestone recognition for practice, e.g., through experience based acknowledgments if our members want this.

The remaining issue is one of titles. As members are aware, the original draft of SCoPEd mooted the titles Counsellor, Advanced Counsellor, and Psychotherapist. This resulted in some considerable concern and these titles were removed from the second iteration of the project (shortly before we joined the SCoPEd group). It is fair to say there is of course a difference of opinion between the view of psychotherapy which, pointing to its training routes and job roles, sees it as different from counselling, with more in-depth work and deeper training; and the view which sees counselling and psychotherapy as interchangeable umbrella terms.

The SCoPEd group will, we hope, reach a joint view on this and again, you, our members will have a vote on whether to adopt SCoPEd.

Of course we welcome any comments and questions on this iteration to scoped@nationalcounsellingsociety.org.

Best wishes,

The National Counselling Society

The SCoPEd framework is a ground-breaking shared standards’ framework, developed by six Professional Standards Authority accredited bodies representing over 75,000 counsellors and psychotherapists.

It transparently sets out the core training, practice and competence requirements for counsellors and psychotherapists working with adults.

You can view or download the January 2022 version of the SCoPEd framework using the links below.

SCoPEd Framework January 2022

SCoPEd Framework January 2022 - Accessible Version

SCoPEd Methodology Update January 2022

SCoPEd Methodology Update January 2022 - Accessible Version

We’re pleased to announce that the latest version of the ground-breaking SCoPEd framework has been published today (02/02/2022).

This January 2022 version of the framework is the first to be developed jointly by our six Professional Standards Authority-accredited counselling and psychotherapy organisations. Together, we represent over 75,000 counsellors and psychotherapists. We’d like to thank all the members, registrants, partners and staff who have contributed to its development.

This latest framework version reflects our better mutual understanding and a closer working alliance, underlined by our shared passion and priority of protecting the public. It has been a real pleasure to collaborate with one another, and we are bound powerfully by our joint commitment to promoting the skills and competences of all our members and registrants, at a time of acute societal need.

We are already seeing the positive impact on how the counselling and psychotherapy profession is perceived, with significant engagement at this early stage from bodies such as the NHS and Health Education England.

The publication of the January 2022 framework marks the delivery of our phase one work on SCoPEd – a joint commitment to map the current reality of the core training, practice and competence requirements. The framework is written at a high level, is not modality specific, and it is about working with adults over the age of 18, and not about working with children or young people.

We are now moving on to phase two of our collective work. This means working towards the potential adoption of the framework by each partner organisation, and in due course we will also populate the framework with titles, gateways and much more.

We want to achieve a basic high-level recognition of the rigour and standards of counselling and psychotherapy as a whole. This is because we are still at an early stage in making sure policymakers, commissioners and the public have a fundamental grasp of our profession.

As we enter phase two, we have jointly committed to:

• continuing to develop the framework to provide essential information to clients, patients and service users to make informed choices about the support they seek
• conducting an impact assessment of the SCoPEd framework
• creating a shared set of principles – based around fairness, inclusion and transparency – for implementing the framework
• working towards agreed shared ‘column titles’ which are not included in this version
• agreeing transparent and evidence-based mechanisms for members and registrants to progress between the columns of the framework as they develop their training, skills, knowledge and experience throughout their professional journey

The expansion of the SCoPEd partnership to embrace new organisations, and the excellent working relationships we have formed, have made a very positive impact on the framework, and have further emphasised the need for it, its purpose, and its benefits.

We are looking forward to moving ahead collectively on this phase two activity in the coming weeks and months.

What are the key changes in this version of the framework?

There have been a number of significant updates and improvements made to the content and the language of the framework since the previous version was published in July 2020. These have been made as a result of:

• feedback from members, registrants and stakeholders on the previous version
• input from all new and existing partners and the independent experts by experience recruited to support and review the development of the framework
• greater emphasis on the role of the therapeutic relationship and the qualities of the therapist
• further focus on equality, diversity and inclusion as a theme embedded and integrated throughout the framework
• additional standards relating to online and phone therapy
• more consistent use of language that is inclusive and more accessible to a wider audience
• the addition of a glossary of terms

The key changes include:

Who are the SCoPEd partners?

The partner organisations collaborating on SCoPEd are:

• Association of Christian Counsellors (ACC)
• British Association for Counselling and Psychotherapy (BACP)
• British Psychoanalytic Council (BPC)
• Human Givens Institute (HGI)
• National Counselling Society (NCS)
• UK Council for Psychotherapy (UKCP)

Collectively, the SCoPEd partners represent over 75,000 counsellors and psychotherapists from a diverse range of backgrounds, approaches, philosophies and professional training.

The SCoPEd Oversight Committee (SOC) is the governance body for the framework. The SOC was established when ACC, ACP (Association of Child Psychotherapists), HGI and NCS joined the original SCoPEd partners BACP, BPC and UKCP in November 2020.

It meets regularly to oversee, guide and scrutinise the work of SCoPEd. It includes the six Chief Executives of the participating partners, three independent experts by experience and Independent Chair Paul Buckley who was appointed in spring 2021.

As the next iteration of the SCoPEd framework is due to be published early next year, we would like to update you on how the project has progressed and the next steps that will be taken.

Publishing the framework

Work on the SCoPEd framework is ongoing. The next iteration will be published in early 2022 and will be the first to include the contributions and collaborations from the experts by experience (EbEs) and the new partners. Publication was anticipated to be in December 2021, however moving it to early 2022 will ensure that the updates are finalised across the partners and that the framework design meets accessibility requirements.

Association of Child Psychotherapists (ACP)

Following the collaboration on the latest iteration of the framework, ACP have reviewed their role in the partnership and will be continuing in the capacity of observer to support the ongoing work of the SCoPEd partnership.

Dr Nick Waggett, Chief Executive, ACP said:

‘ACP joined SCoPEd as we believe in collaborating with other counselling and psychotherapy bodies to improve standards, protect the public and increase understanding of our profession. We have decided to step aside from the current process as we now recognise that a framework focussed on work with adults is not able to sufficiently represent the specialist training and practice of ACP registered Child and Adolescent Psychotherapists. As such, continuing with the process would not have met our aims. We have appreciated the opportunity to work with fellow accredited registers on this important project.’

Psychological Professions Network conference

The SCoPEd partners* have been invited to present at the Psychological Professions Week conference in November as part of the ‘Improving career pathways in psychological professions’ session.

BACP will deliver a presentation on behalf of the SCoPEd partners and the event will also include a panel debate.

Next steps

The partners continue to collaborate on finalising the next iteration, and the details of all changes will be communicated when the framework is published.

*SCoPEd partners:
Association of Christian Counsellors, British Association for Counselling and Psychotherapy, British Psychoanalytic Council, Human Givens Institute, National Counselling Society, and United Kingdom Council for Psychotherapy

SCoPEd Bulletin #2 - April 2021

SCoPEd Informal Survey Results - December 2020

SCoPEd Bulletin #1 - December 2020

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.

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 21^st 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:

1. 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.
2. 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.
3. 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?
4. 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?
5. 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?
6. 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.
7. 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?
8. 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 6^th 2020

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.

Yours sincerely

Vicky Parkinson

CEO

National Counselling Society

Read our full response in the below document.

• SCoPEd: Open Letter to BACP (1MB)

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• BACP Response Letter 2009 (4MB)

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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

Dear Vicky,

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.

Yours sincerely,

Gary Fereday

Chief Executive BPC

(signed on behalf of the SCoPEd Steering Group)

Following our open letter (which can be found further down this page), we have now received a response from the SCoPEd collaboration.

Dear Vicky

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.

Yours sincerely

Gary Fereday

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.'

and

'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.

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.

They write;

‘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.

Kind Regards

Vicky Parkinson

CEO

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

Janet Tolan

Lesley Wilson

Heather Kapelko

Sheila McCarthy-Dodd

Jane Pendlebury

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)