Reproduced here is an letter from 8 psychoanalytic institutions, openly addressed to anyone who considers themselves a colleague. It is one of three docs they have written in response to the HPC consultation on regulating counselling and psychotherapy. The other two docs can be accessed through the web-link embedded in the title of this blog and downloaded (HPC response to PLG and HPC Response to SoP). Taken together - or indeed separately - they are a tremendous rebuttal of the ideas put forward by the HPC. It remains to be seen whether the HPC is capable of tackling the points raised, or whether it will simply rely on the governmental power to ignore the opposition and carry on regardless.
Dear Colleague,
The Health Professions Council have now published their Draft Standards of Proficiency for Psychotherapy and Counselling. Although they have been working on the proposed regulation of the talking therapies for the last three years, the Standards will surprise many therapists and counsellors. They apply more to medical processes than to therapies, and will be unrecognisable to many practitioners. Indeed, they seem to apply more to a surgical team preparing a patient for an operation than to the open-ended relationship-based work of a talking therapy. The Standards dictate that practitioners should:
- know how to operate equipment and minimise the risk of infection.
- know how to select appropriate hazard control and risk management, reduction or elimination techniques.
- have a knowledge of health, disease, disorder and dysfunction.
- be able to evaluate and implement intervention plans using recognised outcome measures.
- know how to use protective equipment.
- know how to formulate and deliver plans and strategies for meeting health and social care needs.
- understand the principles of quality control and quality assurance and conduct audits correspondingly.
- maintain an effective audit trail, participate in audit procedures and work towards continued improvement.
- be able to formulate specific and appropriate management plans including the setting of timescales.
- demonstrate a logical and systematic approach to problem solving and be able to initiate problem solving techniques.
- observe and record client's responses.
-be able to demonstrate effective and appropriate skills in communicating information, advice and instruction.
- understand the need to engage service users and carers in planning and evaluating the diagnostics, treatment and interventions to meet their needs and goals.
- understand the importance of maintaining their own health.
- know how to meet the needs of the client.
A detailed critique of the Standards is [downloadable from the resource page linked to the heading of this blog: Response to HPC], together with a response to the HPC Professional Liaison Group's Report on the proposed regulation of psychotherapy and counselling [click header to download both docs]. Accepting the HPC Standards threatens the talking therapies with the same fate that has met other professions: practice simply becomes a technique of risk management, with the prime concern less the work undertaken with the client than the avoidance of litigation or complaint. Complaints, indeed, would be much more likely given the definition given by HPC of a 'service user': this no longer simply refers to the client, but to "anyone who is affected by the services of a registrant", including a client's relatives or spouse, thus encouraging third party complaints.
Therapists, on the HPC model, would be obliged to act in exactly the ways they may be encouraging their clients to escape from: submission to rather than questioning of internalised authority, and a conformity to socially-agreed expectations, rather then the fostering of creativity and uniqueness that therapies have traditionally aimed at. Whereas the system of values that the talking therapies have always offered was freed from the moral judgements of social authorities, it is now made to conform to exactly these moral judgements. It will no longer be psychotherapy as we know it.
All trainings in the field will, according to HPC, be obliged to meet the Standards of Proficiency, and the hearing of complaints and fitness to practice cases will use the Standards as a benchmark. Aside from the obvious problem of medicalising the talking therapies, the therapists of the future, in such a climate, may feel they are perpetually under a judgmental gaze, the private space of the therapy becoming the stage for an internalised judge or examiner. The consequences of this on therapeutic practice cannot be underestimated, and there is an irony here that many traditional descriptions of psychotherapy define it as the effort to find freedom from the internalised observer-judge that may be at the root of the client’s unhappiness.
While we unreservedly support codes of ethics and practice that ensure the practitioner's accountability, we do not believe that HPC's approach is suited to our field and so urge you, should HPC regulation take place, to adopt with us a position of principled non-compliance. If enough therapists and counsellors do not register with HPC, Government will realise the enormous mistake it is making, and our field may not face such a grim future.
Arbours Association
Association for Group and Individual Psychotherapy
Association of Independent Psychotherapists
Centre for Freudian Analysis and Research
The College of Psychoanalysts-UK
The Guild of Psychotherapists
Philadelphia Association
The Site for Contemporary Psychoanalysis
Thursday, 27 August 2009
Counselling and Depression as remedies to FTP
From another case recently posted up on the HPC web, of a paramedic :
"you were referred to an independent counsellor by the Occupational Health Department. You told the Panel that the period of counselling has had a significant effect on your health, that your depression is well controlled and your relationship with your wife is now stable."
Well, three things stand out. First, in what way is it useful for the HPC to post this information up on the public domain? It smacks of 1984.
Second, the counselling is presented as a remedy prescribed by Occupational Health which rather begins to beg the question about another profession that might be regulated by the HPC.
Later in the announcement we find a letter from the GP validating the fact that the counselling has contained the depression. This effectively turns it into a medical condition under control, ultimately, of the GP. This is the third point, and is contentious, to say the least. The HPC and its staff operate within an unenlightened medical paradigm which brings 'counselling' into the frame as a solution, like a drug, to inefficient or ineffective workforce issues.
It is the legal frame, the centralised operation of the HPC, and the close proximity of a government agenda, that distorts the general human condition into a specific public spectacle. Even if this is an unintended consequence, it appears highly normal to those within the frame.
I think it is something that many people will be amazed to see blossoming in the UK today.
"you were referred to an independent counsellor by the Occupational Health Department. You told the Panel that the period of counselling has had a significant effect on your health, that your depression is well controlled and your relationship with your wife is now stable."
Well, three things stand out. First, in what way is it useful for the HPC to post this information up on the public domain? It smacks of 1984.
Second, the counselling is presented as a remedy prescribed by Occupational Health which rather begins to beg the question about another profession that might be regulated by the HPC.
Later in the announcement we find a letter from the GP validating the fact that the counselling has contained the depression. This effectively turns it into a medical condition under control, ultimately, of the GP. This is the third point, and is contentious, to say the least. The HPC and its staff operate within an unenlightened medical paradigm which brings 'counselling' into the frame as a solution, like a drug, to inefficient or ineffective workforce issues.
It is the legal frame, the centralised operation of the HPC, and the close proximity of a government agenda, that distorts the general human condition into a specific public spectacle. Even if this is an unintended consequence, it appears highly normal to those within the frame.
I think it is something that many people will be amazed to see blossoming in the UK today.
Tuesday, 25 August 2009
Learning from our mistakes
"it is difficult enough to be critical of our own mistakes, but it must be nearly impossible for us to persist in a critical attitude towards those of our actions which involve the lives of many men and women. To put it differently, it is very hard to learn from very big mistakes." Karl Popper, 1944 (Piecemeal Social Engineering)
The longer the HPC is allowed to continue with its large scale utopianist experiment, the less likely it is to learn from it. It has recently been noted that the ambulance drivers are disproportionately victimised by the FTP process - they are turning up far more than any other group on the HPC register. Also, more men are pushed into the process, even tho the majority of people on the register are in fact women. The HPC has commissioned some 'research' to discover whether the former fact is significant (I don't think they are worried about the second fact yet). I wonder what the outcome will be of that piece of work.
The point that Popper makes here is that there are two reasons for the difficulty to learn. The first is that, because of "the scale of a utopianist experiment, it is impossible to say which particular measure is responsible for any of the results.... Even the greatest efforts to secure a well-informed, independent and critical statement of these results are unlikely to prove successful. But the chances" he goes on to say "that such efforts will be made are negligible; on the contrary, there is every likelihood that free discussion about the holistic plan and its consequences will not be tolerated."
The passage from which I draw these words gets more and more interesting. Written in 1944 - before the end of the second world war, a whole lifetime ago - it seems amazingly relevant to the question before us today:
It will not be tolerated, because: "every attempt at planning on a very large scale is an undertaking which must cause considerable inconvenience to many people (to put it mildly) and over a considerable span of time. Accordingly there will always be a tendency to oppose the plan, and to complain about it. To may of these complaints the Utopian engineer will have to turn a deaf ear if he wishes to get anywhere at all; in fact, it will be part of his business to suppress unreasonable objections. But with them he must invariably suppress reasonable criticism too. And the mere fact that expressions of dissatisfaction will have to be curbed reduces even the most enthusiastic expression of satisfaction to insignificance. Thus it will be difficult to ascertain the facts, ie, the repercussions of the plan on the individual citizen; and without these facts scientific criticism is impossible.'
Popper uses the word 'scientific' to mean critical thinking, and speaks often of its many different forms. Not for him the unified 'gold standard' that we find ourselves bogged down with under the 'evidence based' experiment of today.
The longer the HPC is allowed to continue with its large scale utopianist experiment, the less likely it is to learn from it. It has recently been noted that the ambulance drivers are disproportionately victimised by the FTP process - they are turning up far more than any other group on the HPC register. Also, more men are pushed into the process, even tho the majority of people on the register are in fact women. The HPC has commissioned some 'research' to discover whether the former fact is significant (I don't think they are worried about the second fact yet). I wonder what the outcome will be of that piece of work.
The point that Popper makes here is that there are two reasons for the difficulty to learn. The first is that, because of "the scale of a utopianist experiment, it is impossible to say which particular measure is responsible for any of the results.... Even the greatest efforts to secure a well-informed, independent and critical statement of these results are unlikely to prove successful. But the chances" he goes on to say "that such efforts will be made are negligible; on the contrary, there is every likelihood that free discussion about the holistic plan and its consequences will not be tolerated."
The passage from which I draw these words gets more and more interesting. Written in 1944 - before the end of the second world war, a whole lifetime ago - it seems amazingly relevant to the question before us today:
It will not be tolerated, because: "every attempt at planning on a very large scale is an undertaking which must cause considerable inconvenience to many people (to put it mildly) and over a considerable span of time. Accordingly there will always be a tendency to oppose the plan, and to complain about it. To may of these complaints the Utopian engineer will have to turn a deaf ear if he wishes to get anywhere at all; in fact, it will be part of his business to suppress unreasonable objections. But with them he must invariably suppress reasonable criticism too. And the mere fact that expressions of dissatisfaction will have to be curbed reduces even the most enthusiastic expression of satisfaction to insignificance. Thus it will be difficult to ascertain the facts, ie, the repercussions of the plan on the individual citizen; and without these facts scientific criticism is impossible.'
Popper uses the word 'scientific' to mean critical thinking, and speaks often of its many different forms. Not for him the unified 'gold standard' that we find ourselves bogged down with under the 'evidence based' experiment of today.
The Utopianist planner must make man fit society
I'm reading Karl Popper's 1944 essay 'Piecemeal Social Engineering' in which he constantly compares the piecemeal social engineer with the utopianist holistic planner. One of the many distinctions he makes is that the PSE tries, bit by bit, to make society fit the real men and women who happen to live there, but the UHP tries to make his fellow men and women fit the society he dreams of.
By way of a break, I clicked over to the hpc website and had a look at some of the FTP allegations coming up in the next few months, and straight away found this one:
1. In the course of your employment as an Occupational Therapist by Super-Duper Hospital NHS Trust, between 19 March 2007 and 14 June 2007, you undertook work elsewhere whilst on long term sick leave and whilst receiving statutory sick pay.
It's not that I think that someone who works for money whilst receiving stat sick pay should go un-remarked, but I do think that it is silly to say that it means, ipso facto, they are not morally fit for the work they are qualified to do. It's clumsy, brutal, and out of proportion with reality - Utopian, in a cold, harsh, petty, nasty sort of way.
By way of a break, I clicked over to the hpc website and had a look at some of the FTP allegations coming up in the next few months, and straight away found this one:
1. In the course of your employment as an Occupational Therapist by Super-Duper Hospital NHS Trust, between 19 March 2007 and 14 June 2007, you undertook work elsewhere whilst on long term sick leave and whilst receiving statutory sick pay.
2. The matter set out in Paragraph 1 constitutes misconduct.
3. By reason of that misconduct, your fitness to practice is impaired.It's not that I think that someone who works for money whilst receiving stat sick pay should go un-remarked, but I do think that it is silly to say that it means, ipso facto, they are not morally fit for the work they are qualified to do. It's clumsy, brutal, and out of proportion with reality - Utopian, in a cold, harsh, petty, nasty sort of way.
Thursday, 6 August 2009
Three no shows in a row:
Here's another case reported on today's press releases. Another registrant who didn't turn up, which might suggest that the registrant has no confidence in being given a fair hearing.
Points of interest
1. this is a manager that is being judged, which raises a series of questions about the difference between a manager and a practitioner, and so who is the judge of the proficiency.
2. Given the managerial function, this raises the question of the organisational context that gives the scene its local meaning.
3. Who raised the complaint - what attempts were made to resolve this at the local level, why did they fail.
In all these cases it is important to ask 'what is the evidence' used by HPC. It would be wrong to conclude that they had carried out objective in depth research. Often cases are launched on hearsay. All cases begin with the assumption that the professional is probably guilty. They are all are investigated at a distance, with paperwork as the main method. Committees are the primary vehicle, followed by solicitor who prepares the allegation (that is to say, the solicitor's research is not objective, but is conducted in order to win).
Final point, much is made of the phrase 'balance of probabilities' which borrows the power of statistics. No statistics are used, however, and the phrase is simply a metaphor.
Quoted from HPC website:"Mismanagement results in human error and lack of concentration in cellular pathology unit. Biomedical scientist, Mr x has been suspended from the HPC Register for misconduct after a HPC Conduct and Competence Committee found his current fitness to practise impaired whilst working at the Y Hospitals NHS Trust.
The panel heard how Mr X’s lack of competence as a senior staff member had resulted in over 600 products of conception (POC) that were not disposed of, swapped breast biopsies and a wrongly prepared rectal tissue sample.
The Panel also heard that the registrant failed to accept ownership and accountability for the incidents, and that he had not taken any remedial steps to address the short comings.
Panel Chair, Raymond Pattison, commented:“The registrant knowingly allowed an inordinate and substantial amount of POCs to accumulate”
“The registrants failure, in his managerial position, to exercise sound judgment, particularly to the sensitive issue of POC disposals constitutes a serious lapse from the standards to be expected of a health professional of his seniority.
”The panel decided the most appropriate action was to suspend Mr X from the Register for a period of one year with immediate effect.
Mr X was neither present nor represented at the hearing
Points of interest
1. this is a manager that is being judged, which raises a series of questions about the difference between a manager and a practitioner, and so who is the judge of the proficiency.
2. Given the managerial function, this raises the question of the organisational context that gives the scene its local meaning.
3. Who raised the complaint - what attempts were made to resolve this at the local level, why did they fail.
In all these cases it is important to ask 'what is the evidence' used by HPC. It would be wrong to conclude that they had carried out objective in depth research. Often cases are launched on hearsay. All cases begin with the assumption that the professional is probably guilty. They are all are investigated at a distance, with paperwork as the main method. Committees are the primary vehicle, followed by solicitor who prepares the allegation (that is to say, the solicitor's research is not objective, but is conducted in order to win).
Final point, much is made of the phrase 'balance of probabilities' which borrows the power of statistics. No statistics are used, however, and the phrase is simply a metaphor.
Quoted from HPC website:"Mismanagement results in human error and lack of concentration in cellular pathology unit. Biomedical scientist, Mr x has been suspended from the HPC Register for misconduct after a HPC Conduct and Competence Committee found his current fitness to practise impaired whilst working at the Y Hospitals NHS Trust.
The panel heard how Mr X’s lack of competence as a senior staff member had resulted in over 600 products of conception (POC) that were not disposed of, swapped breast biopsies and a wrongly prepared rectal tissue sample.
The Panel also heard that the registrant failed to accept ownership and accountability for the incidents, and that he had not taken any remedial steps to address the short comings.
Panel Chair, Raymond Pattison, commented:“The registrant knowingly allowed an inordinate and substantial amount of POCs to accumulate”
“The registrants failure, in his managerial position, to exercise sound judgment, particularly to the sensitive issue of POC disposals constitutes a serious lapse from the standards to be expected of a health professional of his seniority.
”The panel decided the most appropriate action was to suspend Mr X from the Register for a period of one year with immediate effect.
Mr X was neither present nor represented at the hearing
Telling tales to the HPC - another failure to take responsibility locally.
And, here's another.
Points of note: a senior position, not simply that of practitioner - suggests that an appointments panel thought she was competent for the job.
Would seem to be a matter better dealt with by someone with a bit of life in them at a local level, rather than reported to an anonymous committee in some central office elsewhere.
The phone calls and internet seem very petty misdemeanours, and not obviously harmful to patients. Again, something that should be dealt with at a local level. Yet she was struck off! I'm not condoning slovenly work in the NHS, but trying to keep a perpsective, and to remember that once in many lifetimes, love can make a fool of even the best of us.
What about this woman's actual work - the thing that she does with a patient, there is absolutely no mention of this whatsoever. Odd.
quoted from HPC web:
Occupational therapist, Ms X has been struck off from the HPC Register for personal misconduct and failing to carry out adequate clinical occupational therapy input to patient care whilst working at the Y Primary Care Trust.
A panel of the HPC Conduct and Competence Committee heard how Ms X had failed to provide regular supervision and appraisals to the members of staff for whom she was responsible, failed to correctly assess patients and failed to organise cover for holiday and sickness leave.
The Panel also heard that Ms X had made personal calls to the value of £32 on her work telephone, used the Trust’s internet resources during working hours to contact dating agencies, took colleagues shopping during work hours and made excessive reference to personal issues in discussions with colleagues.“Ms X must have known that her failings were likely to place patients’ welfare at risk and that these were not proper uses of the Trust’s resources.”
The panel decided the most appropriate action was to strike Ms X from the Register with immediate effect.Ms X was neither present nor represented at the hearing.
Points of note: a senior position, not simply that of practitioner - suggests that an appointments panel thought she was competent for the job.
Would seem to be a matter better dealt with by someone with a bit of life in them at a local level, rather than reported to an anonymous committee in some central office elsewhere.
The phone calls and internet seem very petty misdemeanours, and not obviously harmful to patients. Again, something that should be dealt with at a local level. Yet she was struck off! I'm not condoning slovenly work in the NHS, but trying to keep a perpsective, and to remember that once in many lifetimes, love can make a fool of even the best of us.
What about this woman's actual work - the thing that she does with a patient, there is absolutely no mention of this whatsoever. Odd.
quoted from HPC web:
Occupational therapist, Ms X has been struck off from the HPC Register for personal misconduct and failing to carry out adequate clinical occupational therapy input to patient care whilst working at the Y Primary Care Trust.
A panel of the HPC Conduct and Competence Committee heard how Ms X had failed to provide regular supervision and appraisals to the members of staff for whom she was responsible, failed to correctly assess patients and failed to organise cover for holiday and sickness leave.
The Panel also heard that Ms X had made personal calls to the value of £32 on her work telephone, used the Trust’s internet resources during working hours to contact dating agencies, took colleagues shopping during work hours and made excessive reference to personal issues in discussions with colleagues.“Ms X must have known that her failings were likely to place patients’ welfare at risk and that these were not proper uses of the Trust’s resources.”
The panel decided the most appropriate action was to strike Ms X from the Register with immediate effect.Ms X was neither present nor represented at the hearing.
Management vs HPC Police
What ever has happened to the staff of the NHS that they can't handle tensions at work? And why has note keeping become fetishised in this way?
Below, taken from today's HPC website, is someone who is described as experienced, yet is suspended for not filling in her notes. From the report here, it seems that there was a bit of a fight between colleagues at work. Everything is ok with the patients, no problems emerge from there, but when this woman goes on holiday, her colleagues appear to snitch on her! What is going on here? I wonder whether a new compturised system is getting in the way - something that assumes work should be done differently from the way it has been done throughout this woman's experience.
And as for the phrase 'I probably made it up' - what on earth is that supposed to refer to? the HPC are notorious for thinking that their registrants might fib (ref their advertising campaign which portrayed professionals as liars), and this quote is so out of context that it is meaningless.
Below, taken from today's HPC website, is someone who is described as experienced, yet is suspended for not filling in her notes. From the report here, it seems that there was a bit of a fight between colleagues at work. Everything is ok with the patients, no problems emerge from there, but when this woman goes on holiday, her colleagues appear to snitch on her! What is going on here? I wonder whether a new compturised system is getting in the way - something that assumes work should be done differently from the way it has been done throughout this woman's experience.
And as for the phrase 'I probably made it up' - what on earth is that supposed to refer to? the HPC are notorious for thinking that their registrants might fib (ref their advertising campaign which portrayed professionals as liars), and this quote is so out of context that it is meaningless.
quoted from HPC web:
Physiotherapist, Ms X, has been suspended from the HPC Register for failing to keep accurate patient records whilst employed by Y District Primary Care Trust.
A panel of the HPC Conduct and Competence Committee heard that whilst Ms X was on leave her colleagues were alerted to cases where she had failed to keep accurate records and failed to create action plans for appropriate treatment of patients.
Ms X was an experienced physiotherapist and had been counselled previously in relation to her inadequate record keeping. The Panel heard that when Ms X was confronted about the incidents she admitted ‘she had probably made it up.’
Panel Chair, Mr Gordon Sutehall, commented:
“We are satisfied that there were deficiencies in the registrant’s practice to record keeping and despite supervision and training the registrant did not consistently meet the required standard of record keeping”
“The allegation involves an element of dishonesty and is therefore a serious one.”
The panel decided the most appropriate action was to suspend Ms X from the Register for a period of six months with immediate effect.
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