Picking up the Archbishop’s thread from Easter Bank Holiday Monday – can literature defeat bureaucracy? – I’m sorry to report that there was a clear win for bureaucracy at last weeks International PEN meeting ‘Free the Word’ at London’s South Bank. Internationally celebrated writer Donato Ndongo-Bidyogo (a political refugee currently living in Spain, exiled from his home in Equatorial Guinea) was denied entry into the UK to take the stage on Saturday because the beleaguered bureaucrat got tangled up in the red tape of the new border control agencies (UKBA, formed in April 2008). Donato had applied to enter as a ‘business visitor’, but the poor fuddled civil servant got hopelessly lost in the labyrinth of rules and ended up quoting chapter and verse from the wrong page of the book. Donato was rejected without hope of appeal and thus prevented from entering good old bastion of liberty, free speaking Britain.
The Labour Party Manifesto links this new agency with crime reduction policy in chapter 5 entitled Crime and Immigration. “Our borders are stronger than ever” it declares, though it may simply be that piles and piles of red tape are simply in the way. This “new Border Agency has police-level powers and thousand more immigration officers, 100 per cent of visas are now biometric, and new electronic border controls will be counting people in and out by the end of the year… Genuine refugees will continue to receive protection.” Or not…
In the absence of Donato Ndongo-Bidyogo’s bodily presence, someone read a passage from his book: Shadows of your Black Memory (Swan Isle Press, 2007), around about page 84. Told in the voice of a boy this piece describes him watching with glee as his Uncle, the leader of the tribe, sparred and jibed with the visiting Catholic Priest whose mission was to impose his superior culture on these poor guys who were evidently stuck in the dark and dismal past. The Uncle’s work was to constantly subvert the Priest’s mission by reminding him to practice what he preached. But the Priest was deaf to his witty reminders and carried on obliviously. The justifications for the Priest’s unwelcome rescue package were uncannily familiar and reminded me, of all things, of the HPC. A man convinced he is right, and employed in a state backed institution excuses himself the effort to think and takes pleasure from telling the other how to live.
Which reminds me, I received a letter from Marc Seale today, replying to the letter I sent following Malcolm Cross’s hearing in which I asked a series of questions about the way the HPC conducts itself. Mr Seale quotes chapter and verse from his big book of rules to prove that I am wrong to raise these questions, and invites me in for re-educating.
Last night at the National Theatre, Alan Bennett’s play, The Habit of Art, (in which, by the way, Alex Jennings, who read the part of the CBT therapist in Josh Appignanesi’s play Therapy! plays the Benjamin Britten) was filmed and broadcast live across the world to thousands and thousands of people. Fabulously rich, layered, funny, thought provoking, intelligent, and mysteriously moving this play sent me off to discover Auden on You Tube reading his poem In Memory of Freud in which so many lines are worth quoting but these especially:
If he succeeded, why, the Generalised Life
Would become impossible, the monolith
Of State be broken and prevented
The co-operation of avengers.
Other lines also reminded me of Therapy! whose most moving scenes come in the analytic session when, between them, analyst and analysand managed to find the truth that Auden puts like this: “to be free is often to be lonely”. And,
But he would have us remember most of all
To be enthusiastic over the night
Not only for the sense of wonder
It alone has to offer, but also
Because it needs our love…
Literature alone doesn’t solve it, of course. Bennett’s play was very different from that of Mark Haddon currently playing at the Donmar – Polar Bears. This one tries hard to look directly at Bi-polar living with the help of philosophy, post-mortem anatomy, and post-modern style. Although engaging in parts, the cut up nature of the play gives everyone the chance to avoid asking themselves what the hell they thought they were doing. It gave a glimpse of the world in which Sigmund Freud’s work was already long forgotten.
In Auden’s poem, written in 1939, he could say of Freud
To us he is no more a person
Now but a whole climate of opinion.
Climate Change, apparently, has evaporated his wisdom.
Only Hate was happy, hoping to augment
his practice now, and his shabby clientele
At the Dulwich Village yoga class on Tuesday evening two women talked enthusiastically about what they’d learned on the Radio 4 programme “Between Ourselves” earlier that morning (9.am, 20th April) in a discussion between Oliver James and Laverne Antrobus. If a baby doesn’t receive the right amount of love, they said, then the brain does not develop, and there’s nothing more to be done. They went on to explain that this was the reason for Jamie Bulger’s murder. Listening again (on iPlayer) Oliver James (who I learned is the son of two psychoanalysts) didn’t exactly say this, but the general drift of his interventions take us directly into this difficult water and look very much like the current climate of opinion.
Back in the Manifesto, in a section of chapter 5 (Crime and Immigration) entitled Early Intervention and Preventing Crime, the Labour Party boldly state: “We need to do more and act earlier to stop children going down the wrong path. So we will expand Family Nurse Partnerships to all vulnerable young mothers, reducing future crime and behavioural problems. For the 50,000 most dysfunctional families who cause misery to their neighbours, we will provide Family Intervention Projects – proven to tackle anti-social behaviour – a no-nonsense regime of one-to-one support with tough sanctions for non-compliance’. All three major Party Political Manifestos contain a line or two about mental health. Labour promise to provide ‘access to psychological therapy for those who need it’. The Liberal Democrats say they will ‘improve access to counselling for people with mental health problems, by continuing to roll out cognitive and behavioural therapies’. The Tories will ‘increase access to effective ‘talking’ therapies.’ The question remains in all cases, however, how these policies relate to the State. In particular, who defines mental illness, who defines the talking therapy, the behavioural adaptation, the cognitive modification, and how the practitioner who delivers this policy is going to be policed.
The Institute of Group Analysis, in the 7th edition of their newsletter Dialogue (March 2010) illustrates how the insipid creep of the modern British State infiltrates even (!) analysed minds. At their conference (Can Group Therapy Survive NICE: Examining the Evidence) Glenys Parry and Chris Blackmore presented their findings from what is known in these circles as ‘a systematic review’. They were searching for ‘evidence’ of the ‘effectiveness’ of psychodynamic group therapy and group analysis, something they described as ‘difficult’ in the ‘deluge of articles picked up by their search terms’. Nevertheless, they were able to conclude that there was, indeed, broad and consistent evidence for the aforesaid therapies, tho ‘insufficient to distinguish between the various group therapies, and, get this, ‘insufficient randomised controlled trials’.
And thus they can conclude, this puts them ‘in the position of not being able to make a case for inclusion in NICE guidelines apart from in a combined treatment for personality disorder.’
What do do? Chris Mace ‘usefully’ suggested that they do a Cost Benefit Analysis on their Group Analysis! Apparently the Powerpoint presentations can be accessed from the IGA website.
Perhaps you too have had experience of doing a systematic review. You will know that it is made possible by the powerful computerised search engines ploughing mindlessly through databases to pick up keywords across disparate fields. The quantity of papers that line up to be read is literally mind-blowing. Each paper, once a pearl of wisdom situated in an agonistic field, is plucked from its context and thrust into a such a heap that difference, meaning and value are reduced, mashed and beaten to a pulp and any goodness is utterly destroyed.
Perhaps you too have had experience of learning a poem off by heart, or of learning a part in a play. You will know that it is only possible by constantly going over one text. Could there be two more different approaches?
Auden, again, on Freud:
He wasn’t clever at all: he merely told
The unhappy Present to recite the Past
Like a poetry lesson till sooner
Or later it faltered at the line where
Long ago the accusations had begun,
And suddenly knew by whom it had been judged
How rich life had been and how silly
And was life-forgiven and more humble.
The whole poem is well worth a longer look - published by Faber and Faber in the collection Another Time.
Monday, 26 April 2010
Saturday, 17 April 2010
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.)
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.)
Monday, 12 April 2010
The Mystery of FTP. Andrew Marr, Archbishop of Canterbury, Philip Pullman, Mona Sidiqqui and David Baddiel help us to think about the HPC
The big idea written into the circuitry of the HPC is that professional organisations have vested interests which render them unfit to be given statutory power and to conduct their own regulation. Only an organisation free from vested interests is capable of dealing objectively with regulation says the One with the big idea.
This assumes that there are other kinds of organisations that do not have vested interests. Thus a central and longstanding problem is dismissed at a stroke. This blind spot at the heart of the HPC is identical to that which gives prejudice its energy. It gathers together a set of people and separates them from other people through the application of a negative characteristic. Written into the law is the idea that professionals are not to be trusted to regulate themselves, HPC functionaries are.
Before 2001 it was enough for politicians to say ‘we don’t think these professionals are ready to be handed statutory power’. A strong reason for this was the lack of a coherent body of knowledge to bind the field into one. Now it is said that we can make the field into one by defining it as a threat to the public, and then creating a new statutory body to police it.
The HPC appeared as the one organisation incapable of corruption. The benefactor of its virtue was The Public whose vigilance against sinful aspects of itself was needed to make the thing work.
The idea that the HPC is incapable of corruption is linked to the idea that it cannot think for itself but gets its instructions from something unnamable and powerful. This might explain why the professional links to the HPC are largely shrouded in mystery. There are three sacred tomes: Standards of Proficiency, Standards of Education and Training, and Standards of Conduct, Performance and Ethics.
Any problems associated with these three great questions are swept aside with a combination of strategies: consult legal advisors; appoint friendly panels of experts; set up bureaucratic procedures which are somehow not of their own invention nor subject to their influence.
Each of these routines can be seen at work in any of fitness to practise hearings. Today’s example is of a complaint that was prevented from entering the process. This is a part of the picture that rarely gets exposed, but it is nevertheless instructive in that it reveals once more revealing the way in which the HPC interprets its mission and reveals what it considers a sin.
It is worth holding in mind the recent case of psychologist and HPC Council member Malcolm Cross (an excellent report of which is posted on the HPC watchdog blog, written by Bruce Scott). The contrast reveals the working assumptions about the nature of the public the HPC feels it worth protecting, about the kind of sin that it needs to protect the public from, and also about the potential for vested interests to make themselves felt.
The setting, as usual, is the NHS. An employee suspects he is about to be downgraded when a manager re-writes his job description. There is a specific clause in the job contract forbidding unilateral changes, and he suspects the manager is trying to avoid a redundancy situation. He complains to a more senior manager who sits on the paperwork and does nothing about it. The employee (who does not belong to a trade union) engages a lawyer and complains to the Trust. He is vindicated and the managers are prevented from breaking the law. A few weeks later an incident arises at work and the two managers use it to effectively get rid of the thorn in their side. So the employee complains to the HPC that the two managers are acting unprofessionally – the main contention was their intention to break the law by rewriting the job description and failing to activate a grievance.
If Dr Cross’s dinnertime antics register as a possible harm to the public, why does this case not also make the HPC alarm ring?
Here is what the HPC said: “I … understand that both complaints were closed on the basis that the concerns you raised were not considered to relate to the registrants’ fitness to practise as registered professionals.”
The letter is signed by the head of case management who explains that someone else has given her to understand that, following due process, they have judged that the actions are nothing to worry about. She continues:
“Please be advised that your complaints were closed following legal advice from the HPC’s legal advisor. The complaints were not considered by a Panel of the Investigating Committee.”
There is something curious in the form of the letter. In a Humpty Dumpty way she writes: legal advice was gotten from the legal advisor. In repeating the phrase she avoids saying who is actually responsible here, and conjures up the mystery of He whose name cannot be spoken. The repetition effectively creates a screen behind which we may not go. We have to trust that this manager has the experience and wisdom to know that this ok, but we know nothing about her nor how she’s been put to the test. The legal advice also stops the complaint from entering the formal process – it does not go in front of the Panel of the Investigating Committee (populated by registrants and lay-people recruited and trained through the HPC).
She continues:
“I am of the view that the complaints you made against X and Y do not raise public protection issues …
The emplyee’s point was that x and y were trying to over-ride the law to implement their own, local, agenda, and might have used the power of the institution to damage his own less powerful position.
“I am satisfied that your complaints were investigated fully and dealt with appropriately …
Investigated fully? It was legal advice from the legal advisor, not Investigation by the Investigation Panel.
… “Should you remain dissatisfied with the HPC’s decision to close your complaint, it is open to you to make a complaint via the HPC complaints process.”
Such convolutions do not inspire confidence, and neither does the fact that the complaints manager is another HPC employee.
“You should address your complaint to: Mr Greg Ross-Sampson, Director of Operations, HPC…"
Presumably Mr Greg Ross-Sampson will go to the same legal advisor for legal advice and catch our complainant in the same infernal loop.
This complaint has many aspects, and the situation remains in dispute. One of the complications is that the complainant discovered that the manager he was complaining about was the chair of his professional organisation. He now suspects that the manager’s position in the hierarchy, coupled with his liaison with the HPC, has effectively scuppered his complaint. The promise of protection was offered, and this public was disappointed. No ameliorating mechanisms were put into play.
Andrew Marr nailed the problem within the first few minutes of Easter’s Start the Week (BBC R4, Monday, 4 April 2010). In conversation with the Archbishop of Canterbury, Marr said ‘It seems to me that the core of the problem is that of being an institution, because every institution wants to protect itself as an institution’. This, of course, is not news (Max Weber said much the same thing about a century ago), but perhaps more interesting is that Marr was talking not only to Rowan Williams but also to Philip Pullman whose new book (The Good Man Jesus and the Scoundrel Christ) novelises exactly this dilemma. “What we are talking about is the difference between the institution and the essence,” said Marr. Rowan Williams thought a central theme of Pullman’s books was the question of the ‘price you pay for transmitting, in institutional terms, the message’. Pullman thinks the price too high, Williams does not.
Prof Mona Siddiqui tried to elaborate on this difference by reminding everyone that these differences of opinion exist amongst many religious. For example, the Sunni and Shia sects of Islam have almost opposite relationships with bureaucratic structure. Unfortunately, her point was lost as soon as Marr asked: ‘Is it possible to have an effective religion without a huge bureaucracy? To which Williams replied: ‘You need some way of recognising from generation to generation that you are talking about the same mission’. The question became: ‘Does the religion, does the structure, have enough in it to rein the people back from less relevant ends?’
David Baddiel (whose new film The Infidel directed by Josh Appignanesi is out this week), said the urge to institutionalise, along with the tendency to split and form schisms can also be found among atheists.
Mona Siddiqui raised the question of love by distinguishing between institutional expressions of religion (which give context and reference points for people to make sense of it), and the creation and exploitation of sacred leaders. Again, the point was left when Pullman set off on a slightly different tack: ‘There is always an original visionary who speaks about a time that will be coming soon when heaven will be fulfilled and earth will be full of plenty. Of course it doesn’t happen, so an institution is set up in order to validate the vision’. He could have been speaking of politics.
Both Marr and Williams picked up the thread and talked about rules, codes, tick boxes, and the collection of scores to ‘prove’ the truth of the vision. Williams thought ‘this is one of the things that the gospels do try to undermine’, and a bizarre wager was made when the writer pessimistically bet on bureaucracy to always trumps literature, and the Archbishop (optimistically) backed literature to triumph over bureaucracy.
Baddiel thought that the function of bureaucracy was to inject the greater truth into the story and noted how some people could then cash in on the power. Williams thought that this was too instrumental a version, and that it gave people too much intentionality. It is not, he said, really the way a lot of these things start out. But he might have conceded it was the way that a many things proceeded, especially when cut off from the original plot.
But then a pearl of wisdom was dispensed. The Archbishop said: ‘Something happens that releases an explosion of puzzles, more than language can cope with, which leads to a very complicated period. This is when you begin to see the start of bureaucracy.’
He could have been speaking of a pregnancy, a terrorist attack, the triggering of a psychosis, or the conception of the HPC.
This assumes that there are other kinds of organisations that do not have vested interests. Thus a central and longstanding problem is dismissed at a stroke. This blind spot at the heart of the HPC is identical to that which gives prejudice its energy. It gathers together a set of people and separates them from other people through the application of a negative characteristic. Written into the law is the idea that professionals are not to be trusted to regulate themselves, HPC functionaries are.
Before 2001 it was enough for politicians to say ‘we don’t think these professionals are ready to be handed statutory power’. A strong reason for this was the lack of a coherent body of knowledge to bind the field into one. Now it is said that we can make the field into one by defining it as a threat to the public, and then creating a new statutory body to police it.
The HPC appeared as the one organisation incapable of corruption. The benefactor of its virtue was The Public whose vigilance against sinful aspects of itself was needed to make the thing work.
The idea that the HPC is incapable of corruption is linked to the idea that it cannot think for itself but gets its instructions from something unnamable and powerful. This might explain why the professional links to the HPC are largely shrouded in mystery. There are three sacred tomes: Standards of Proficiency, Standards of Education and Training, and Standards of Conduct, Performance and Ethics.
Any problems associated with these three great questions are swept aside with a combination of strategies: consult legal advisors; appoint friendly panels of experts; set up bureaucratic procedures which are somehow not of their own invention nor subject to their influence.
Each of these routines can be seen at work in any of fitness to practise hearings. Today’s example is of a complaint that was prevented from entering the process. This is a part of the picture that rarely gets exposed, but it is nevertheless instructive in that it reveals once more revealing the way in which the HPC interprets its mission and reveals what it considers a sin.
It is worth holding in mind the recent case of psychologist and HPC Council member Malcolm Cross (an excellent report of which is posted on the HPC watchdog blog, written by Bruce Scott). The contrast reveals the working assumptions about the nature of the public the HPC feels it worth protecting, about the kind of sin that it needs to protect the public from, and also about the potential for vested interests to make themselves felt.
The setting, as usual, is the NHS. An employee suspects he is about to be downgraded when a manager re-writes his job description. There is a specific clause in the job contract forbidding unilateral changes, and he suspects the manager is trying to avoid a redundancy situation. He complains to a more senior manager who sits on the paperwork and does nothing about it. The employee (who does not belong to a trade union) engages a lawyer and complains to the Trust. He is vindicated and the managers are prevented from breaking the law. A few weeks later an incident arises at work and the two managers use it to effectively get rid of the thorn in their side. So the employee complains to the HPC that the two managers are acting unprofessionally – the main contention was their intention to break the law by rewriting the job description and failing to activate a grievance.
If Dr Cross’s dinnertime antics register as a possible harm to the public, why does this case not also make the HPC alarm ring?
Here is what the HPC said: “I … understand that both complaints were closed on the basis that the concerns you raised were not considered to relate to the registrants’ fitness to practise as registered professionals.”
The letter is signed by the head of case management who explains that someone else has given her to understand that, following due process, they have judged that the actions are nothing to worry about. She continues:
“Please be advised that your complaints were closed following legal advice from the HPC’s legal advisor. The complaints were not considered by a Panel of the Investigating Committee.”
There is something curious in the form of the letter. In a Humpty Dumpty way she writes: legal advice was gotten from the legal advisor. In repeating the phrase she avoids saying who is actually responsible here, and conjures up the mystery of He whose name cannot be spoken. The repetition effectively creates a screen behind which we may not go. We have to trust that this manager has the experience and wisdom to know that this ok, but we know nothing about her nor how she’s been put to the test. The legal advice also stops the complaint from entering the formal process – it does not go in front of the Panel of the Investigating Committee (populated by registrants and lay-people recruited and trained through the HPC).
She continues:
“I am of the view that the complaints you made against X and Y do not raise public protection issues …
The emplyee’s point was that x and y were trying to over-ride the law to implement their own, local, agenda, and might have used the power of the institution to damage his own less powerful position.
“I am satisfied that your complaints were investigated fully and dealt with appropriately …
Investigated fully? It was legal advice from the legal advisor, not Investigation by the Investigation Panel.
… “Should you remain dissatisfied with the HPC’s decision to close your complaint, it is open to you to make a complaint via the HPC complaints process.”
Such convolutions do not inspire confidence, and neither does the fact that the complaints manager is another HPC employee.
“You should address your complaint to: Mr Greg Ross-Sampson, Director of Operations, HPC…"
Presumably Mr Greg Ross-Sampson will go to the same legal advisor for legal advice and catch our complainant in the same infernal loop.
This complaint has many aspects, and the situation remains in dispute. One of the complications is that the complainant discovered that the manager he was complaining about was the chair of his professional organisation. He now suspects that the manager’s position in the hierarchy, coupled with his liaison with the HPC, has effectively scuppered his complaint. The promise of protection was offered, and this public was disappointed. No ameliorating mechanisms were put into play.
Andrew Marr nailed the problem within the first few minutes of Easter’s Start the Week (BBC R4, Monday, 4 April 2010). In conversation with the Archbishop of Canterbury, Marr said ‘It seems to me that the core of the problem is that of being an institution, because every institution wants to protect itself as an institution’. This, of course, is not news (Max Weber said much the same thing about a century ago), but perhaps more interesting is that Marr was talking not only to Rowan Williams but also to Philip Pullman whose new book (The Good Man Jesus and the Scoundrel Christ) novelises exactly this dilemma. “What we are talking about is the difference between the institution and the essence,” said Marr. Rowan Williams thought a central theme of Pullman’s books was the question of the ‘price you pay for transmitting, in institutional terms, the message’. Pullman thinks the price too high, Williams does not.
Prof Mona Siddiqui tried to elaborate on this difference by reminding everyone that these differences of opinion exist amongst many religious. For example, the Sunni and Shia sects of Islam have almost opposite relationships with bureaucratic structure. Unfortunately, her point was lost as soon as Marr asked: ‘Is it possible to have an effective religion without a huge bureaucracy? To which Williams replied: ‘You need some way of recognising from generation to generation that you are talking about the same mission’. The question became: ‘Does the religion, does the structure, have enough in it to rein the people back from less relevant ends?’
David Baddiel (whose new film The Infidel directed by Josh Appignanesi is out this week), said the urge to institutionalise, along with the tendency to split and form schisms can also be found among atheists.
Mona Siddiqui raised the question of love by distinguishing between institutional expressions of religion (which give context and reference points for people to make sense of it), and the creation and exploitation of sacred leaders. Again, the point was left when Pullman set off on a slightly different tack: ‘There is always an original visionary who speaks about a time that will be coming soon when heaven will be fulfilled and earth will be full of plenty. Of course it doesn’t happen, so an institution is set up in order to validate the vision’. He could have been speaking of politics.
Both Marr and Williams picked up the thread and talked about rules, codes, tick boxes, and the collection of scores to ‘prove’ the truth of the vision. Williams thought ‘this is one of the things that the gospels do try to undermine’, and a bizarre wager was made when the writer pessimistically bet on bureaucracy to always trumps literature, and the Archbishop (optimistically) backed literature to triumph over bureaucracy.
Baddiel thought that the function of bureaucracy was to inject the greater truth into the story and noted how some people could then cash in on the power. Williams thought that this was too instrumental a version, and that it gave people too much intentionality. It is not, he said, really the way a lot of these things start out. But he might have conceded it was the way that a many things proceeded, especially when cut off from the original plot.
But then a pearl of wisdom was dispensed. The Archbishop said: ‘Something happens that releases an explosion of puzzles, more than language can cope with, which leads to a very complicated period. This is when you begin to see the start of bureaucracy.’
He could have been speaking of a pregnancy, a terrorist attack, the triggering of a psychosis, or the conception of the HPC.
Wednesday, 7 April 2010
Invitation to HPC registrants & co
During the last year several people (registrants of the HPC and their clients, patients and employees), have contacted me to tell me about their dreadful experiences with the FTP processes.
One woman was being 'tried' for the third time for the same 'crime' and was well beyond the end of her tether. The patient had complained to the NHS who had listened and decided there was no case, then to the Quality Care Commission, who had listened and found there was no case to answer, and then to the HPC who had ... put their machinery into operation, heeding neither the NHS nor the QCC, nor even their common sense, only to find, months and months later, that ... there was no case to answer. Three times! For exactly the same complaint!
Another case was of a very well known and respected woman who had herself raised a question about the staff in an agency where she once been contracted to work. This irked the agency who found their way to complain about her in their turn. After months and months of work, and loads and loads of money, the case was finally dismissed.
There is a complaint from an individual against one of his NHS bosses. This boss turns out to be a senior member of the profession, a regular visitor to the HPC. The complainant was (therefore?) told there was no case... However, he continues to hold onto the logic of his case, and writes to the HPC regularly. He is trying to call them to account, and is pursuing his argument tenaciously.
Another woman has been trying to get a response from a registrant whose work damaged the relationship she had with her son. The HPC have no resources to offer her, and can only add to her increasing distress.
There are more. Those caught up in the FTP process are very unwilling to tell their story in public for fear of retribution from the HPC. Others are so immersed in the turmoil that writing about it is the last thing on their minds. People I've spoken to after the hearing is over usually just want to disappear back into their lives and try to rebuild their relationships and routines.
This is simply terrible. What is there to be done?
Many people exclaim: it's a waste of tax payers money!
But before dismissing this as untrue, it's really worth thinking about this in detail. The fee that the registrants pay must be agreed in parliament and passed by law. This fee is then levied exactly like a tax. However, the familiar cry: No Taxation Without Representation is not heeded here. The registrants of the HPC cannot vote on the way the money is spent, and cannot call the officials to account for wasting the money they have paid them. It looks more and more like a stealth tax, and one without representation!
A few people have suggested that I open up this blog to other writers and make sections for each of the different professional groups (15 of them at present in the HPC). If you know someone who would like to write an entry, do encourage them to get in touch (click my name in the Contributors Side Panel at the bottom of the list to find my email address). My aim here is to expose the mechanisms of harm, and to show through actual examples what is really going on. It is this kind of real evidence that can convince people gently, and that can even produce a pacifying effect to the otherwise pernicious experience. It's an appeal to natural justice, with the aim of learning from the mistake (no matter who made it) and of making things better for others in the future. At the moment, the HPC is wasting opportunities for learning, and turning local spats into major incidents; this is very negative overall.
In the meantime, anyone can post a comment on any of the articles already here, and these comments can be anonymous. I am more than happy to engage in a conversation, if you are willing to take the time.
Janet
One woman was being 'tried' for the third time for the same 'crime' and was well beyond the end of her tether. The patient had complained to the NHS who had listened and decided there was no case, then to the Quality Care Commission, who had listened and found there was no case to answer, and then to the HPC who had ... put their machinery into operation, heeding neither the NHS nor the QCC, nor even their common sense, only to find, months and months later, that ... there was no case to answer. Three times! For exactly the same complaint!
Another case was of a very well known and respected woman who had herself raised a question about the staff in an agency where she once been contracted to work. This irked the agency who found their way to complain about her in their turn. After months and months of work, and loads and loads of money, the case was finally dismissed.
There is a complaint from an individual against one of his NHS bosses. This boss turns out to be a senior member of the profession, a regular visitor to the HPC. The complainant was (therefore?) told there was no case... However, he continues to hold onto the logic of his case, and writes to the HPC regularly. He is trying to call them to account, and is pursuing his argument tenaciously.
Another woman has been trying to get a response from a registrant whose work damaged the relationship she had with her son. The HPC have no resources to offer her, and can only add to her increasing distress.
There are more. Those caught up in the FTP process are very unwilling to tell their story in public for fear of retribution from the HPC. Others are so immersed in the turmoil that writing about it is the last thing on their minds. People I've spoken to after the hearing is over usually just want to disappear back into their lives and try to rebuild their relationships and routines.
This is simply terrible. What is there to be done?
Many people exclaim: it's a waste of tax payers money!
But before dismissing this as untrue, it's really worth thinking about this in detail. The fee that the registrants pay must be agreed in parliament and passed by law. This fee is then levied exactly like a tax. However, the familiar cry: No Taxation Without Representation is not heeded here. The registrants of the HPC cannot vote on the way the money is spent, and cannot call the officials to account for wasting the money they have paid them. It looks more and more like a stealth tax, and one without representation!
A few people have suggested that I open up this blog to other writers and make sections for each of the different professional groups (15 of them at present in the HPC). If you know someone who would like to write an entry, do encourage them to get in touch (click my name in the Contributors Side Panel at the bottom of the list to find my email address). My aim here is to expose the mechanisms of harm, and to show through actual examples what is really going on. It is this kind of real evidence that can convince people gently, and that can even produce a pacifying effect to the otherwise pernicious experience. It's an appeal to natural justice, with the aim of learning from the mistake (no matter who made it) and of making things better for others in the future. At the moment, the HPC is wasting opportunities for learning, and turning local spats into major incidents; this is very negative overall.
In the meantime, anyone can post a comment on any of the articles already here, and these comments can be anonymous. I am more than happy to engage in a conversation, if you are willing to take the time.
Janet
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