Constructing the proposed new generic standards

This is based on the HPC Council meeting of March 25th 2010 (attended by Bruce Scott, from the PA). The long list of dense documents pertaining to this meeting can be accessed here:
http://www.hpc-uk.org/aboutus/council/councilmeetings/index.asp?id=523)

A private meeting followed in the afternoon (public excluded), which dealt with the Judicial Review.

Marc Seale (CEO of HPC) opened: registrant fees would probably be increased to fund the rising volume of fitness to practice hearings. In the accompanying papers the fitness to practice budget for 2010/2011 is estimated at £7,145,823! “That’s a lot of lawyers” thought Bruce to himself.

Seale also talked about launching a media campaign to create/push for the professionalism of the guys at football matches with buckets and sponges who run on to the pitch when a player gets injured. The HPC only want “professional helpers” who will then have be HPC registered!

He also wants to capture golf coaches and sports psychologists/coaches, saying ‘we have got to get them because some are not trained psychologists or sports coaches’.

Will the insidious nature of HPC regulation make its way into the Sunday kick-about with the boys or girls? Will “coaches” have to be regulated? Bruce used to be a racing cyclist: “I had several “unqualified” coaches throughout my career - they did it for free because they loved the sport and wanted to give something to the community: they were ex-cyclists, boxers, or just keen on endurance sport. Under the proposed HPC system my coaches would be not be allowed to get involved in sport coaching at all.”

The volume of papers the Council is faced with is overwhelming. I shall focus on only one, The Generic Standards of Proficiency Review Group – Executive summary and recommendations, http://www.hpc-uk.org/assets/documents/10002CED20100325Council-enc06-genericSoPsreview.pdf

These standards are applicable to ALL registrants across the 15 professions already regulated. They were shown to be wholly inappropriate for counselling and psychotherapy in the recent public consultation.

In brief: the Group recommended:
1) The generic standards applicable to all registrants should be kept.
2) But they should be BROADENED.
The council agreed.

The Group comprised:

Eileen Thornton (Physiotherapist)
Joy Tweed (Lay, Lecturer Health & Social Care)
Di Waller (Arts therapist)
Arun Midha (Lay, MBA)
John Donaghy (Paramedic)
Annie Turner (Occupational Therapist)
Penny Renwick (Chiropodist).

They met twice: on 28 September (ie before the end of the consultation on C&P) and then on 27/8 January 2010, after a ‘survey’ of 20 professional bodies. They were specifically advised (presumably by the invisible Legal Adviser mentioned in the report last week): “not to make changes specifically in response to the feedback received through the psychotherapists and counsellors consultation as these professions are not currently regulated by the HPC.”
In September 2009, HPC wrote to TWENTY professional bodies asking for feedback on the generic standards of proficiency. SEVEN responded: FOUR said they had nothing to say, ONE commented on the intro, not the standards, and TWO commented in detail about eight of the 25 or so standards. The Group thought this might indicate that on the whole most of the professional bodies covered by the HPC were satisfied with the standards. It would be interesting to know which two bodies gave the detailed comments.

Why is the HPC reviewing them if none of the existing Groups is unhappy with them? Is it because they want to capture C&P? But they are advised not to consult C&P in the process of revision.

Attachment B of the Review Group’s Recommendations summarises the additional information available to the Group and considered at their second meeting. Most of this information came from the consultation on regulating counselling and psychotherapy, and the rest relates to concerns raised by the psychologists. Neither of these Groups are allowed to be involved in re-writing the generic standards. The legal implications of any new standards for the time-table of work means that it will take years before the psychologists can re-write their specific standards (because the grand-parenting period has to be allowed to play out under the current, agreed, standards). If the PLG for P&C begin writing their specific standards before the new ones are finalised (they are due to reconvene on 12th May 2010, the new generic standards are predicted for January 2011); they too will also have to wait at least three years before re-writing can begin.

It is not noted that the huge number of concerns coming from these two Groups indicates the inappropriateness of including them in the domain of the HPC. Everyone in this field expressed forthright opposition to regulation by the HPC before the White Paper (Trust, Assurance and Safety) was published in 2007, an inconvenient truth that HPC tends to bracket off and ignore.
The report is presented with numbered sections suggesting an orderly progression of logic. However, on close reading one is forced to conclude that the numbering exists mainly for reference, much like page numbering. Could it be also that the numbers function to separate sentences from each other in order to ignore the flow of meaning and logic that some of them might present.

For example in para 2.2 the Group “[agree] that standards 2a.1-2a.4 are examples of when rewording the standards would still not make them applicable for all professions” because they do not apply to Arts therapists. The inconvenient truth that Arts therapists have not met these standards for 8 year is isolated in a numbered paragraph and ignored.

Meanwhile, the Group reflect on the history of the generic standards in the HPC. These were introduced when the HPC was created in order to identify commonalities across the professions. That this was only achieved by ignoring the anomaly of the Arts therapists is not noted.
It is again ignored in Paragraph 2.4, where “the Group agreed that the principle of having a set of generic standards of proficiency is important as they recognise that the professions regulated by the HPC do have commonalities.” To make the professions conform is the single most important task of this Group. But, apparently incapable of referring to real aspects of the work involved in the professions, the Group relies on generalised moral guidelines apparently of their own invention.

First, it is worth noticing how the re-write is justified. To recap, the Group must retain something called generic standards in order to justify the existence of the HPC as the single entity capable of regulation. But they know that these must be substantially rewritten if they are to succeed in capturing C&P. The existing professions have never complained, and don’t see the need to change. But the Arts therapists have taken this opportunity to say that, after more than 8 years, have never complied with these generic standards. As the HPC likes to justify its competence to regulate C&P by reference to its success with Arts therapists, this constitutes a considerable weak point.

This is probably why the admission is made, separated in a numbered paragraph, and then simply ignored.

So how will seven people rewrite the generic standards applicable to more than 205,000 people in 15 different professions? First they acknowledge that they can’t simply reword the current standards, because “some concerns go beyond wording” (2.1, p2). But this means that all other standards will also have to be rewritten, as the generic standards function as section headings in the overall document of standards.

In order to justify this huge project, the Group present three possible options and then choose one. This is prefaced with:

“The Group therefore agreed that generic standards should be retained, but that they should be as CONCISE as possible and applicable to the increasing diversity of professions and professional philosophies regulated by the HPC.” [emphasis added]

Note the use of the word ‘therefore’, which implies a logical argument, where in fact there is none. This small Group of people, meeting on two separate occasions, interspersed by a failed ‘survey’ of 20 professional organisations, are of course unable to do the job they have been tasked with. But instead of saying so (as the generic standards indeed would command) they seem to be creating a smokescreen behind which they are improvising wildly.

Preceding the word ‘therefore’ are four numbered paragraphs bluntly restating the imperative that HPC must have generic standards. The 5th preceding paragraph was the one that said Arts therapists have never conformed to 4 of these.

The word CONCISE has no meaning in the text, but seems instead to signal the Group’s anxiety at the amount of work, time, money and effort that this project will entail. All but the Arts therapists, apparently, are happy with the current standards.

What about the words BROADEN and EXPAND in the next section – what might they mean? Having recommended CONCISE new standards, the Group set out three options.
1. To make concise the old standards – rejected.
2. BROADEN the consultation of old generic standards to include principles and STRUCTURE of standards - rejected.
3. EXPAND the review of generic standards to include STRUCTURE of standards – accepted
This option (3) was chosen ‘because’
1. It would allow the HPC to engage with those who have an interest in the generic standards;
2. The HPC would be seen to be listening and responding to external feedback.
3. It would ‘future proof’ standards for potential new Groups;
4. A BROADER review would stand up to public scrutiny;
5. The work already done can feed into the BROADER review. (P. 4)

The rationale is blatantly political – if there is any sign of any other logic in the text, I couldn’t find it.

The Group goes on to consider a few different options for structuring the new BROADER generic standards:

1. Remove the generic standards, and allow each profession to compile their own. Rejected!
2. Group the generic standards under BROAD headings (eg Psychological Therapies, Scientists and Allied Health Professionals). Rejected ‘because’ it would be ‘complex and superficial’!
3. Change the structure to OVERARCHING, BROAD standards. Accepted because: it would give a set of OVERARCHING standards applicable to all; it would provide headings under which each Profession could then write its own SUB-STANDARDS (sic); the standard ‘be able to select appropriate personal protective equipment and use it correctly’ is likely to be retained for biomedical scientists, but is less likely to be needed for Arts therapists.’ Well, well, well – what a pitiful state of affairs.

Paragraph 2.19 lists six bullet points in an attempt to justify why this option is the most appropriate. These points are an object lesson in how to rob words of any meaning and muddle and confuse the reader to force through the forgone conclusion. Here they are in condensed form:

1. Keep generic standards;
2. There are 14 [sic] diverse professions but there are some commonalities that the generic standards recognise;
3. The OVERARCHING generic standards can be interpreted by individuals;
4. It solves terminology problems allowing difference to be expressed within the professions, own standards; the new structure can be rolled out, beginning with the most problematic professions; new professions will fit.

This meaningless jumble of words leads directly to RECOMMENDATION 3: to adopt OVERARCHING generic standards with profession specific sub-standards underneath. Sub-standards?

The proposed 15 new overarching generic standards (yet to be tweaked by executive and legal advisor) can be winkled out of the HPC website here. http://www.hpc-uk.org/assets/documents/10002CED20100325Council-enc06-genericSoPsreview.pdf

Last Friday saw the first full read through of Josh Appignanesi’s new play Therapy! at London’s Vaudeville Theatre. Matthew Lloyd directed the cast

Richard Schiff – The Shrink
Alex Jennings – The CBT
Jessica Raine – The Analysand
Amanda Drew –Wife
Tom Goodman-Hill –Husband

Particularly impressive were Richard Schiff, instantly believable as the psychoanalyst, and Jessica Raine (the analysand trying to get the best of both worlds by also having CBT). Food provided the linking theme, and the action shifted between consulting rooms and dining room, presenting political points, sexual politics, problems of identity and rivalry, hilariously. It was a real privilege to watch five professionals turn our dilemma into a satirical workout for their talents. (Thanks to Julia Carne, CFAR, for contributing to this.)