On this page you can access our archive of bulletins and news relating to the topic of SCoPEd.
If you have any questions, please email email@example.com.
- SCoPEd Members' Update - October 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.
- National Counselling Society Statement on Second Iteration of SCoPEd - August 2020
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
- SCoPEd Consultation Response - March 2019
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
- SCoPEd: AN OPEN LETTER TO BACP by the NATIONAL COUNSELLING SOCIETY - February 2019
Read our full response in the below document.
- SCoPEd: Open Letter to BACP (1MB)
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- SCoPEd: Open Letter to BACP (1MB)
- Update regarding SCoPEd - June 2018
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)
- Response to open letter regarding SCoPEd - May 2018
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.
- Society Response to SCoPEd project - April 2018
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)