Betty Bertrand-Godfrey very kindly agreed to my posting this here on the blog:
Report on the Manchester ‘Stakeholder’ Meeting organised by the Health Professions Council for UK stakeholders in Counselling and Psychotherapy. 31 March 2009.
By Betty Bertrand-Godfrey, a 'user' of psychoanalysis
As planned I went to the Manchester stakeholder meeting. Clearly the HPC's intention was to make us believe that statutory regulation is good for us - but they must be deluded and desperate.
Deluded first.
Prof Di Waller (HPC Council member, Chair of the Professional Liaison Group for Counselling Psychotherapy, and Arts Psychotherapist registrant of the HPC) opened the day with a very positive statement: " We have got a pretty good start on the work", she said.
I have observed two PLG meetings and I didn't think so. This was confirmed by the discussion we had at the end of the day when the PLG (at last) asked the floor's views on the matter. It was felt strongly that even the split between titles was a problem and suggested that everything was to be put on hold until the HPC finds a better way of dealing with this mammoth tasks. So not a "pretty" but an "ugly" start then!
One highlight of the day for me was Di Waller being genuinely surprised that the "fear of NOS keeps cropping up" (National Operating Standards). At the break I had a quiet word with an HPC representative and told him that having the Chair of NOS from Skills for Health on the PLG certainly does help this "cropping up". I also said that HPC wants to gain our "trust" but how can we do this when we think Prof Fonagy has been pushed in. I must say that the representative looked uneasy with this issue and I sensed almost agreed with me.
HPC denies categorically that it will refer to the NOS guidelines for setting their standards of proficiency and said that "it will actually be quite unhelpful" (Michael Guthrie, Acting Director of Policy and Standards). But in my little chat I also mentioned that if HPC registration goes through then we know it is an open door for further rules to be implemented that will damage the core of most therapeutic work.
Desperate now.
At 11:40, we had the most incredible power point presentation I have ever seen. Mary Smith (Royal College of Speech and Language Therapists, and HPC registrant) put together images and words destined to five-year-olds. She seemed to want to make us believe that registration is fantastic and that we should all go for it with all our hearts and souls. The way she operated was weird, very weird indeed, and clumsy. I felt she was trying to hypnotise the whole room but all she managed to do was irritate us by taking up precious space that could have been dedicated to proper grown-up debate.
In substance she said we should (I am quoting now) "abandon ourselves to the process and leave the professional bodies behind. You need to pass it all over to the HPC. There will be a moment of bereavement and we ourselves (SLT) felt that we were handing stuff away but we need to have that clear blue water (here was the soothing image of a lake on her power point presentation at the same time!) that can only allow the transition". Basically, she said: go to sleep - resistance to HPC is futile! A shame she had to go and could not reflect on Prof Parker's (Manchester Met University) beautiful intervention: he urged people to be cautious, but most of all to THINK.
At last in the afternoon we broke out into rooms. I happened to be with Sally Aldridge (BACP), Jonathan Coe (Witness) representing HPC but more interestingly the stakeholders Prof Darian Leader (College of Psychoanalysts, UK), Dennis Greenwood (Universities Psychotherapy and Counselling Association) and some serious opponents to this process. This is how it should have been right from the beginning. Darian reminded us that the White Paper (Trust Assurance and Safety) says "whether the HPC can accommodate the profession" not how. The "whether" has had no space to be discussed so far.
Then at 2:40pm (after only 40 min of intense discussions in small groups) we got back to the wider group where at last something more real was debated and animosity, fear and anxieties were emerging (which I think surprised the HPC-PLG people). I must say Janet Low (representing the Philadelphia Association), Ian Parker, and Nick Totton (from the Independent Practitioner’s Network) were brilliant and inspirational. The quality of their interventions allowed more people to join in to challenge HPC.
On departing I asked Michael Guthrie if he had the intention to feed back to this group by setting another meeting as people were anxious as to what was going to become of all that was said during the day. I emphasised the need for a real meeting and not some feedback on the HPC website because this is where it all happens.
He said he will have to think about it and thanked me.
Showing posts with label CandP. Show all posts
Showing posts with label CandP. Show all posts
Thursday, 2 April 2009
Wednesday, 1 April 2009
Centralisation in action: The Manchester Stakeholder Meeting
Yesterday (31 March 2009), in Manchester’s Thistle Hotel, the HPC staged a meeting for those who are not quite engaged in the process to draw counsellors and psychotherapists into state regulation. It was a well organised meeting in a nice venue with a lovely lunch. The acting Director of Policy and Standards (Michael Guthrie), the Director of Fitness to Practise (Kelly Johnson), Director of Communications (Jacqueline Ladds), Policy Officers (Sam Mars and Charlotte Urwin), the Secretary, Education Manager (Osama Ammar), Events Manager (Susan Carini), and some other employees were present: young and charming people, all (about 8 or so people).
The HPC elders were represented by the practitioners (or their close associates): President Anna van der Gaag, Di Waller (chair of the PLG), and Annie Turner (Council Member representing Occupational Therapists), then there were the PLG professionals: Fiona Ballantine Dykes (CPCAB), Sally Aldridge (BACP), Peter Fonagy (Skills for Health), Malcolm Allen (BPC), Brian McGee (Counselling and Psychotherapy in Scotland), Kathi Murphy and Carmen Ablack (UKCP), Nick Turner (Relate) and Jonathan Coe representing Witness (formerly POPAN – a user complaints organisation), about 11 people. The other 30 or so in the room included representatives from NICE, IAPT, Universities, NHS, Umbrella organisations for counselling, psychotherapy and psychoanalysis. An analysis of who was there, and what kind of experience they represented and what their positions and questions were would itself be a work involving some considerable effort and time.
The process, however, will squash the difference and reduce the experience to a size that the HPC can manage. This is very small indeed, and is one of the most straightforward destructive effects of intense centralisation. A second effect will follow: in order to show that they have heard everyone, a document will be produced which captures a sentence here, a phrase there, enough to prove in an imaginary (though possible) future thoughtless court of law that consultation has taken place. The meaning of what has been said will have to be sacrificed – it is simply not possible to understand and take it all on, and it will not be possible to write this up in a way that dignifies truth. The process will force the HPC to manufacture a representation that shows that they have consulted, but that can barely hope to benefit directly from the experience.
However, given that human beings are involved it is at least possible that someone could change the course of this infernal machine. That person would have to be a hero, and an unlikely one at that: “the holistic planner overlooks the fact that it is easy to centralize power but impossible to centralize all knowledge which is distributed over many individual minds, and whose centralisation would be necessary for the wise wielding of centralised power. But this fact has far-reaching consequences. Unable to ascertain what is in the minds of many individuals, he must try to control and stereotype interests and beliefs by education and propaganda. But this attempt to exercise power over minds must destroy the last possibility of finding out what people really think, for it is clearly incompatible with the free expression of thought, especially of critical thought.” (THES editorial, quoting Popper’s Nightmare, 8 June 1984) emphasis added.
In the morning were three presentations, first from Di Waller who wants to paint a rosy picture and said ‘We have got a pretty good start on the work" [see previous blogs for another point of view]. She couldn’t understand, tho, why people ‘outside’ kept asking about the relationship of the HPC to the NOS of the SfH. It would be helpful if she, Anna Van der Gaag, and Michael Guthrie explained their reasons for inviting Peter Fonagy, chair of NOS at SfH, to sit on the PLG – that would aid the understanding.
Jonathan Coe was next up, and delivered a horror story of a relationship gone wrong between a therapist and a client. Jonathan, backed up by Peter Fonagy, has been circulating an unsubstantiated statistic that 5% of therapists represent a serious threat to the safety of the public. In the absence of serious research, Jonathan was reduced to ‘bigging it up’ with a story about a poor woman victimised by an evil greasy man and had to resort to bringing the actual woman with him in lieu of proper proof. Many people in the room found this un-ethical, and Darian Leader (President of the UK College of Psychoanalysts) pointed out that in using this story for his own aims, Jonathan was unwittingly repeating elements in the structure of abuse that the substance of the story represented. The presence of the woman in such a context made any discussion of the case impossible: another nail in the coffin of enlightenment, another point offered up to the bogey-man.
After Jonathan, there were two women representing the Royal College of Speech and Language Therapists. They had evidently been briefed – consciously or not – to reassure the stakeholders in this new profession that everything would be alright. Mary Smith kicked off with a power-point presentation that many thought was pitched at the wrong level, and she went on to recount something akin to a fairy story: there had been a lot of worries expressed by members of the SLT profession when it had been their turn for hpc-ification, but in the end they gave in and left their professional concerns behind, passing control over to the HPC. She said there had been a moment of bereavement when they felt that they were giving important things away, and then she said something mysterious: ‘we need to have that clear blue water [here she had a lovely photo on a power point slide presenting the soothing image of a lake] that is necessary for the transition". What on earth does that mean? The message received by some at least was in the form of a bribe: if you shut up and go with the flow, you will get your hands on some power. For Mary this meant access to the corridors of Whitehall, and a chance to influence government. The kind of mind-numbing effect of the HPC process has left its mark on Mary who wondered why her predecessors hadn’t become arch lobbyists. When I suggested that this was because England had not always been a highly centralized system and that it hadn’t been necessary before, she could only respond vaguely about the devolution of Wales, NI, and Scotland, as if this somehow proved a point.
Her colleague Kamini Gadhok might have produced her talk out of a manual of politically-sanctioned phrases. She said: robust regulation, enhanced protection, raised standards, support for the profession, raised profiles, fit for practice, keeping our agenda on the government’s radar, influencing the commissioners, bringing added value, protecting our practice against pressures, enhancing CPD, in line with government policy, improving outcomes, getting up there with the GMC, being invited to the top table, building our capacity. Newspeak? Or a hidden attempt to hypnotise? Nevertheless her power-point slide showed that over the years the Royal College was losing members to the HPC. I asked Kamini what her organization was doing to protect its members from the HPC. This caused a ripple of laughter in the room, but if you check out the case study of Mr R [see side panel index] you will see a staggering example of how the thoughtless process of HPC FTP hearings ride rough shod over perfectly decent practitioners. Kamini said that this had been discussed in their recent AGM. I look forward to the HPC publishing the apology soon.
In the effort to establish a congenial relationship the professional bodies can easily forget that the HPC has in fact been set up on a prejudice against them. Read Ian Kennedy’s book The Unmasking of Medicine (1981), trace his influence in the Bristol Royal Infirmary Inquiry Report, read the HPO2001, and the Section 60 currently before parliament. Instead of the good old fashioned English presumption that people are innocent until proven guilty, we have the idea that professionals constitute a danger that only HPC can overcome. This is why the HPC is made up of administrators without any experience, and why the difficult questions that relate to reality get squeezed out onto the edge and beyond. Professions are made up of people who are forced by their work to face up to the impossibilities that arise in practise. In reality, administrators can only imagine this, or subordinate themselves to the practice. In fantasy, administrators emerge as the only true pure and innocent.
Some of the stakeholders present knew nothing at all about HPC-ification, and had come hoping to be enlightened. They will have to work a lot harder if they want proper, useful, practical information about what the process will mean to them. Others had clearly done some homework. Ian Parker (Manchester Metropolitan University), for example, has read the Government White Paper Trust, Assurance and Safety more carefully than the HPC. In the detail the documents asks "whether the HPC can accommodate the profession" not how it could. He also asked what evidence there was that the form of regulation proposed by the HPC would actually achieve increased protection of the public. These two sensible questions are incredibly difficult to maintain.
Why?
In the afternoon came the ‘breakout groups’ in which the voices of the visitors could be heard. The chair of each group had been briefed to take back three things to the final plenary session. To their credit, all of them took back more. The assumption behind the construction of this meeting was that simple messages and supportive comments wouldn’t take long to deal with. But for those interested in reality and who have the tenacity to tangle with the truth and the conflicts involved, something more is needed.
Throughout the PLG process, difficult issues have emerged only to be ‘parked’ until some mythical future date. Tricky issues are constantly postponed and left in the mist of imagination. In my break-out group I said I was alarmed that the PLG (who are 2/3 of the way through their predefined life) don’t even know whether it will be possible to legally protect the title of counsellor (Michael Guthrie is supposed to be checking this out with the solicitors). All of the discussion so far in those PLG’s presupposes that they can legally own this title. From my point of view this is another sign that the process is rushed and ill-thought through. The expression of my alarm caused alarm and provoked an effort of suppression. John Nightingale (Association of Christian Counsellors) rescued the situation, and returned to it later to get things said straight.
Adrian Rhodes from the European Association for Psychotherapy also expressed an alarm. He said a constant stream of people was hammering on his European door asking what on earth was happening in the UK. Unfortunately, this was condensed into the rather simplistic idea that Europeans felt that ‘standards were being lowered’ which was more or less translated by Di Waller to mean Europeans are ‘elitist’. This rhetorical move needs unpacking. Elite, etymologically, means simply ‘elected’ - those few who are elected to represent the majority who cannot be present themselves. The HPC group is an elite. However, the word has been totally submerged by a wholly pejorative meaning, which effectively brings all conversation to a halt. So, the letter written by European Psychoanalysts expressing their great concern that NOS and HPC will kill off psychoanalysis didn’t get mentioned at all.
Fiona Ballantine Dykes managed to distil 7 sensible points of concern from the discussion in our group, and the HPC admin staff pledged to write this up in a document. The next PLG meeting is due to debate it again, where several of us will be sitting in silence, waiting to hear what they make of it.
Ian Parker’s point from the morning needs to be brought back here – is the HPC process actually paying attention to the question “can it accommodate this profession?” If it has sped forward to “how shall we force it to fit?” (which is what is articulated time and again by those in strategic positions in the process), then the work and the words of the day will have been in vain and the stakeholders meeting will be reduced to a cosmetic event and questions will crumble away. In the plenary session at the end of the day I asked Michael Guthrie directly how the HPC manages dissension within its structures. He said that the professional partners and groups discuss these things outside the main structure, and this is where the difficult issues must ultimately be dealt with. Within the HPC they are confined to act in ways that Government can accommodate. I heard this as a confirmation of Popper’s Nightmare. Someone else said she heard the exact opposite. Two more people tended to agree with me. It will be proved in the future action: will the machinery simply grind on? Or will human beings gain some control over the action?
On Sunday 5th April a meeting will be held in the ULU building on Malet Street London W1, staged by the Alliance for Counselling and Psychotherapy against State Regulation. It will be an important occasion which might load the dice in favour of the human factor. Here is the link to the web-site - click here.
The HPC elders were represented by the practitioners (or their close associates): President Anna van der Gaag, Di Waller (chair of the PLG), and Annie Turner (Council Member representing Occupational Therapists), then there were the PLG professionals: Fiona Ballantine Dykes (CPCAB), Sally Aldridge (BACP), Peter Fonagy (Skills for Health), Malcolm Allen (BPC), Brian McGee (Counselling and Psychotherapy in Scotland), Kathi Murphy and Carmen Ablack (UKCP), Nick Turner (Relate) and Jonathan Coe representing Witness (formerly POPAN – a user complaints organisation), about 11 people. The other 30 or so in the room included representatives from NICE, IAPT, Universities, NHS, Umbrella organisations for counselling, psychotherapy and psychoanalysis. An analysis of who was there, and what kind of experience they represented and what their positions and questions were would itself be a work involving some considerable effort and time.
The process, however, will squash the difference and reduce the experience to a size that the HPC can manage. This is very small indeed, and is one of the most straightforward destructive effects of intense centralisation. A second effect will follow: in order to show that they have heard everyone, a document will be produced which captures a sentence here, a phrase there, enough to prove in an imaginary (though possible) future thoughtless court of law that consultation has taken place. The meaning of what has been said will have to be sacrificed – it is simply not possible to understand and take it all on, and it will not be possible to write this up in a way that dignifies truth. The process will force the HPC to manufacture a representation that shows that they have consulted, but that can barely hope to benefit directly from the experience.
However, given that human beings are involved it is at least possible that someone could change the course of this infernal machine. That person would have to be a hero, and an unlikely one at that: “the holistic planner overlooks the fact that it is easy to centralize power but impossible to centralize all knowledge which is distributed over many individual minds, and whose centralisation would be necessary for the wise wielding of centralised power. But this fact has far-reaching consequences. Unable to ascertain what is in the minds of many individuals, he must try to control and stereotype interests and beliefs by education and propaganda. But this attempt to exercise power over minds must destroy the last possibility of finding out what people really think, for it is clearly incompatible with the free expression of thought, especially of critical thought.” (THES editorial, quoting Popper’s Nightmare, 8 June 1984) emphasis added.
In the morning were three presentations, first from Di Waller who wants to paint a rosy picture and said ‘We have got a pretty good start on the work" [see previous blogs for another point of view]. She couldn’t understand, tho, why people ‘outside’ kept asking about the relationship of the HPC to the NOS of the SfH. It would be helpful if she, Anna Van der Gaag, and Michael Guthrie explained their reasons for inviting Peter Fonagy, chair of NOS at SfH, to sit on the PLG – that would aid the understanding.
Jonathan Coe was next up, and delivered a horror story of a relationship gone wrong between a therapist and a client. Jonathan, backed up by Peter Fonagy, has been circulating an unsubstantiated statistic that 5% of therapists represent a serious threat to the safety of the public. In the absence of serious research, Jonathan was reduced to ‘bigging it up’ with a story about a poor woman victimised by an evil greasy man and had to resort to bringing the actual woman with him in lieu of proper proof. Many people in the room found this un-ethical, and Darian Leader (President of the UK College of Psychoanalysts) pointed out that in using this story for his own aims, Jonathan was unwittingly repeating elements in the structure of abuse that the substance of the story represented. The presence of the woman in such a context made any discussion of the case impossible: another nail in the coffin of enlightenment, another point offered up to the bogey-man.
After Jonathan, there were two women representing the Royal College of Speech and Language Therapists. They had evidently been briefed – consciously or not – to reassure the stakeholders in this new profession that everything would be alright. Mary Smith kicked off with a power-point presentation that many thought was pitched at the wrong level, and she went on to recount something akin to a fairy story: there had been a lot of worries expressed by members of the SLT profession when it had been their turn for hpc-ification, but in the end they gave in and left their professional concerns behind, passing control over to the HPC. She said there had been a moment of bereavement when they felt that they were giving important things away, and then she said something mysterious: ‘we need to have that clear blue water [here she had a lovely photo on a power point slide presenting the soothing image of a lake] that is necessary for the transition". What on earth does that mean? The message received by some at least was in the form of a bribe: if you shut up and go with the flow, you will get your hands on some power. For Mary this meant access to the corridors of Whitehall, and a chance to influence government. The kind of mind-numbing effect of the HPC process has left its mark on Mary who wondered why her predecessors hadn’t become arch lobbyists. When I suggested that this was because England had not always been a highly centralized system and that it hadn’t been necessary before, she could only respond vaguely about the devolution of Wales, NI, and Scotland, as if this somehow proved a point.
Her colleague Kamini Gadhok might have produced her talk out of a manual of politically-sanctioned phrases. She said: robust regulation, enhanced protection, raised standards, support for the profession, raised profiles, fit for practice, keeping our agenda on the government’s radar, influencing the commissioners, bringing added value, protecting our practice against pressures, enhancing CPD, in line with government policy, improving outcomes, getting up there with the GMC, being invited to the top table, building our capacity. Newspeak? Or a hidden attempt to hypnotise? Nevertheless her power-point slide showed that over the years the Royal College was losing members to the HPC. I asked Kamini what her organization was doing to protect its members from the HPC. This caused a ripple of laughter in the room, but if you check out the case study of Mr R [see side panel index] you will see a staggering example of how the thoughtless process of HPC FTP hearings ride rough shod over perfectly decent practitioners. Kamini said that this had been discussed in their recent AGM. I look forward to the HPC publishing the apology soon.
In the effort to establish a congenial relationship the professional bodies can easily forget that the HPC has in fact been set up on a prejudice against them. Read Ian Kennedy’s book The Unmasking of Medicine (1981), trace his influence in the Bristol Royal Infirmary Inquiry Report, read the HPO2001, and the Section 60 currently before parliament. Instead of the good old fashioned English presumption that people are innocent until proven guilty, we have the idea that professionals constitute a danger that only HPC can overcome. This is why the HPC is made up of administrators without any experience, and why the difficult questions that relate to reality get squeezed out onto the edge and beyond. Professions are made up of people who are forced by their work to face up to the impossibilities that arise in practise. In reality, administrators can only imagine this, or subordinate themselves to the practice. In fantasy, administrators emerge as the only true pure and innocent.
Some of the stakeholders present knew nothing at all about HPC-ification, and had come hoping to be enlightened. They will have to work a lot harder if they want proper, useful, practical information about what the process will mean to them. Others had clearly done some homework. Ian Parker (Manchester Metropolitan University), for example, has read the Government White Paper Trust, Assurance and Safety more carefully than the HPC. In the detail the documents asks "whether the HPC can accommodate the profession" not how it could. He also asked what evidence there was that the form of regulation proposed by the HPC would actually achieve increased protection of the public. These two sensible questions are incredibly difficult to maintain.
Why?
In the afternoon came the ‘breakout groups’ in which the voices of the visitors could be heard. The chair of each group had been briefed to take back three things to the final plenary session. To their credit, all of them took back more. The assumption behind the construction of this meeting was that simple messages and supportive comments wouldn’t take long to deal with. But for those interested in reality and who have the tenacity to tangle with the truth and the conflicts involved, something more is needed.
Throughout the PLG process, difficult issues have emerged only to be ‘parked’ until some mythical future date. Tricky issues are constantly postponed and left in the mist of imagination. In my break-out group I said I was alarmed that the PLG (who are 2/3 of the way through their predefined life) don’t even know whether it will be possible to legally protect the title of counsellor (Michael Guthrie is supposed to be checking this out with the solicitors). All of the discussion so far in those PLG’s presupposes that they can legally own this title. From my point of view this is another sign that the process is rushed and ill-thought through. The expression of my alarm caused alarm and provoked an effort of suppression. John Nightingale (Association of Christian Counsellors) rescued the situation, and returned to it later to get things said straight.
Adrian Rhodes from the European Association for Psychotherapy also expressed an alarm. He said a constant stream of people was hammering on his European door asking what on earth was happening in the UK. Unfortunately, this was condensed into the rather simplistic idea that Europeans felt that ‘standards were being lowered’ which was more or less translated by Di Waller to mean Europeans are ‘elitist’. This rhetorical move needs unpacking. Elite, etymologically, means simply ‘elected’ - those few who are elected to represent the majority who cannot be present themselves. The HPC group is an elite. However, the word has been totally submerged by a wholly pejorative meaning, which effectively brings all conversation to a halt. So, the letter written by European Psychoanalysts expressing their great concern that NOS and HPC will kill off psychoanalysis didn’t get mentioned at all.
Fiona Ballantine Dykes managed to distil 7 sensible points of concern from the discussion in our group, and the HPC admin staff pledged to write this up in a document. The next PLG meeting is due to debate it again, where several of us will be sitting in silence, waiting to hear what they make of it.
Ian Parker’s point from the morning needs to be brought back here – is the HPC process actually paying attention to the question “can it accommodate this profession?” If it has sped forward to “how shall we force it to fit?” (which is what is articulated time and again by those in strategic positions in the process), then the work and the words of the day will have been in vain and the stakeholders meeting will be reduced to a cosmetic event and questions will crumble away. In the plenary session at the end of the day I asked Michael Guthrie directly how the HPC manages dissension within its structures. He said that the professional partners and groups discuss these things outside the main structure, and this is where the difficult issues must ultimately be dealt with. Within the HPC they are confined to act in ways that Government can accommodate. I heard this as a confirmation of Popper’s Nightmare. Someone else said she heard the exact opposite. Two more people tended to agree with me. It will be proved in the future action: will the machinery simply grind on? Or will human beings gain some control over the action?
On Sunday 5th April a meeting will be held in the ULU building on Malet Street London W1, staged by the Alliance for Counselling and Psychotherapy against State Regulation. It will be an important occasion which might load the dice in favour of the human factor. Here is the link to the web-site - click here.
Tuesday, 3 March 2009
PLG C&P March 3rd meeting
18 uniformed officers were waiting at the gate of the station tonight when I returned from the 1st day of this 3rd meeting of the HPC PLG for C&P. 18 uniformed officers to check the validity of our train tickets. Such a concentration of power for such a silly job is a rather stark example of how out of balance stuff is in the UK today. Perhaps they are protecting the public from leaving the station quickly. 18 uniformed officers (half of them wearing padded flack jackets over already portly tummies) rather choke the little underpass to the street.
Meanwhile in a bland office in a back street near Elephant & Castle 11 non-representatives of the counselling and psychotherapy world met together with about 20 other people in order to say nothing of importance from 10.30am till 3.30pm. They will meet again tomorrow, and I can only hope that they manage to muster the courage to utter a coherent and definitive sentence between them at least once in the meeting.
To be fair, two or three people did make valiant attempts to keep it real, but they were swimming against a tide of platitudes, point scoring and polite snipes.
The 11 non-representatives from the world of counselling and psychotherapy were selected by Diane Waller (an arts psychotherapist) in conversation with Anna van der Gaag (a speech and language therapist) and Michael Guthrie (an administrator). There had been 40 or so applications, some from individuals, some from organisations. A little list of criteria had been written down and Di, Anna and Michael made their longer list with this. Since then, they have been bombarded with emails and letters and visits about the non-representative nature of the 11 they selected. Today, at the opening of the meeting Diane Waller set out to make a statement. She wanted to set the record straight: the 11 non-hpc people round the table should know that they had not been selected to represent their particular group, but were simply there to ... err, to, well, the only specific thing I heard her say was to hold onto Wales as an idea (because not one amongst them was Welsh).
This is just one example of the mad rules that the group are supposed to abide by. How can Sally Aldridge not represent the BACP? She is their paid Director on precisely this question. They have several thousand members. If she has anything sensible to say, it would be from her experience in that job. Surely she should restrict herself to this, not exclude herself. She should inform the rest of the group about the real practical issues at stake in transferring this particular membership onto the HPC register - this is her specialist subject. What about Mick Cooper? He is a professor of counselling (a relatively new breed of professor, the evolution of which would be very interesting to track) from Strathclyde University. He does not represent the University. So he can speak from a different position, and people can hear him in his capacity of intellectual and scholar, or whatever indeed he is. Peter Fonagy? He is there under the auspice of the Skills for Health - he can restrict himself to talking about the National Operating Standards that are his responsibility to coordinate. Each member of the group has a specific position from which they can speak authoritatively, what's the problem? They have been chosen according to those criteria, haven't they? So why does Diane begin today's meeting by describing the rationality of their selection, then forbidding them to be precisely that? She ended her little lecture by strongly emphasising that those 11 non-representatives should Reinforce and Remind people of their non-representativeness, 'that would be helpful' she said.
Mad.
Difficult questions get parked, reparked and parked again. Topics are constantly left for another day. Another day? There are only 4 days left for this group of people to come up with something that is destined to be turned into law. LAW. Do we need any more laws in this country? There are already more laws than Parliament knows what to do with, and a handful of politicians at Saturday's Convention on Modern Liberty were even pledging to repeal dozens at a time. What is the point of turning this mess into a legal document? The field we know as counselling and psychotherapy is so diverse, so rooted in relationships and places, so firmly fixed amongst ordinary people that the wish to legislate it into a neat standardised package should rather be written into next DSM as a sectionable mental illness.
It is so difficult to sit silently watching this process. It feels like being forced to watch a child being drowned, and forbidden even from throwing a rope.
It is extremely difficult to report on anything of substance. Nothing of substance emerged. However, two things are worth passing on. In the moments before the meeting started this morning one of the HPC lay members on the PLG suddenly came over to show us a CHRE document. This was one of the documents that teach doctors not to have sex with their patients. This document was offered to us in answer to the question raised at the last meeting about the source of the data that Fonagy and Jon Coe were trumpeting that 5% of C&P practitioners constitute a real and present danger. Here is a great example of the real trouble that this group has. A group of eminent and intelligent people are unable to think clearly in this process. We were offered this document as the evidence that 5% of therapists and counsellors were dangerous. I thought she meant that the reference to the paper that produced the statistic would be in there. But no. What was there was the fact that some doctors have sex with or marry their patients. This is absolutely barmy. Well meant, but barmy.
The second notable moment came at lunch time: three of us 'public' were eating lunch together when one of the 11 non-representatives came and sat down beside us. She asked us for our advice - what would we say if it were us who had landed at that powerful table? This was a real live thinking human being and it was a massive relief to discover it. So what would we say? Keep it Real. And she did - after lunch she tried and tried and tried again to keep reality in the picture. I'm not talking about anecdotes - she was furnishing the meeting with real information about things that she knows about, that are actually happening out there. What a relief. I'm going to start a collection to raise a statue for her if she carries on like this.
Meanwhile in a bland office in a back street near Elephant & Castle 11 non-representatives of the counselling and psychotherapy world met together with about 20 other people in order to say nothing of importance from 10.30am till 3.30pm. They will meet again tomorrow, and I can only hope that they manage to muster the courage to utter a coherent and definitive sentence between them at least once in the meeting.
To be fair, two or three people did make valiant attempts to keep it real, but they were swimming against a tide of platitudes, point scoring and polite snipes.
The 11 non-representatives from the world of counselling and psychotherapy were selected by Diane Waller (an arts psychotherapist) in conversation with Anna van der Gaag (a speech and language therapist) and Michael Guthrie (an administrator). There had been 40 or so applications, some from individuals, some from organisations. A little list of criteria had been written down and Di, Anna and Michael made their longer list with this. Since then, they have been bombarded with emails and letters and visits about the non-representative nature of the 11 they selected. Today, at the opening of the meeting Diane Waller set out to make a statement. She wanted to set the record straight: the 11 non-hpc people round the table should know that they had not been selected to represent their particular group, but were simply there to ... err, to, well, the only specific thing I heard her say was to hold onto Wales as an idea (because not one amongst them was Welsh).
This is just one example of the mad rules that the group are supposed to abide by. How can Sally Aldridge not represent the BACP? She is their paid Director on precisely this question. They have several thousand members. If she has anything sensible to say, it would be from her experience in that job. Surely she should restrict herself to this, not exclude herself. She should inform the rest of the group about the real practical issues at stake in transferring this particular membership onto the HPC register - this is her specialist subject. What about Mick Cooper? He is a professor of counselling (a relatively new breed of professor, the evolution of which would be very interesting to track) from Strathclyde University. He does not represent the University. So he can speak from a different position, and people can hear him in his capacity of intellectual and scholar, or whatever indeed he is. Peter Fonagy? He is there under the auspice of the Skills for Health - he can restrict himself to talking about the National Operating Standards that are his responsibility to coordinate. Each member of the group has a specific position from which they can speak authoritatively, what's the problem? They have been chosen according to those criteria, haven't they? So why does Diane begin today's meeting by describing the rationality of their selection, then forbidding them to be precisely that? She ended her little lecture by strongly emphasising that those 11 non-representatives should Reinforce and Remind people of their non-representativeness, 'that would be helpful' she said.
Mad.
Difficult questions get parked, reparked and parked again. Topics are constantly left for another day. Another day? There are only 4 days left for this group of people to come up with something that is destined to be turned into law. LAW. Do we need any more laws in this country? There are already more laws than Parliament knows what to do with, and a handful of politicians at Saturday's Convention on Modern Liberty were even pledging to repeal dozens at a time. What is the point of turning this mess into a legal document? The field we know as counselling and psychotherapy is so diverse, so rooted in relationships and places, so firmly fixed amongst ordinary people that the wish to legislate it into a neat standardised package should rather be written into next DSM as a sectionable mental illness.
It is so difficult to sit silently watching this process. It feels like being forced to watch a child being drowned, and forbidden even from throwing a rope.
It is extremely difficult to report on anything of substance. Nothing of substance emerged. However, two things are worth passing on. In the moments before the meeting started this morning one of the HPC lay members on the PLG suddenly came over to show us a CHRE document. This was one of the documents that teach doctors not to have sex with their patients. This document was offered to us in answer to the question raised at the last meeting about the source of the data that Fonagy and Jon Coe were trumpeting that 5% of C&P practitioners constitute a real and present danger. Here is a great example of the real trouble that this group has. A group of eminent and intelligent people are unable to think clearly in this process. We were offered this document as the evidence that 5% of therapists and counsellors were dangerous. I thought she meant that the reference to the paper that produced the statistic would be in there. But no. What was there was the fact that some doctors have sex with or marry their patients. This is absolutely barmy. Well meant, but barmy.
The second notable moment came at lunch time: three of us 'public' were eating lunch together when one of the 11 non-representatives came and sat down beside us. She asked us for our advice - what would we say if it were us who had landed at that powerful table? This was a real live thinking human being and it was a massive relief to discover it. So what would we say? Keep it Real. And she did - after lunch she tried and tried and tried again to keep reality in the picture. I'm not talking about anecdotes - she was furnishing the meeting with real information about things that she knows about, that are actually happening out there. What a relief. I'm going to start a collection to raise a statue for her if she carries on like this.
Thursday, 5 February 2009
HPC PLG C&P day 2, pm
Towards the end of the HPC PLG for C&P last week the group started thinking about their next meetings. According to the work plan written down by Mr Guthrie, most of these meetings will be taken up with the question of Education and Training/standards of proficiency.
As the group approached this they revived something that Diane Waller had mentioned and parked a bit earlier. It was the question of 'life coaches' and people using other titles but doing similar work. Mr Guthrie had reminded the group that the process was about Protecting Titles, not function. This left the difficult question of figuring out how the HPC could guarantee anyone on its register without recourse to training and validation of practise. There is also the question of what they would do if people simply invented a new title for their work.
This is the way the nightmare works. Having invented a name, they now have to invent a new practise that fits the name and that they can police, otherwise they have no power whatsoever. It is a where the twist in the law is most obvious. The mistake Ian Kennedy and his followers made was to imagine a group of people who were the exception to the rule. The rule was that professionals were not to be trusted, the exception to this rule could alone solve this problem. The exception to this rule is the HPC. When Ian Kennedy said so casually 'why should they [the medics] have the power over life and death' he implicitly also said 'it should be us, who are better'. Which is, of course, nonsense.
What follows is a compact and incomplete account of some of the discussion. I've given it like this as an antidote to the anodyne minutes which reduce all the differences in the group to a single unanimous voice. I have also included their names so that anyone reading this blog might decide to engage in a conversation with any of these people (simple to figure out how through google) on some of the points that they make.
Jonathan Coe (Witness CE) said "The need for standards in professional training is what will protect the public."
Graham Smith (HPC Panel, Physio) linked this to the 'intention to deceive'.
Karen Ablack (UKCP standing in for Kathi Murphy) remarked that 'if people are not doing it [therapy] well enough and they are using my professional title then ...' she left it to her body language to indicate what she would do (flush them down the loo, I guess, she seemed to
indicate poo).
Mary Clark Glass (HPC Panel lay member) said 'we'll get them on it - if you go beyond your skills and competence, you will be called to account'.
Someone said "Prevention is the better protection of the public"
Finally Julian Lousada (BCP) remarked 'we've parked a difficult issue' to which
Diane Waller (chair) replied 'we can be seen to have done justice to the question'.
Sally Aldridge (BACP) then offered to exhume a dead and buried report done by the big 5 some years ago [UKCP, BACP, BPS, BCP, BABCP I think] which had tried and failed to synthesise competencies across the board. Someone else offered another similar dead and buried document, and Peter Fonagy (SfH) offered his NOS. All were eagerly accepted as fodder for the next few meetings.
In this way the work done in these other places by these other people for those other purposes are going to emerge into this tight schedule and could easily be taken up for want of the time to make something more suitable. This is how bad laws get made, and its other people who are going to suffer the consequences without any idea how it happened to them. That's why I'm writing this blog.
As the group approached this they revived something that Diane Waller had mentioned and parked a bit earlier. It was the question of 'life coaches' and people using other titles but doing similar work. Mr Guthrie had reminded the group that the process was about Protecting Titles, not function. This left the difficult question of figuring out how the HPC could guarantee anyone on its register without recourse to training and validation of practise. There is also the question of what they would do if people simply invented a new title for their work.
This is the way the nightmare works. Having invented a name, they now have to invent a new practise that fits the name and that they can police, otherwise they have no power whatsoever. It is a where the twist in the law is most obvious. The mistake Ian Kennedy and his followers made was to imagine a group of people who were the exception to the rule. The rule was that professionals were not to be trusted, the exception to this rule could alone solve this problem. The exception to this rule is the HPC. When Ian Kennedy said so casually 'why should they [the medics] have the power over life and death' he implicitly also said 'it should be us, who are better'. Which is, of course, nonsense.
What follows is a compact and incomplete account of some of the discussion. I've given it like this as an antidote to the anodyne minutes which reduce all the differences in the group to a single unanimous voice. I have also included their names so that anyone reading this blog might decide to engage in a conversation with any of these people (simple to figure out how through google) on some of the points that they make.
Jonathan Coe (Witness CE) said "The need for standards in professional training is what will protect the public."
Graham Smith (HPC Panel, Physio) linked this to the 'intention to deceive'.
Karen Ablack (UKCP standing in for Kathi Murphy) remarked that 'if people are not doing it [therapy] well enough and they are using my professional title then ...' she left it to her body language to indicate what she would do (flush them down the loo, I guess, she seemed to
indicate poo).
Mary Clark Glass (HPC Panel lay member) said 'we'll get them on it - if you go beyond your skills and competence, you will be called to account'.
Someone said "Prevention is the better protection of the public"
Finally Julian Lousada (BCP) remarked 'we've parked a difficult issue' to which
Diane Waller (chair) replied 'we can be seen to have done justice to the question'.
Sally Aldridge (BACP) then offered to exhume a dead and buried report done by the big 5 some years ago [UKCP, BACP, BPS, BCP, BABCP I think] which had tried and failed to synthesise competencies across the board. Someone else offered another similar dead and buried document, and Peter Fonagy (SfH) offered his NOS. All were eagerly accepted as fodder for the next few meetings.
In this way the work done in these other places by these other people for those other purposes are going to emerge into this tight schedule and could easily be taken up for want of the time to make something more suitable. This is how bad laws get made, and its other people who are going to suffer the consequences without any idea how it happened to them. That's why I'm writing this blog.
Friday, 30 January 2009
The Lobbed letter: a few home truths
In yesterday's PLG C&P meeting there was a section devoted to the question 'conscientious objection'. This matter had been reduced to 3 lines in Michael Guthrie's report for the group, but it turns out that some members of the PLG had also received a letter from the College of Psychoanalysts UK. Perhaps not everyone had received it, and it wasn't actually mentioned by anyone on the day. But the letter has now been published on the website of the College of Psychoanalysts-UK (click heading for link).
Dear PLG Member,
We are writing to you as a member of the HPC Professional Liaison Group because we believe it is valuable for all those on this important committee to have equal access to information concerning the question of the proposed HPC regulation of talking therapies and the consultation process so far. This process, unfortunately, has failed to remain faithful to the original Department of Health remit to include representation from the breadth of the professional field and to respect the difference and diversity of the stakeholders concerned. Documents recently released under the Freedom of Information Act, which will be detailed below, make this clear and give us serious concern about the parity and transparency of the consultation to date. There are three main issues here:
. Misunderstandings about the commitment of all psychotherapy groups to appropriate regulation of the profession in the interests of public protection and the vitality of psychotherapy.
. The importance of explicitly reflecting the particular and differing nature of the psychotherapies in the mechanisms of regulation.
. The hijacking of the process by a minority section of the profession to the exclusion of others.
From the first PLG meeting held on 4/12/08 it seemed apparent that the scope for discussion of these difficult issues is likely to be very limited, with the danger that they will be treated as inconveniences to be given an airing and then ignored. We believe it is important that you are aware that they are not minor details and that thousands of clinicians, as well as academics, intellectuals and public figures, across the country are gravely concerned about the high risks involved in a hasty and ill-informed consultation process. A major media campaign will begin later this year which will draw public attention to these problems.
We understand that it is not the HPC's task to assess whether it is fit for the undertaking the Government has given it, yet that it is within the scope of the PLG to comment on the appropriateness of HPC regulation of the talking therapies and to understand and reflect on the relevant arguments. These arguments relate specifically to the issue of the effectiveness of any future register, the protection of the public and the concern that the action of the HPC in carrying out the task of regulation be proportionate to the requirement that the public be protected. Commitment to Regulation
We, and all psychotherapy organisations of which we are aware, have been actively committed to regulation for many years. The self-regulatory systems which have been developed over the last 20 years have grown in sophistication and effectiveness and are continuing to do so. When critiques of the proposed HPC regulatory framework are formulated, the response is often that this is because the clinicians in question just don't want regulation. This is a major misunderstanding. The concern is not with regulation, which already exists, but that the proposed process of HPC regulation will narrow the broad practice of psychotherapy, making much of what currently takes place in reputable psychotherapy consulting rooms illegal in the near future. We are also concerned that the Government's insistence that all psychotherapies be subsumed under the Health Professionals' umbrella will inevitably impose on psychotherapies the same framework as fits the health professions but does not translate to a non health-care profession such as ours.
To date, neither HPC nor Skills for Health have published a risk analysis of the field of psychotherapy, nor research into appropriate forms for its regulation. In Australia, the government aimed initially to regulate psychotherapists and counsellors under a healthcare model, yet after a three year consultation period, they accepted that counsellors were best left to self-regulate, and the same result looks set to happen for psychotherapy. The government there has recognised that statutory self-regulation works better for the protection of the public and for the life of the profession itself. The Australian consultation demonstrated that:
. Counselling and psychotherapy are fundamentally different from the majority of health professions.
. The focus of 'talking therapy' is the relationship and the process of therapy, rather than the performance of certain definable procedures.
. It is difficult and even unhelpful to define competences and scopes of practice in a narrow legalistic sense.
. A diversity of training bodies, professional associations, and theoretical approaches is both a strength and a weakness and requires a model that respects diversity while being clear about standards.
. The profession would be best managed within a self-regulatory model based on professional colleges, which will have the necessary expertise to link training standards and practice.
It seems important to us that the question of the regulation of talking therapies which explicitly claim not to be health-related be given proper consideration. Many clinicians see their work as an exploration of the human condition, a journey in the same sense that becoming a Buddhist monk involves a long process of questioning one's life, ideals and expectations. Like a Buddhist training, this long process of psychotherapy cannot be identified with a set of techniques or procedures to be applied to a human being, but forms rather a strange kind of relationship which operates in unpredictable and unexpected ways. One cannot know what will happen in advance, and change often takes place through surprise, bafflement, shock and disappointment.
The Particularity of the Talking Therapies
The results of the Skills for Health consultation on psychoanalytic/psychodynamic therapy were published recently in draft form. These are the so-called National Occupational Standards (NOS). They list 451 criteria and guidelines for psychodynamic and psychoanalytic therapy. They dictate every aspect of how therapists should organise their sessions, how they should 'monitor' themselves and how they should carry out their work. They go into minute detail about the timing of interventions, the setting of the therapy, its aims - and even the expression of appropriate 'feelings'. Such an application of externally-imposed rules - most of which were expressly contraindicated by Freud, Jung and the analysts who followed, such as Klein, Lacan and Winnicott - removes the very foundation on which such therapies are based, namely the freedom of both parties to work together authentically and creatively.
If these rules were to be accepted, then it would no longer be possible for many clinicians to work in this country. Although the HPC has been keen to point out their independence from Skills For Health (SfH), it has also been made very clear that the work done by SfH on National Occupational Standards will 'inform' the work carried out by HPC. The NOS draft is an extremely controversial document and the process by which it was arrived at has been shown to be highly partisan, an issue we will come to presently. If the HPC has to gain a full understanding of the profession it hopes to regulate, this understanding risks being biased by the influence of the SfH project. The SfH project has attempted to shoehorn analytic work into the current culture of outcomes, where all variables must be predicted in advance and evaluated in relation to expected results. Analysis, however, and many forms of psychotherapy, involve an open-ended relationship, where results may emerge that were never predicted or even thought of by the person in analysis. The very distinction between conscious and unconscious motivation that lies at the heart of analytic work is ignored by the proposed regulations which encourage a 'false self', a box-ticking clinician, fearful of being watched by the authorities and anxious to please them. If analysis has an aim, it is to help patients free themselves from irrational forms of authority, exactly those that now threaten to constrain their work within the therapy.
According to the government roadmap, HPC will establish a list of reputable practitioners, which will mean effectively those who adopt their particular formulations as to what talking therapy is about. All the documentation published to date by HPC shows a serious misunderstanding of the nature of analytic work, together with a new insistence on 'good character' defined in highly rigid ways. If this goes ahead, then members of the public will no longer have the freedom to choose their analyst, a fact already brought up by user groups. They will have to select a practitioner from a list which only includes those who practise a particular form of therapy. Practitioners who are totally opposed to the idea of their work as 'healthcare' will have to adopt a healthcare model and become 'model citizens', when the whole of the analytic tradition emphasises that the practitioner's human failings are essential for the analysand to recognise and work with.
Nearly all of the professional groups in the field have agreed that HPC is not suitable as a regulator for a variety of reasons, yet one in particular stands out regarding analytic work. In this work, the analyst puts themself in the place of the object of all the projections of the analysand. Powerful feelings of hatred, disappointment and rage that had once been directed to one's caregivers and then repressed or negated may emerge and now be directed to the analyst. These are features of the phenomenon known as 'transference'. The analysand will not be aware that this is happening, and hence a long, difficult and painful period may follow when these feelings are clarified and worked through. At the same time, the analysand may realise that the analyst is no expert but just a fallible and weak human being. The sanitised image of the practitioner aimed at by HPC cannot fit this model, just as the complaints procedures they adopt are not sensitive to the crucial question of transference. Analytic work requires, in a sense, that the analyst should become a scapegoat, and at the same time, act unpredictably or even shockingly. How else, after all, to overcome the defensive system that someone may have spent their whole life constructing? Change in analytic work rarely comes about by the polite communication of some hypothesis ('When you were a child, X must have happened..'), but through interventions that may seem, or indeed may be, totally unacceptable to the analysand. This is how analysis works, and it is unlikely that HPC complaints panels would be well-suited to assess the complexity and often hidden nature of such issues within a culture where complaints against practitioners by their patients are openly encouraged by the regulator. An extensive literature exists on this question, which has been totally absent from all bibliographies published to date during the consultation process.
Hijacking of the Consultation Process
The consultation process initiated by the Department of Health was intended to assess the feasibility and suitability of state regulation through dialogue with all of the professional field. However, Skills for Health allowed their consultation to be monopolised by a very small number of people with both a narrow and restrictive view of psychoanalytic practice and, arguably, a clear agenda to further their own particular brand of therapy which they endeavour to promote within the NHS. The task of drafting psychodynamic/psychoanalytic competences was given by Skills for Health to Tony Roth and Steve Pilling, employees in the UCL Sub-Department of Clinical Health Psychology run by Peter Fonagy. Fonagy, in fact, chaired the Executive Group and the Strategy Group of the SfH project and also sits on the Reference Group. These researchers, aside from having the link to Fonagy, are known for their work on CBT, a set of therapies which are totally at odds with psychoanalysis and most psychodynamic therapies. It is extraordinary that the work was given to them rather than to one of the many university departments of psychoanalysis in the UK. It raises the question of how the UCL department managed to secure this contract.
This bias was continued in the composition of the project Expert Reference Group and the Modality Working Group, both of which were chaired by Anthony Bateman. Bateman is a close colleague of Fonagy and the two have co-authored a treatment manual for a form of therapy (MBT) which they endeavour to promote within the NHS. Fonagy is Director of the Anna Freud Centre, which holds courses on MBT in conjunction with the UCL Sub-Department of Clinical Health Psychology. These courses are held for those working in the NHS and generate revenue for the institution concerned. There is thus a clear line of economic benefit here. It is perhaps no accident that the competences produced for psychodynamic/psychoanalytic therapy fit MBT remarkably well, but not psychoanalytic work.
It is important for the PLG to be aware here of some history. The BPC is a network of organisations centred around the British Psychoanalytical Society, also known as the Institute of Psychoanalysis - of which Fonagy, Bateman and Julian Lousada are members - an organisation which for many years claimed to be the only psychoanalytic training body in this country. They repeatedly published statements that only their own members were psychoanalysts, and even wrote to newspapers claiming that those who pursued other psychoanalytic trainings were deceiving the public. Over the years many other psychoanalytic organisations were established, attracting trainees who were not drawn to the Institute's practices, their theoretical orientations or the ethics of their selection procedures: gay trainees were not accepted until quite recently. As the absurdity of this position became clear, they moderated their claim to a monopoly, yet there is still a real tension between the Institute - and hence the BPC groups - and the other non-BPC psychoanalytic training organisations in the UK. This is a major political factor in the current regulatory landscape.
The composition of the Expert Reference Group and the Modality Working Group is biased quite radically in favour of BPC - Fonagy and Bateman's organisation - with nearly all members coming from there. The list for the Psychodynamic Modality Group established on 16/10/07 consisted off 11 people, all of whom come from the BPC. Another list sent by SfH to Fonagy in January 2008 received the reply that it "goes slightly too far in the direction of UKCP", yet this list of 16 people included 2 from UKCP compared with 11 from BPC. UKCP, moreover, had pointed out to SfH in Jan 08 that it represented the majority of psychoanalytic practitioners in the UK. Documents released under the Freedom of Information Act show how the lists for the work groups were made up almost exclusively of those from BPC and that, when other names of organisations or user groups that had actually been invited to participate were proposed or added to the lists by SfH, they mysteriously vanish. When further information on these disappearances was requested by The College of Psychoanalysts-UK under the Freedom of Information Act, SfH replied by sending hundreds of pages of totally irrelevant documents relating to the CBT groups and then claimed that they could not help further as they were only obliged by the Act to perform a certain number of hours work collating documents.
We also believe that some BPC groups may have failed to inform their members of developments in the consultation process, with a handful of those on the relevant committees making claims for their membership without proper consultation. It is remarkable how nearly everyone involved in the SfH working groups either comes from BPC or the Fonagy UCL Department. In the list of PLG members that HPC have published, Fonagy's institution is listed as Skills for Health, an extraordinary claim given that, as far as we know, he is not an employee of SfH and is in fact associated with the British Psychoanalytic Council, the same organisation as the person preceding him on the PLG list. If Fonagy's affiliation had been stated correctly, it would obviously have shown a bias in the PLG composition. HPC has thus not acted with transparency in this matter.
Fonagy, likewise, has been relied on in a wholly unprecedented way by SfH: in an email of 19.10.07, Linda Hardy of SfH writes re Fonagy "I sort of feel I don't want to ask him everything". The PLG should be aware that Fonagy is a highly controversial figure in the world of psychoanalysis. He has advocated genetic testing as a guide to focus psychotherapy intervention and brain scanning to 'test' the results of psychodynamic work. He has termed the traditional neuroses 'disease processes' or 'weaknesses in brain function', and even encouraged brain scanning of two year old infants to determine whether psychotherapy intervention is necessary (as reported in The Times 12/5/07). For many, probably most psychotherapists, these are extreme views. There are also other questions here: in an email to SfH he states (incorrectly) that The College is a "largely Lacanian organisation" and then follows this with : "French psychoanalyst - Lacan - intellectual superhero but clinical and ethical problem, ultimately dismissed from the rank of the international psychoanalytic movement". Yet the very same Fonagy can refer on the dustjacket of a recent analytic book to "the intellectual sparkle of Lacanian psychoanalytic scholarship" and "the highest quality Lacanian thinking, creating a firm bridge between two forms of psychoanalytic theorisation that have for too long been separated by inadequate understanding". In September 2007 the UCL department apparently sent out a letter inviting participation in the expert reference group for psychodynamic therapy, yet this letter was not received by any psychotherapy organisation that we aware of. It stated that the general framework would be that used for CBT, a fact which would have caused a great deal of protest in the profession had it been known. The methodology of the work is stated as "identifying manuals published in the UK, the US and elsewhere and building the framework from these sources". This would also have caused a great deal of protest in the field for the simple reason that there are no manuals of psychoanalysis, a fact which Fonagy himself points out in a minuted SfH meeting of 11/4/08. On 5/2/08, Roth and Pilling claim to have sourced "the psychoanalytic treatment manuals" for the criteria they have formulated, yet in the list supplied by them in May 2008 to accompany the NOS there are no psychoanalytic texts at all! The result of the dominance of Fonagy and his colleagues in the consultation process has been the exclusion of other voices : professional groups and user groups have been excluded, despite initial inclusion in draft documents, and the Skills for Health team have even conspired to lie directly to an accredited therapist seeking representation in one of the work groups who had been invited to participate. Steven Richards, Chair of the British Society for Clinical Psychophysiology, contacted SfH on 18.10.07 requesting involvement in the cognitive and psychodynamic work groups. Linda Hardy of SfH writes to Rod Holland, who Fonagy had recommended to SfH to chair this group, on 25.10.07, that "We need not have him on the group if you are not happy - I'll rely on your superior knowledge of the therapies here!". This illustrates SfH's failure to do their work properly, leaving the process open to political manoeuvering. Holland writes that Richard's school of therapy "is at variance with most concepts of CBT", yet SfH do not assess this claim or even object to the exclusion of a diverse practice. Hardy then writes to Richards on 29.10.07, "I contacted the chair of the group with your information and he feels that at this stage, with numbers on the group nearing capacity we really need to give the remaining few places to NHS employed practitioners as they are really underrepresented on the groups". In fact, it is because, as she writes to Marc Lyall two hours earlier on the same day, "Rod does not want this guy on the group.However I'm not sure what to say back to him - it's difficult when we invite people to show an interest and then tell them they can't join a group.I could say we are now seeking more NHS employed practitioners as they are under represented on the groups? [sic]".
When a Freedom of Information Act disclosure made these emails available to Richards, and he took them up with SfH, new correspondence was brought forward - strangely not included in the initial disclosure - which it is quite possible and even likely that SfH actually fabricated (further details available on request). The College has also written to SfH regarding an item of correspondence which we believe was falsified in order to cover themselves about another issue.
SfH appear to have failed to conduct the appropriate research for themselves, relying almost exclusively on 'outsourcing' opinion about what is legitimate and what isn't: this means emailing one of a handful of 'experts' to ask if an academic or clinician that SfH had themselves invited to be part of the consultation process should in fact be 'invited'. These distortions to the consultation process have effectively ruled out a rational assessment of the feasibility and suitability of state regulation. We very much hope that this has been of use to you in laying out some of the detail behind this difficult issue, and to assure you of our good faith in our effort to ensure that you all have full access to the information that is available. The College would be pleased to meet with you to discuss any of these issues further.
Yours sincerely,
Prof. Darian Leader President, College of Psychoanalysts-UK
Dear PLG Member,
We are writing to you as a member of the HPC Professional Liaison Group because we believe it is valuable for all those on this important committee to have equal access to information concerning the question of the proposed HPC regulation of talking therapies and the consultation process so far. This process, unfortunately, has failed to remain faithful to the original Department of Health remit to include representation from the breadth of the professional field and to respect the difference and diversity of the stakeholders concerned. Documents recently released under the Freedom of Information Act, which will be detailed below, make this clear and give us serious concern about the parity and transparency of the consultation to date. There are three main issues here:
. Misunderstandings about the commitment of all psychotherapy groups to appropriate regulation of the profession in the interests of public protection and the vitality of psychotherapy.
. The importance of explicitly reflecting the particular and differing nature of the psychotherapies in the mechanisms of regulation.
. The hijacking of the process by a minority section of the profession to the exclusion of others.
From the first PLG meeting held on 4/12/08 it seemed apparent that the scope for discussion of these difficult issues is likely to be very limited, with the danger that they will be treated as inconveniences to be given an airing and then ignored. We believe it is important that you are aware that they are not minor details and that thousands of clinicians, as well as academics, intellectuals and public figures, across the country are gravely concerned about the high risks involved in a hasty and ill-informed consultation process. A major media campaign will begin later this year which will draw public attention to these problems.
We understand that it is not the HPC's task to assess whether it is fit for the undertaking the Government has given it, yet that it is within the scope of the PLG to comment on the appropriateness of HPC regulation of the talking therapies and to understand and reflect on the relevant arguments. These arguments relate specifically to the issue of the effectiveness of any future register, the protection of the public and the concern that the action of the HPC in carrying out the task of regulation be proportionate to the requirement that the public be protected. Commitment to Regulation
We, and all psychotherapy organisations of which we are aware, have been actively committed to regulation for many years. The self-regulatory systems which have been developed over the last 20 years have grown in sophistication and effectiveness and are continuing to do so. When critiques of the proposed HPC regulatory framework are formulated, the response is often that this is because the clinicians in question just don't want regulation. This is a major misunderstanding. The concern is not with regulation, which already exists, but that the proposed process of HPC regulation will narrow the broad practice of psychotherapy, making much of what currently takes place in reputable psychotherapy consulting rooms illegal in the near future. We are also concerned that the Government's insistence that all psychotherapies be subsumed under the Health Professionals' umbrella will inevitably impose on psychotherapies the same framework as fits the health professions but does not translate to a non health-care profession such as ours.
To date, neither HPC nor Skills for Health have published a risk analysis of the field of psychotherapy, nor research into appropriate forms for its regulation. In Australia, the government aimed initially to regulate psychotherapists and counsellors under a healthcare model, yet after a three year consultation period, they accepted that counsellors were best left to self-regulate, and the same result looks set to happen for psychotherapy. The government there has recognised that statutory self-regulation works better for the protection of the public and for the life of the profession itself. The Australian consultation demonstrated that:
. Counselling and psychotherapy are fundamentally different from the majority of health professions.
. The focus of 'talking therapy' is the relationship and the process of therapy, rather than the performance of certain definable procedures.
. It is difficult and even unhelpful to define competences and scopes of practice in a narrow legalistic sense.
. A diversity of training bodies, professional associations, and theoretical approaches is both a strength and a weakness and requires a model that respects diversity while being clear about standards.
. The profession would be best managed within a self-regulatory model based on professional colleges, which will have the necessary expertise to link training standards and practice.
It seems important to us that the question of the regulation of talking therapies which explicitly claim not to be health-related be given proper consideration. Many clinicians see their work as an exploration of the human condition, a journey in the same sense that becoming a Buddhist monk involves a long process of questioning one's life, ideals and expectations. Like a Buddhist training, this long process of psychotherapy cannot be identified with a set of techniques or procedures to be applied to a human being, but forms rather a strange kind of relationship which operates in unpredictable and unexpected ways. One cannot know what will happen in advance, and change often takes place through surprise, bafflement, shock and disappointment.
The Particularity of the Talking Therapies
The results of the Skills for Health consultation on psychoanalytic/psychodynamic therapy were published recently in draft form. These are the so-called National Occupational Standards (NOS). They list 451 criteria and guidelines for psychodynamic and psychoanalytic therapy. They dictate every aspect of how therapists should organise their sessions, how they should 'monitor' themselves and how they should carry out their work. They go into minute detail about the timing of interventions, the setting of the therapy, its aims - and even the expression of appropriate 'feelings'. Such an application of externally-imposed rules - most of which were expressly contraindicated by Freud, Jung and the analysts who followed, such as Klein, Lacan and Winnicott - removes the very foundation on which such therapies are based, namely the freedom of both parties to work together authentically and creatively.
If these rules were to be accepted, then it would no longer be possible for many clinicians to work in this country. Although the HPC has been keen to point out their independence from Skills For Health (SfH), it has also been made very clear that the work done by SfH on National Occupational Standards will 'inform' the work carried out by HPC. The NOS draft is an extremely controversial document and the process by which it was arrived at has been shown to be highly partisan, an issue we will come to presently. If the HPC has to gain a full understanding of the profession it hopes to regulate, this understanding risks being biased by the influence of the SfH project. The SfH project has attempted to shoehorn analytic work into the current culture of outcomes, where all variables must be predicted in advance and evaluated in relation to expected results. Analysis, however, and many forms of psychotherapy, involve an open-ended relationship, where results may emerge that were never predicted or even thought of by the person in analysis. The very distinction between conscious and unconscious motivation that lies at the heart of analytic work is ignored by the proposed regulations which encourage a 'false self', a box-ticking clinician, fearful of being watched by the authorities and anxious to please them. If analysis has an aim, it is to help patients free themselves from irrational forms of authority, exactly those that now threaten to constrain their work within the therapy.
According to the government roadmap, HPC will establish a list of reputable practitioners, which will mean effectively those who adopt their particular formulations as to what talking therapy is about. All the documentation published to date by HPC shows a serious misunderstanding of the nature of analytic work, together with a new insistence on 'good character' defined in highly rigid ways. If this goes ahead, then members of the public will no longer have the freedom to choose their analyst, a fact already brought up by user groups. They will have to select a practitioner from a list which only includes those who practise a particular form of therapy. Practitioners who are totally opposed to the idea of their work as 'healthcare' will have to adopt a healthcare model and become 'model citizens', when the whole of the analytic tradition emphasises that the practitioner's human failings are essential for the analysand to recognise and work with.
Nearly all of the professional groups in the field have agreed that HPC is not suitable as a regulator for a variety of reasons, yet one in particular stands out regarding analytic work. In this work, the analyst puts themself in the place of the object of all the projections of the analysand. Powerful feelings of hatred, disappointment and rage that had once been directed to one's caregivers and then repressed or negated may emerge and now be directed to the analyst. These are features of the phenomenon known as 'transference'. The analysand will not be aware that this is happening, and hence a long, difficult and painful period may follow when these feelings are clarified and worked through. At the same time, the analysand may realise that the analyst is no expert but just a fallible and weak human being. The sanitised image of the practitioner aimed at by HPC cannot fit this model, just as the complaints procedures they adopt are not sensitive to the crucial question of transference. Analytic work requires, in a sense, that the analyst should become a scapegoat, and at the same time, act unpredictably or even shockingly. How else, after all, to overcome the defensive system that someone may have spent their whole life constructing? Change in analytic work rarely comes about by the polite communication of some hypothesis ('When you were a child, X must have happened..'), but through interventions that may seem, or indeed may be, totally unacceptable to the analysand. This is how analysis works, and it is unlikely that HPC complaints panels would be well-suited to assess the complexity and often hidden nature of such issues within a culture where complaints against practitioners by their patients are openly encouraged by the regulator. An extensive literature exists on this question, which has been totally absent from all bibliographies published to date during the consultation process.
Hijacking of the Consultation Process
The consultation process initiated by the Department of Health was intended to assess the feasibility and suitability of state regulation through dialogue with all of the professional field. However, Skills for Health allowed their consultation to be monopolised by a very small number of people with both a narrow and restrictive view of psychoanalytic practice and, arguably, a clear agenda to further their own particular brand of therapy which they endeavour to promote within the NHS. The task of drafting psychodynamic/psychoanalytic competences was given by Skills for Health to Tony Roth and Steve Pilling, employees in the UCL Sub-Department of Clinical Health Psychology run by Peter Fonagy. Fonagy, in fact, chaired the Executive Group and the Strategy Group of the SfH project and also sits on the Reference Group. These researchers, aside from having the link to Fonagy, are known for their work on CBT, a set of therapies which are totally at odds with psychoanalysis and most psychodynamic therapies. It is extraordinary that the work was given to them rather than to one of the many university departments of psychoanalysis in the UK. It raises the question of how the UCL department managed to secure this contract.
This bias was continued in the composition of the project Expert Reference Group and the Modality Working Group, both of which were chaired by Anthony Bateman. Bateman is a close colleague of Fonagy and the two have co-authored a treatment manual for a form of therapy (MBT) which they endeavour to promote within the NHS. Fonagy is Director of the Anna Freud Centre, which holds courses on MBT in conjunction with the UCL Sub-Department of Clinical Health Psychology. These courses are held for those working in the NHS and generate revenue for the institution concerned. There is thus a clear line of economic benefit here. It is perhaps no accident that the competences produced for psychodynamic/psychoanalytic therapy fit MBT remarkably well, but not psychoanalytic work.
It is important for the PLG to be aware here of some history. The BPC is a network of organisations centred around the British Psychoanalytical Society, also known as the Institute of Psychoanalysis - of which Fonagy, Bateman and Julian Lousada are members - an organisation which for many years claimed to be the only psychoanalytic training body in this country. They repeatedly published statements that only their own members were psychoanalysts, and even wrote to newspapers claiming that those who pursued other psychoanalytic trainings were deceiving the public. Over the years many other psychoanalytic organisations were established, attracting trainees who were not drawn to the Institute's practices, their theoretical orientations or the ethics of their selection procedures: gay trainees were not accepted until quite recently. As the absurdity of this position became clear, they moderated their claim to a monopoly, yet there is still a real tension between the Institute - and hence the BPC groups - and the other non-BPC psychoanalytic training organisations in the UK. This is a major political factor in the current regulatory landscape.
The composition of the Expert Reference Group and the Modality Working Group is biased quite radically in favour of BPC - Fonagy and Bateman's organisation - with nearly all members coming from there. The list for the Psychodynamic Modality Group established on 16/10/07 consisted off 11 people, all of whom come from the BPC. Another list sent by SfH to Fonagy in January 2008 received the reply that it "goes slightly too far in the direction of UKCP", yet this list of 16 people included 2 from UKCP compared with 11 from BPC. UKCP, moreover, had pointed out to SfH in Jan 08 that it represented the majority of psychoanalytic practitioners in the UK. Documents released under the Freedom of Information Act show how the lists for the work groups were made up almost exclusively of those from BPC and that, when other names of organisations or user groups that had actually been invited to participate were proposed or added to the lists by SfH, they mysteriously vanish. When further information on these disappearances was requested by The College of Psychoanalysts-UK under the Freedom of Information Act, SfH replied by sending hundreds of pages of totally irrelevant documents relating to the CBT groups and then claimed that they could not help further as they were only obliged by the Act to perform a certain number of hours work collating documents.
We also believe that some BPC groups may have failed to inform their members of developments in the consultation process, with a handful of those on the relevant committees making claims for their membership without proper consultation. It is remarkable how nearly everyone involved in the SfH working groups either comes from BPC or the Fonagy UCL Department. In the list of PLG members that HPC have published, Fonagy's institution is listed as Skills for Health, an extraordinary claim given that, as far as we know, he is not an employee of SfH and is in fact associated with the British Psychoanalytic Council, the same organisation as the person preceding him on the PLG list. If Fonagy's affiliation had been stated correctly, it would obviously have shown a bias in the PLG composition. HPC has thus not acted with transparency in this matter.
Fonagy, likewise, has been relied on in a wholly unprecedented way by SfH: in an email of 19.10.07, Linda Hardy of SfH writes re Fonagy "I sort of feel I don't want to ask him everything". The PLG should be aware that Fonagy is a highly controversial figure in the world of psychoanalysis. He has advocated genetic testing as a guide to focus psychotherapy intervention and brain scanning to 'test' the results of psychodynamic work. He has termed the traditional neuroses 'disease processes' or 'weaknesses in brain function', and even encouraged brain scanning of two year old infants to determine whether psychotherapy intervention is necessary (as reported in The Times 12/5/07). For many, probably most psychotherapists, these are extreme views. There are also other questions here: in an email to SfH he states (incorrectly) that The College is a "largely Lacanian organisation" and then follows this with : "French psychoanalyst - Lacan - intellectual superhero but clinical and ethical problem, ultimately dismissed from the rank of the international psychoanalytic movement". Yet the very same Fonagy can refer on the dustjacket of a recent analytic book to "the intellectual sparkle of Lacanian psychoanalytic scholarship" and "the highest quality Lacanian thinking, creating a firm bridge between two forms of psychoanalytic theorisation that have for too long been separated by inadequate understanding". In September 2007 the UCL department apparently sent out a letter inviting participation in the expert reference group for psychodynamic therapy, yet this letter was not received by any psychotherapy organisation that we aware of. It stated that the general framework would be that used for CBT, a fact which would have caused a great deal of protest in the profession had it been known. The methodology of the work is stated as "identifying manuals published in the UK, the US and elsewhere and building the framework from these sources". This would also have caused a great deal of protest in the field for the simple reason that there are no manuals of psychoanalysis, a fact which Fonagy himself points out in a minuted SfH meeting of 11/4/08. On 5/2/08, Roth and Pilling claim to have sourced "the psychoanalytic treatment manuals" for the criteria they have formulated, yet in the list supplied by them in May 2008 to accompany the NOS there are no psychoanalytic texts at all! The result of the dominance of Fonagy and his colleagues in the consultation process has been the exclusion of other voices : professional groups and user groups have been excluded, despite initial inclusion in draft documents, and the Skills for Health team have even conspired to lie directly to an accredited therapist seeking representation in one of the work groups who had been invited to participate. Steven Richards, Chair of the British Society for Clinical Psychophysiology, contacted SfH on 18.10.07 requesting involvement in the cognitive and psychodynamic work groups. Linda Hardy of SfH writes to Rod Holland, who Fonagy had recommended to SfH to chair this group, on 25.10.07, that "We need not have him on the group if you are not happy - I'll rely on your superior knowledge of the therapies here!". This illustrates SfH's failure to do their work properly, leaving the process open to political manoeuvering. Holland writes that Richard's school of therapy "is at variance with most concepts of CBT", yet SfH do not assess this claim or even object to the exclusion of a diverse practice. Hardy then writes to Richards on 29.10.07, "I contacted the chair of the group with your information and he feels that at this stage, with numbers on the group nearing capacity we really need to give the remaining few places to NHS employed practitioners as they are really underrepresented on the groups". In fact, it is because, as she writes to Marc Lyall two hours earlier on the same day, "Rod does not want this guy on the group.However I'm not sure what to say back to him - it's difficult when we invite people to show an interest and then tell them they can't join a group.I could say we are now seeking more NHS employed practitioners as they are under represented on the groups? [sic]".
When a Freedom of Information Act disclosure made these emails available to Richards, and he took them up with SfH, new correspondence was brought forward - strangely not included in the initial disclosure - which it is quite possible and even likely that SfH actually fabricated (further details available on request). The College has also written to SfH regarding an item of correspondence which we believe was falsified in order to cover themselves about another issue.
SfH appear to have failed to conduct the appropriate research for themselves, relying almost exclusively on 'outsourcing' opinion about what is legitimate and what isn't: this means emailing one of a handful of 'experts' to ask if an academic or clinician that SfH had themselves invited to be part of the consultation process should in fact be 'invited'. These distortions to the consultation process have effectively ruled out a rational assessment of the feasibility and suitability of state regulation. We very much hope that this has been of use to you in laying out some of the detail behind this difficult issue, and to assure you of our good faith in our effort to ensure that you all have full access to the information that is available. The College would be pleased to meet with you to discuss any of these issues further.
Yours sincerely,
Prof. Darian Leader President, College of Psychoanalysts-UK
Sunday, 25 January 2009
Preparing for the next PLG for C&P, 28/29 Jan 09: structure of register
The complexity of this is mind boggling. What is in a name? How can we pin it down? What relation does it have to the practise, to reality, to the real?
Part of this document attempts to summarise points from documents received by HPC in its 'Call for Ideas'. Leaving aside questions of method, science, and truth, it is sufficient to note that 31 named institutions are quoted in this text, including Skills for Health, 'The NHS', IAPT, and New Ways of Working for Psychological Therapists.
Some other institutions include The Tavistock Centre for Couple Relationships, The Association for Rational and Emotive Behaviour Therapy, The Cambridge Body Psychotherapy Centre, The Association of Counsellors and Psychotherapists in Primary Care, and the Stirling District Mental Health Association.
In the spirit of scientific endeavour it would be valid to note the huge variety of responders, including several people speaking in their own name. In fact, this might be the most important point to note. The practise that is currently in question (conjured up by the phrase 'counselling and psychotherapy) is enormously diverse. There are those who think this is the most valid characteristic of a dynamic, responsive field of work - it is close to the ground, answerable to the roots of its practise, known through its context and locality. There are others who think this is a horrible mess that does not convince The Public of its solid knowledge base. This latter group are the ones who work tirelessly to reduce the diversity to a singularity which will be more easily managed by faceless bureaucrats in a centralised institution. These would be the foot soldiers that knowingly or not form the army that populate Popper's Nightmare (see video link in the side panel).
Part of this document attempts to summarise points from documents received by HPC in its 'Call for Ideas'. Leaving aside questions of method, science, and truth, it is sufficient to note that 31 named institutions are quoted in this text, including Skills for Health, 'The NHS', IAPT, and New Ways of Working for Psychological Therapists.
Some other institutions include The Tavistock Centre for Couple Relationships, The Association for Rational and Emotive Behaviour Therapy, The Cambridge Body Psychotherapy Centre, The Association of Counsellors and Psychotherapists in Primary Care, and the Stirling District Mental Health Association.
In the spirit of scientific endeavour it would be valid to note the huge variety of responders, including several people speaking in their own name. In fact, this might be the most important point to note. The practise that is currently in question (conjured up by the phrase 'counselling and psychotherapy) is enormously diverse. There are those who think this is the most valid characteristic of a dynamic, responsive field of work - it is close to the ground, answerable to the roots of its practise, known through its context and locality. There are others who think this is a horrible mess that does not convince The Public of its solid knowledge base. This latter group are the ones who work tirelessly to reduce the diversity to a singularity which will be more easily managed by faceless bureaucrats in a centralised institution. These would be the foot soldiers that knowingly or not form the army that populate Popper's Nightmare (see video link in the side panel).
More on the meaning of a 'Public Gallery'
Dear Mr Seale
Thank you for your letter dated 21 January, which I received yesterday.
I am surprised and pleased to hear that I am the first to take the trouble to draw to your attention the strange seating arrangements of your rooms, and the first to spend time reflecting on the unintended or unexpected consequences of this. It is good to be of use and to bring something new to light. I wonder, though, why you decline to engage with me on the point. When I described the layout to a colleague, he was most surprised. He had thought that 'public gallery' meant what it said.
I had no idea you were also seated here during the course of that meeting, but am happy to hear you were not uncomfortable. However, I am surprised you are not aware that you and I are in different positions and that this has a bearing on my experience, also it seems necessary to say that though you weren't made uncomfortable this is not evidence that I was not uncomfortable. I do wonder why you are so quick to dismiss my point.
My suggestion that the coffee tables could easily give way to the comfort of the public remains true. It was a simple suggestion made in good will, which you have completely overlooked.
I have been unable to fathom the meaning of your third paragraph (that the public is not expected to participate in the actual meeting itself). In a court of law, a lecture room, or indeed an opera house the audience might not be expected to participate in the actual thing itself, but nevertheless has a role to play. Moreover, it must be rare for the audience to be confined to a corner, and obliged continually to look askance at the backs of many players’ heads.
My other question related to designating the speakers with names and positions - both seating and substantial. Your reply addresses only 2 of my 4 points. You supplied a list of names and organisational associations, but I also asked for their position statements and where they were seated. Even the minimum would have been a welcome addition to the day - my neighbours also spent many minutes looking for such a list on and about the chairs. I understand that you are not obliged, and that we might have brought our own copy, etc but be assured a few of us at least had expected it as a courtesy.
There is little courtesy here, in fact, and I am indeed surprised. Your reply is rather mechanical and lacks a human touch. This gives me cause for concern.
One final point – I should like you to know that I have been writing a blog called ‘hpcwatchdog’ for a few months now, and that I would like to record this correspondence there. May I suppose that you will let me know if you don't agree to this act?
Yours sincerely
Thank you for your letter dated 21 January, which I received yesterday.
I am surprised and pleased to hear that I am the first to take the trouble to draw to your attention the strange seating arrangements of your rooms, and the first to spend time reflecting on the unintended or unexpected consequences of this. It is good to be of use and to bring something new to light. I wonder, though, why you decline to engage with me on the point. When I described the layout to a colleague, he was most surprised. He had thought that 'public gallery' meant what it said.
I had no idea you were also seated here during the course of that meeting, but am happy to hear you were not uncomfortable. However, I am surprised you are not aware that you and I are in different positions and that this has a bearing on my experience, also it seems necessary to say that though you weren't made uncomfortable this is not evidence that I was not uncomfortable. I do wonder why you are so quick to dismiss my point.
My suggestion that the coffee tables could easily give way to the comfort of the public remains true. It was a simple suggestion made in good will, which you have completely overlooked.
I have been unable to fathom the meaning of your third paragraph (that the public is not expected to participate in the actual meeting itself). In a court of law, a lecture room, or indeed an opera house the audience might not be expected to participate in the actual thing itself, but nevertheless has a role to play. Moreover, it must be rare for the audience to be confined to a corner, and obliged continually to look askance at the backs of many players’ heads.
My other question related to designating the speakers with names and positions - both seating and substantial. Your reply addresses only 2 of my 4 points. You supplied a list of names and organisational associations, but I also asked for their position statements and where they were seated. Even the minimum would have been a welcome addition to the day - my neighbours also spent many minutes looking for such a list on and about the chairs. I understand that you are not obliged, and that we might have brought our own copy, etc but be assured a few of us at least had expected it as a courtesy.
There is little courtesy here, in fact, and I am indeed surprised. Your reply is rather mechanical and lacks a human touch. This gives me cause for concern.
One final point – I should like you to know that I have been writing a blog called ‘hpcwatchdog’ for a few months now, and that I would like to record this correspondence there. May I suppose that you will let me know if you don't agree to this act?
Yours sincerely
Thursday, 22 January 2009
The responsibility and respect of the public
Dear Dr Anna van der Gaag (President of the HPC)
You were kind enough to welcome us as members of the public, to the first meeting of the PLG for Counselling and Psychotherapy (4 December). In now occurs to me that you might be the person to ask for something quite mundane yet vital in preparation for the next two day ordeal (28 and 29 January).
I found it very uncomfortable at the last meeting partly on account of the strange arrangement of the seating. I had expected to be seated in a 'public gallery' which would afford me the opportunity to view the proceedings and aid my listening and understanding. As it turned out, we were crammed into a corner, and forced to look at the backs of several heads. It was often difficult to know who was speaking as the name tags were not at all visible, this made it difficult for me to follow the discussion at times.
I am rather dreading the repeat of this experience, especially as it will be spread over two days. I have raised this with Messrs Bendall and Seale, but have yet to receive a reply.
But the discomfort of the public gallery was also caused by the substance of the meeting. For example, there were two members of the HPC panel present in this meeting who took up a lot of valuable time apparently reassuring the new professional representatives that in spite of widespread objections from the profession, resistance was going to be futile. This might have been amusing had it been said succinctly, but it was said more than once and at length, which suggests that humour was not the intention. This was odd - what can have been their meaning? Resistance is futile. Wasn't this what the Borg were famous for saying? I should very much have liked to have asked.
A second occasion arose when the spokesman for Skills for Health said there was evidence that 5% of therapists were a serious threat to the public. Can this really be true? Shocking! The HPC say that only 0.23% of other professions represent such a menace. No-one on the committee challenged him. Someone should have. I did wonder whether we had a duty in the public gallery to shout out at that point. What would happen if a voice of conscience were to emit from the back of the room?
It is difficult to know where to post one's questions in all this, and this is why I have finally come up with the idea to write to you. There was more than one moment in the proceedings when our quiet cramped corner was shuffling and muttering under its breath as some committee member or other talked rot. Perhaps there could be a way for the meeting to tolerate or even benefit from some of this frustration. After all, any theatre, even a court of law, can benefit from the feedback of the audience if the performance is outstanding in any way. I hope that the Chairman of the Group is capable of tolerating a groan, a guffaw, or a gasp at least issuing from the back of the room, tho I am sure this would be altogether better managed if we were first accorded the dignity of a properly constructed space.
I do hope you are able to respond.
Yours sincerely
You were kind enough to welcome us as members of the public, to the first meeting of the PLG for Counselling and Psychotherapy (4 December). In now occurs to me that you might be the person to ask for something quite mundane yet vital in preparation for the next two day ordeal (28 and 29 January).
I found it very uncomfortable at the last meeting partly on account of the strange arrangement of the seating. I had expected to be seated in a 'public gallery' which would afford me the opportunity to view the proceedings and aid my listening and understanding. As it turned out, we were crammed into a corner, and forced to look at the backs of several heads. It was often difficult to know who was speaking as the name tags were not at all visible, this made it difficult for me to follow the discussion at times.
I am rather dreading the repeat of this experience, especially as it will be spread over two days. I have raised this with Messrs Bendall and Seale, but have yet to receive a reply.
But the discomfort of the public gallery was also caused by the substance of the meeting. For example, there were two members of the HPC panel present in this meeting who took up a lot of valuable time apparently reassuring the new professional representatives that in spite of widespread objections from the profession, resistance was going to be futile. This might have been amusing had it been said succinctly, but it was said more than once and at length, which suggests that humour was not the intention. This was odd - what can have been their meaning? Resistance is futile. Wasn't this what the Borg were famous for saying? I should very much have liked to have asked.
A second occasion arose when the spokesman for Skills for Health said there was evidence that 5% of therapists were a serious threat to the public. Can this really be true? Shocking! The HPC say that only 0.23% of other professions represent such a menace. No-one on the committee challenged him. Someone should have. I did wonder whether we had a duty in the public gallery to shout out at that point. What would happen if a voice of conscience were to emit from the back of the room?
It is difficult to know where to post one's questions in all this, and this is why I have finally come up with the idea to write to you. There was more than one moment in the proceedings when our quiet cramped corner was shuffling and muttering under its breath as some committee member or other talked rot. Perhaps there could be a way for the meeting to tolerate or even benefit from some of this frustration. After all, any theatre, even a court of law, can benefit from the feedback of the audience if the performance is outstanding in any way. I hope that the Chairman of the Group is capable of tolerating a groan, a guffaw, or a gasp at least issuing from the back of the room, tho I am sure this would be altogether better managed if we were first accorded the dignity of a properly constructed space.
I do hope you are able to respond.
Yours sincerely
Thursday, 15 January 2009
Preparing for the next PLG for C&P, 28/29 Jan 09
[email sent 19th January]
Dear Mr Seale
Looking forward to the HPC PLG for C&P meeting next week, 28 and 29 January, I have written to Mr Bendall to ask if it is possible to organise the room differently so that the public gallery is accorded more respect. I understand that Mr Bendall is not in today, and I suspect he may not be the correct person to whom to address this request, so I have taken the liberty of writing to you.
The problem I refer to is the way the furniture is organised. We are rather pushed into the corner and forced to look at the back of people's heads. This makes it uncomfortable but also very difficult to ascertain who is speaking, and thereby to understand the position from which to make sense of their words.
I think it is common practice for rooms to be organised along the lines of a theatre when the public is allowed to observe. This would be a very welcome innovation not only in the PLG, but also for the fitness to practice hearings and, of course, all other events at which the public is included.
At the very least, if you are unable to innovate in time for next week, may I suggest that you remove the coffee table to another room and allow the seats to occupy the whole of the back wall. Also, it would be enormously helpful to provide a list of the names of the people on the PLG, their affiliation, their position statement, and the seating plan. This would go a long way to relieving the situation.
Yours sincerely
Name and address supplied
Dear Mr Seale
Looking forward to the HPC PLG for C&P meeting next week, 28 and 29 January, I have written to Mr Bendall to ask if it is possible to organise the room differently so that the public gallery is accorded more respect. I understand that Mr Bendall is not in today, and I suspect he may not be the correct person to whom to address this request, so I have taken the liberty of writing to you.
The problem I refer to is the way the furniture is organised. We are rather pushed into the corner and forced to look at the back of people's heads. This makes it uncomfortable but also very difficult to ascertain who is speaking, and thereby to understand the position from which to make sense of their words.
I think it is common practice for rooms to be organised along the lines of a theatre when the public is allowed to observe. This would be a very welcome innovation not only in the PLG, but also for the fitness to practice hearings and, of course, all other events at which the public is included.
At the very least, if you are unable to innovate in time for next week, may I suggest that you remove the coffee table to another room and allow the seats to occupy the whole of the back wall. Also, it would be enormously helpful to provide a list of the names of the people on the PLG, their affiliation, their position statement, and the seating plan. This would go a long way to relieving the situation.
Yours sincerely
Name and address supplied
Sunday, 27 July 2008
Regulating counselling and psychotherapy via HPC
Excerpts from the HPC doc. I include it here because I am surprised by the rather grand way it states its right to intervene in other people's practise in the name of public safety without saying what that means nor why they (the HPC) are less of a threat than any one else. There are many questions begged by this document which I hope to gradually unpack.
Introduction
We are seeking the views of stakeholders on the potential statutory regulation of psychotherapists and counsellors.
About us:
We are the Health Professions Council (HPC). We are a regulator and our job is to protect the health and wellbeing of people who use the services of the health professionals registered with us. To protect the public, we set standards that health professionals must meet. Our standards cover health professionals’ education and training, behaviour, professional skills, and their health. We publish a Register of health professionals who meet our standards.
Health professionals on our Register are called ‘registrants’. If registrants do not meet our standards, we can take action against them which may include removing them from the Register so that they can no longer practise.
About statutory regulation
• Statutory regulation of psychotherapists and counsellors
In February 2007, the government published a White Paper on the future of regulation, ‘Trust, Assurance and Safety – The Regulation of Health Professionals in the 21st Century’.
The White Paper said: ‘The government is planning to introduce statutory regulation
for…psychotherapists and counsellors…’ (page 81) ‘…psychotherapists and counsellors will be regulated by the Health Professions Council, following that Council’s rigorous process of assessing their regulatory needs and ensuring that its system is capable of accommodating them. This will be the first priority for future regulation.’ (page 85)
Subject to the necessary legislative approval, the White Paper indicated that psychotherapists and counsellors would be regulated by the HPC in the future.
We are therefore undertaking this project in anticipation of that legislative approval. [emphasis added] However, please note that the outcome will be subject to any final decisions made by the UK and Scottish Parliaments.
Introduction
We are seeking the views of stakeholders on the potential statutory regulation of psychotherapists and counsellors.
About us:
We are the Health Professions Council (HPC). We are a regulator and our job is to protect the health and wellbeing of people who use the services of the health professionals registered with us. To protect the public, we set standards that health professionals must meet. Our standards cover health professionals’ education and training, behaviour, professional skills, and their health. We publish a Register of health professionals who meet our standards.
Health professionals on our Register are called ‘registrants’. If registrants do not meet our standards, we can take action against them which may include removing them from the Register so that they can no longer practise.
About statutory regulation
• Statutory regulation of psychotherapists and counsellors
In February 2007, the government published a White Paper on the future of regulation, ‘Trust, Assurance and Safety – The Regulation of Health Professionals in the 21st Century’.
The White Paper said: ‘The government is planning to introduce statutory regulation
for…psychotherapists and counsellors…’ (page 81) ‘…psychotherapists and counsellors will be regulated by the Health Professions Council, following that Council’s rigorous process of assessing their regulatory needs and ensuring that its system is capable of accommodating them. This will be the first priority for future regulation.’ (page 85)
Subject to the necessary legislative approval, the White Paper indicated that psychotherapists and counsellors would be regulated by the HPC in the future.
We are therefore undertaking this project in anticipation of that legislative approval. [emphasis added] However, please note that the outcome will be subject to any final decisions made by the UK and Scottish Parliaments.
HPC call for ideas for regulating psychotherapy and counselling
If you go into the web-link in this blog's title, you will download a document about the proceedings to include counselling and psychotherapy in the HPC register.
I suppose it is because the HPC is already set up on the basis of a legal statute that they must proceed as if it is ipso facto a good idea to regulate this practice. The questions are already set up on the contentious assumption that the HPC is the right way to register professionals. The call for ideas, then, is a highly particular call, and precludes the possibility that anyone should have a different idea. This is extremely worrying, especially given the field of work that is in question here.
Summary of questions
The following is a summary of the questions we have asked in this document:
1. What are your views about how the Register should be structured for
psychotherapists and counsellors?
2. Which titles should be protected and why?
3. What criteria might be used in considering which voluntary registers should transfer and which should not?
4. We invite voluntary membership organisations to provide us with details about:
o The number of members and the extent to which this number is likely to overlap with membership of other organisations.
o Information about arrangements for determining entry to membership.
o Information about arrangements for considering complaints about members.
5. How long should the grandparenting period be open for and why?
6. Are there are any other matters which the group should consider in recommending appropriate grandparenting arrangements?
7. We would welcome any information about:
o The number and names of existing qualifications leading to the practice of psychotherapy and counselling.
o Types of qualifications including the academic level or academic awards of those qualifications.
o The structure of qualifications including theoretical content and practical experience.
o Quality assurance of qualifications including existing internal and external quality assurance mechanisms.
8. What issues should the PLG consider in determining the threshold level of qualification for entry to the Register?
9. What existing standards or other work should the PLG take into account in putting together draft standards of proficiency?
10. Do you have any further comments?
http://www.hpc-uk.org/assets/documents/1000234Fcouncil_20080703_enclosure08.pdf
I suppose it is because the HPC is already set up on the basis of a legal statute that they must proceed as if it is ipso facto a good idea to regulate this practice. The questions are already set up on the contentious assumption that the HPC is the right way to register professionals. The call for ideas, then, is a highly particular call, and precludes the possibility that anyone should have a different idea. This is extremely worrying, especially given the field of work that is in question here.
Summary of questions
The following is a summary of the questions we have asked in this document:
1. What are your views about how the Register should be structured for
psychotherapists and counsellors?
2. Which titles should be protected and why?
3. What criteria might be used in considering which voluntary registers should transfer and which should not?
4. We invite voluntary membership organisations to provide us with details about:
o The number of members and the extent to which this number is likely to overlap with membership of other organisations.
o Information about arrangements for determining entry to membership.
o Information about arrangements for considering complaints about members.
5. How long should the grandparenting period be open for and why?
6. Are there are any other matters which the group should consider in recommending appropriate grandparenting arrangements?
7. We would welcome any information about:
o The number and names of existing qualifications leading to the practice of psychotherapy and counselling.
o Types of qualifications including the academic level or academic awards of those qualifications.
o The structure of qualifications including theoretical content and practical experience.
o Quality assurance of qualifications including existing internal and external quality assurance mechanisms.
8. What issues should the PLG consider in determining the threshold level of qualification for entry to the Register?
9. What existing standards or other work should the PLG take into account in putting together draft standards of proficiency?
10. Do you have any further comments?
http://www.hpc-uk.org/assets/documents/1000234Fcouncil_20080703_enclosure08.pdf
Subscribe to:
Posts (Atom)
Posts
