State regulation of the psychologists, quis custodiet ipsos custodes

The Joint Committee on Statutory Instruments now has an Order to consider which, if passed, will put 13,000 psychologists onto the register of the HPC in July. This order is called The Health Care and Associated Professions (Miscellaneous Amendments and Practitioner Psychologists) Order 2009. It is simultaneously laid before the Scottish Parliament.

The Order relates to the General Dental Council, the Health Professions Council, and the Royal Pharmaceutical Society of GB.

It includes governance changes which will effect the Council of the HPC. At the moment, HPC Council is made of members who are elected by the 13 professions already on the register plus 13 lay members who are appointed by Privy Council. This Order will remove the elected members and all will then be appointed by the Privy Council.

The power is moved (yet again) away from the people who practise, to a private group appointed by the Sovereign.

The explanatory memorandum puts it like this:
it is "to ensure that purely professional concerns are not thought to dominate its work"
"Regulators must be seen to be independent and impartial..."
"Doubts based on a perceived partiality have threatened to undermine .. trust"
"The regulators may be seen as partial ..."
"The composition is central to .. these perceptions"
"Regulators may be seen as partial to their professionals because [they] form the majority of their council or may be seen to be partial because their councils are thought to be elected to represent the particular interests of health professionals. Hence the moves to parity of membership and having independently appointed councils rather than professional members being elected by the profession." (Clause 7.1) [emphasis added]

There's a few things to note: these excerpts are all about manipulating an image rather than reflecting or establishing a system grounded in reality. It would be valuable to ask 'not thought by who?', 'perceived by who?' 'seen by who?', and 'on what occasion'? The vagueness does not encourage clear thinking. Second, the idea that purely professional objectives are a bad thing is odd. It sort of implies that the particular interests of health professionals are primarily against, and dangerously against, the interests of someone else. The vagueness leaves a nasty taste and encourages suspicion - abstract suspicion. Thirdly, the structure of the HPC is already predisposed towards destabilising the knowledge and practise of each of these groups of people, which makes it more likely that a group would to try to act in its own favour, to protect its boundaries, and to redefine its speciality - and all these things have already been insinuated as bad. An effective self fulfilling prophecy has been put in place which this new Order can only add to.

Couple this with the realisation that 13000 new people could be added to the register in summer, and that these people are working with other people's minds, and you have quite a prospect.

Quis custodiet ipsos custodes - who will guard the guardians of the psychologists? The question has an infinite regress, remedied here by ... the Queen.