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Statutory Regulation of Counsellors and Psychotherapists
COSCA’S Update July 2008
Psychotherapists and Counsellors Professional Liaison Group
At its meeting on 13 December 2007, the Health Professions Council (HPC) agreed to establish a Professional Liaison Group (PLG) to consider issues relevant to the statutory regulation of psychotherapists and counsellors. The PLG’s remit is to review and recommend to the Secretary of State: the structure of the statutory Register, professional titles, standards of education and training, post-registration standards and grand-parenting arrangements.
The indicative timetable for the PLG’s work is that it will commence in late November/early December 2008 and finish in early July 2009. Between July to September 2008 HPC will hold a ‘call for ideas’ to gather information and the views of various stakeholders. A formal consultation paper calling for ideas will be produced in addition to the meetings HPC will have with key stakeholders.
In this regard, HPC met with COSCA on 9th July ’08. COSCA has agreed to circulate the above consultation paper and to place it on its website when it becomes available. COSCA will also submit a formal response to this paper.
Protection of Titles
As part of its ‘call for ideas’ HPC will consult on the titles that should be protected under statutory regulation. Currently, the two working titles to be protected appear to be that of counsellor and psychotherapist. Apparently, any title used will have to make sense to the public. It will also have to describe the activity that is being regulated. It is possible that there may be difficulty with protecting the title of counsellor due to its use outside of the field of psychological therapies e.g. debt or financial counsellor. However, this difficulty has not been confirmed by HPC or the Government, except to state that titles will be protected on the basis of public protection and not the advancement of the practitioners who use them.
So, ahead of HPC’s formal consultation paper it is worth considering whether there is a difference between counselling and psychotherapy, and what evidence there is for such a difference. If you think that a difference does exist, do you also think that there should be separate protected titles to differentiate between counsellors and psychotherapists? Alternatively, do you think that the Register should reflect no distinction in title? Answers to these kinds of questions will be crucial in determining how the Register will be structured.
Modalities/Orientations
It is very likely that psychologists will be regulated ahead of counsellors and psychotherapists (planned for June 2009). It is, therefore, possible that systems agreed in respect of the modalities/orientations of psychologists could apply to counsellors and psychotherapists. However, it appears that HPC will not propose that orientations or modalities will be protected. This will not prevent practitioners from using a modality adjectively e.g. ‘I am a Gestalt Counsellor’.
Entry to the Register
Under HPC, there are two main routes for people’s names to be entered onto the Register: voluntary register transfer and grand-parenting (for use by people who are not on a voluntary register). The other two routes: UK approved course route (for lapsed members of the voluntary register and students in training when the register is opened) and international route (for those trained outside the UK).
Regarding the voluntary transfer route, HPC have confirmed that on the day that statutory regulation is introduced there would normally be a one-off transfer of one or more voluntary registers. These are normally held by voluntary membership organisations. COSCA will endeavour to be included in the list of voluntary membership organisations. If successful in this endeavour, and depending on the minimum threshold set for entry onto the Register, names of individual COSCA members on our voluntary register will be handed over to the regulator for entry to the Register.
What is not known at this time is what categories of individual membership (associate, practitioner, accredited) will be acceptable to HPC. Information on this will materialise as the Professional Liaison Group completes its work.
What seems to be clear is that HPC does not allow students to have their names entered on the Register. What is also definitely the case is that HPC intends to make entry onto the Register based on a ‘fit to practice’ level, which is very different from current accreditation levels. Additionally, it is also HPC’s intention not to exclude anyone who currently works as a counsellor or psychotherapist and to find inclusive ways for those who are working as counsellors or psychotherapists to have their names entered on the Register.
The advice to COSCA from HPC is that we should encourage all counsellors, psychotherapists, including volunteer counsellors/psychotherapists, who are not already members to join COSCA as individual members. It was made very clear to us by HPC that if the names of individuals are not on a voluntary register acceptable to HPC, that these individuals will probably need to use another entry route e.g. grand-parenting. Grand-parenting is a much more costly entry route, with the current fee being £400 per applicant.
We would, therefore, like to stress the potential importance of COSCA membership for all individual counsellors and psychotherapists who are not already members. We would also like to point out that membership of COSCA, at this moment, does not mean that the names of COSCA individual members are on a voluntary register acceptable by HPC for automatic transfer to the Register. Please see the COSCA website under membership for application forms. www.cosca.org.uk
July 2008
Brian Magee
Chief Executive
COSCA (Counselling & Psychotherapy in Scotland)