On 14th December 2020 we received a response from BACP to CTUK members questions regarding the SCoPEd Framework. You can read in full below. We are currently working with our members to fact-check the answers provided and will respond to BACP in Spring 2021.
In the meantime, if you have any questions or comments then please leave a comment below or get in touch via firstname.lastname@example.org.
QUESTIONS AND ANSWERS ABOUT SCoPEd
Question 1. The basic premise for the SCoPEd framework was to present an answer to some “issues” within the profession.
1a) Can you please present the research you conducted which highlighted which issues the profession needed to address? If no such research exists, please present how you came to these conclusions.
Answer. We actively promote our members using the current membership categories. However, beyond our own membership, the difficulty is that there’s no common framework for training and standards across professional bodies. Terms such as ‘accredited’ and ‘registered’ mean different things in different organisations. Having a shared framework will actively help us when campaigning for roles and opportunities. Experience shows us the current differences in training and standards is confusing and does cause difficulty when talking about our field to those outside our own memberships. We also know that title alone does not indicate whether somebody is more highly trained or more experienced. The advantage of a shared framework is that it provides a shared benchmark against which these differences can be mapped and explained.
This has been a long-standing difficulty in the field which has been generally acknowledged for many years. In practical terms, the three founding organisational members of the SCoPEd project put historical differences to one side to work together on a shared framework based on the evidence of existing training and practice standards. Our experience is that it is difficult to advocate for more paid roles for counsellors and psychotherapists when we cannot differentiate between our members. We know this means our members being side-lined or passed over even when the counselling and psychotherapy workforce would meet the growing mental health crisis we face. At worst we are seen as offering little more than well-meaning support and at best we are seen as having something really valuable to offer, but our profession is very difficult to engage with because of the myriad of training routes, qualifications, titles, modalities and professional rivalries.
In this respect a formal research project was not needed to identify the issues. Rather our focus has been on finding solutions to the problems we had already encountered.
1b) Can you please demonstrate how you came to the conclusion that this project was the best response to the research or the issues?
Answer. The decision for three leading professional bodies to begin working together to address these issues seemed an important and historic initiative. The first step agreed was to map the existing training and practice standards and see where commonality and differences lay based on the published evidence rather than historic use of titles. This felt manageable and was a step to exploring whether a shared standards framework was possible.
Question 2. How to you intend to address the hierarchy that the proposed framework creates within the profession?
There has been a lot of debate around the issue of hierarchy. Firstly, SCoPEd does not ‘create’ a hierarchy but the mapping does show differentiation. This is not surprising as some trainings are longer, at a higher level and require more client hours, supervision, levels of reflective practice and associated skills, like research. It would be inaccurate to say we are all trained to the same level and standard at any given point. We see the framework as a way of describing different groups of therapists who are all highly qualified, ethical, and well trained, but not necessarily all the same. The mapping makes it clear that it is the combination of competences, practice requirements, length and level of training and experience that together indicate differentiation between therapists. It’s not any one factor alone and differentiation isn’t clearly associated with titles currently used by the participating bodies. We’ve responded to concerns about hierarchy throughout the project, for example in discussion of this issue in the member live Q&A (link here) as well as on our website FAQs (link here). We also recently took part in #TherapistsConnects debate which featured various viewpoints and philosophical debates on SCoPEd that you may find useful, this can be found via the link here
Question 3. In creating this hierarchy, you are clearly stating that counselling, advanced counselling and psychotherapy are three different things. Can you provide a clear definition of each one please?
Answer. The framework outlines the competences and associated practice standards within core training. These differences are not currently associated with the way titles are used which is why the project has removed titles in the most recent iteration. The evidence we have mapped demonstrates this differentiation which we are currently referring to as Column A, B and C as set out in the draft framework.
An example of where we’ve talked specifically about the rationale for moving away from the titles used within your question can be found on our website in the introduction to the changes in the latest draft iteration which is on the FAQs page, link here.
Question 4. If the framework is about addressing training standards in the profession:
4a) Why do BACP simultaneously ‘Gold Stamp’ training from CPCAB that fails to meet the basic requirements of BACP’s individual accreditation as a stand-alone course? It is also one of the only courses that does not qualify a counsellor for private work at the point of qualification.
Answer. The CPCAB qualifications meet the standards for membership of BACP and successful candidates then take the Certificate of Proficiency to enter the BACP register. Like all registrants, they are eligible to apply for individual accreditation when they have completed the practice and experience requirements and at that point they are assessed to the same standards as those who completed an accredited training course.
The issue of private practice versus working within an agency is a separate issue which is ultimately a decision for each practitioner and their supervisor, whatever training they have undertaken. We know that not every trainee is ready to go straight into private practice when they finish training.
We believe the SCoPEd project will enable us to better advocate for employment opportunities for all our highly skilled members – so that they don’t end up in unpaid work and so they aren’t pushed into early private practice precisely because the paid opportunities are not currently available to them. We’ve talked about this more on the live member Q&A video, link here
4b) Why is there no minimum training standard for Therapist A even though all membership bodies currently have a bare minimum for qualification?
Answer. The SCoPEd framework clearly shows the minimum standards for those in Column A as a result of mapping the content of entry level trainings. The framework captures the wide range of knowledge, skills and client experience that Column A therapists have. This gives us powerful evidence to campaign for paid roles for Column A therapists and distinguishes our members from those who do not meet minimum standards. It also makes clear to those outside our profession that counselling is more than non-directive support or tea and sympathy as it’s sometimes perceived.
4c) How do you plan to address the issue of training placements when your framework makes trainees unsafe to work?
Answer. The framework does not state that trainees are unsafe to work. We’ve never said this, and it isn’t something which we advocate. Training placements are issues to be addressed with training programmes and by training providers. The framework does not change things.
4d) In addition to the above, you say that this framework is being used to inform training requirements, competencies and practice standards. Can you tell us exactly how these measurable and how you have measured them it fit the Framework?
Answer. The framework captures existing requirements, it does not create them. You can find information on the competences and practice standards which we mapped to create the framework in the framework and methodology documents for both the 2019 and 2020 iterations here
Information relating to how this might inform future training requirements can be found on the BACP website; within the accredited courses Q&As which we’ll be publishing soon.
Courses which do not meet the minimum requirements of the framework may see this an opportunity to ‘increase’ their standards which would be a good thing overall for the wider profession.
Question 5. Can you tell us exactly how you are assessing competency?
Answer. The framework identifies what needs to be assessed but not how it needs to be assessed. It will be for professional bodies, awarding bodies and training providers to work together to agree valid methods of assessment. This has always been the case and this does not change.
Question 6. The recruitment to the ERG resulted in no change in the weighting of how the different modalities were represented. Can you please justify that decision?
Answer. The SCoPEd project is pan-theoretical as it seeks to capture the generic competences required irrespective of theoretical orientation. ERG members were recruited for their ability to scrutinise the methodology and the emerging framework not on the basis of their modality. However, we listened to the feedback that there was insufficient representation of expertise from person-centred/humanistic viewpoints within the ERG and we recruited additional members who were able to bring considerable knowledge and expertise from these modalities to ensure that the framework was more inclusive of all modalities.
Question 7. You have stated that you intend to implement the framework before you have presented the framework progression pathways to members.
Comment. No decisions have been made about implementation, although it is important that issues around potential implementation are explored as part of the project. We have listened to feedback and made changes based on the evidence presented. We welcome the continued feedback from members in helping shape our thinking.
7a) At what point do you intend to make members aware of how they can actually progress up the framework without completely retraining?
Answer. We would like to state clearly here that members will be able to progress without completely retraining. This is one of the important principles embedded in the framework. Agreeing mechanisms for recognising prior training and post qualifying experience will be expanded. The details cannot be set out until a final framework is agreed.
7b) Will you be creating a grandparenting route?
Answer. Yes. That is another term for what we have described above and to enable existing members to represent their training and experience.
7c) When will you be addressing the issue of specialisms?
Answer. The framework isn’t intended to focus on specialisms as its remit is core training for working with adults.
Question 8. How do you intend to support members who will not be able to progress up the framework due to financial barriers?
Answer. BACP have discussed this topic during SCoPEd events and within some articles and we’re committed to ensuring the mechanisms developed are accessible and affordable to all members. The framework is intended to support and enable progression not to add barriers.
Question 9. You are aware that many members do not feel they have been given a voice. Your own survey found 26% of respondents felt unheard.
9a) What are you doing to resolve this issue?
Answer. We’re continuing to incorporate feedback into project discussions. We’ve collated feedback over a variety of informal channels and through the formal consultation exercises that have accompanied both the 2019 and 2020 iterations. We’ll also continue to reflect on what feeling heard means for various members and various viewpoints on SCoPEd and will continue to engage with stakeholders as the project progresses.
9b) Will members be given a clear and democratic vote so they can vote yes or no to this project?
Answer. So far, feedback has shown that members broadly support the need for a framework/support what scoped is trying to do although there are varying degrees of reservations about different aspects. A binary vote would not in itself capture the kinds of nuance that reflect the view of members. However, we’re committed to collecting on-going feedback from members and to listening and responding to the feedback in order to refine the SCoPEd framework.
Question 10. You’ve announced the inclusion of National Counselling Society (NCS), the Association of Christian Counsellors (ACC), the Association of Child Psychotherapists (ACP) – because of their work with adults up to 25 year – and the Human Givens Institute (HGI) to your ERG. Will this be a token consultation, or will these organisations hold some real power in steering the direction of the project?
Answer. The new partners are now part of the project group and as a result, have joint ownership of the framework and any changes made to it going forward. A new governance structure (SCoPEd Oversight Committee (SOC)) on which all partners sit has been created to ensure equal and fair involvement from all partners. The recently released joint statement on this can be viewed here.
Question 11. There are financial costs to this project.
11a) How much money has been spent on researching, developing and implementing the SCoPEd Framework?
Answer. The costs of the work to date have been absorbed in normal running costs in the same way we fund other project work in professional standards, such as the development of competence frameworks.
11b) What the total percentage of BACP membership fees for this project are being used in comparison to what is being contributed by both UKCP and BPC?
Answer. The original partners agreed to share costs proportionately and the new partners have agreed to split ongoing project costs according to a formula based on membership size.
11c) What is the projected total cost of this project; from formation to completion?
As explained, this is part of ongoing costs for professional standards development projects. Professional standards costs are documented in the annual review and financial statements available on the website.
Question 12. We have been told numerous times that the opinions of Stakeholders are being taken into account in the development of the Framework. We have yet to be told who these stakeholders are. In the interests of transparency, can you tell us who the stakeholders are please?
Answer. Stakeholders in this instance is used as a generic term. Within the SCoPEd project we have, and continue to, talk to members, ex-members, members of other membership bodies, other membership bodies, the PSA, the NHS and other workforce areas, training providers, awarding organisations, policy makers and other allied professionals. Their responses are considered both formally and informally and this work, these conversations, these relationships, are ongoing. If you think there are stakeholder groups we should be talking to and have not, please let us know.
Question 13. Are these stakeholders aware that this framework threatens to remove their workforce by labelling them incompetent to work?
Answer. We do not agree that the framework threatens to remove any part of the current workforce or suggests they are incompetent to work. On the contrary, the framework as a whole distinguishes all our members from those who have not completed trainings that meet minimum standards and advocates for paid roles for all.
Question 14. Given the potential for widespread discrimination across all the protected characteristics listed in the Equality Act 2010 will the SCoPEd team appoint an independent and dedicated diversity expert to make sure these issues are addressed and the associated barriers are removed?
Answer. t’s the responsibility of the entire SCoPEd project group, including all partners (new and old) to bring concerns and solutions to the project, and we have talked about barriers and diversity in recent months. As stated in Q7 You have stated that you intend to implement the framework before you have presented the framework progression pathways to members and Q8 How do you intend to support members who will not be able to progress up the framework due to financial barriers?, should SCoPEd be adopted, future work around mechanisms would incorporate and consider barriers and discrimination. It will also take account of work already underway to address diversity and inclusion in training and access to the profession.
Question 15. Initially the framework was being sold to members as a description of competencies at the point of entry into the profession. Now, FBD has made a statement to say that those who work in private practice should be able to map themselves onto the framework. This suggests a much wider impact than the project initially wanted us to consider.
15a) How do you see the framework impacting counsellors in private practice?
Answer. The framework doesn’t look specifically at any setting rather it is intended to be inclusive of all settings. As has been identified, some practitioners move into private practice upon qualification, but others do not. This in itself does not determine whether any individual practitioner is competent to work with the clients they choose to work with. This is an individual decision which includes more factors than core training, but the framework will be helpful for practitioners to benchmark themselves and to undertake further training if they wish to. It is not about limiting what members can do but about describing what they can do.
15b) What steps are you taking, as a project, to create a projection of this impact?
Answer. All decisions about implementation will need to take account of impact. This will be addressed as part of the SCoPEd Oversight Committee’s work.
15c) Do you plan to address that impact to avoid further detriment to counsellors?
Answer. We do not agree that the framework is detrimental to counsellors. Those using the title counsellor are represented in all three columns of the framework because of the range of different trainings offered in counselling.
Question 16. Is this a stepping stone to BACP trying to protect the titles or regulation?
Answer. No. If regulation was introduced, having a framework such as SCoPEd would put us in a much better position to influence those conversations, should they come around. This project is not about regulation. We’ve discussed this at the recent live member Q&A session and an answer also sits within the FAQS on the BACP website.
Question 17. The framework places a psychiatric placement at the top of the hierarchy.
17a) Why have BACP members been blocked from ‘Therapist C’ unless they start their training all over again with UKCP or BPC because of this?
Answer. The current framework specifically recognises prior training and experience, which means BACP members will not have to start their training all over again and will be able to access columns B and C. This is one of the key benefits of having a shared framework. It evidences that some BACP members already fit into all three columns and those that don’t can progress by topping up their training and experience without having to start again. BACP are committed to making these pathways clearer and more accessible as we have addressed in Q7 You have stated that you intend to implement the framework before you have presented the framework progression pathways to members and Q8 How do you intend to support members who will not be able to progress up the framework due to financial barriers?
17b) Why have BACP not negotiated with the ERG for recognition of their membership’s post-qualifying training and for access to Psychiatric placements independent of Membership Bodies?
Answer. The project itself (and the ERG role) isn’t about negotiation, it’s about evidence and mapping of competences and practice standards. Access to specific types of placement is a training issue and not one appropriate for a membership body. However, we will be actively working with employers including the NHS to increase opportunities for mental health placements if practitioners want to move in this direction.
17c) Why is the medical model enshrined at the top of the hierarchy when leading edge thinking (cf open dialogue; power, threat, meaning framework etc.) is moving away from it?
Answer. The project illustrates that the landscape of training is vast; column C trainings are those with the longer duration, more contact and client hours and those which evidence the assessment of the greatest range and depth of competences. The mapping shows that this level of training includes a mental health placement/familiarisation. This does not mean that individual therapists themselves work within or subscribe to the medical model of human distress. However, it does indicate that therapists need to be able to interact with a wide range of other professionals who do work within a medical model, as currently understood by UK health and care systems. As you suggest these models are being challenged by more progressive ways of thinking which is to be welcomed. This has been discussed on various occasions including the member Q&A and is within the website FAQs.
Question 18. So far, there is clearly one column for each membership body, where would other membership bodies fit in?
Answer. We do not agree that the framework suggests that there is one column for each membership body. BACP members sit in all three columns, and this is also evident to the new partners whose initial mapping of their own memberships have been discussed at the Technical Group.
Question 19. What is the reason that BACP has changed their opinion on the difference between counselling and psychotherapy since 2010 when you clearly stated there was no difference?
Answer. There is a continuum of practice in counselling and psychotherapy. The way titles are used by different bodies and individuals doesn’t capture this difference but mapping the training and practice standards, as the SCoPEd framework has done, does show differentiation. The lack of an agreed shared language to describe these differences between different groups of therapists is one of the problems the SCoPEd project is trying to address. Saying that all therapists are the same irrespective of their training and experience is unhelpful and makes it difficult to advocate for our members.
We are trying to find ways to talk about differentiation based on evidence of training and experience rather than whether people call themselves a counsellor or a psychotherapist. As we have said people currently using the titles counsellor and psychotherapist can fit into all three columns of the framework. The terms counselling and psychotherapy in themselves do not capture the difference.
Question 20. Currently, supervisors are not mapped onto this framework.
20a) How do the SCoPEd team intend to map supervisors onto this framework?
20b) Will supervisors be able to supervise those in a column above their own (Supervisor in ‘A’ but supervisee has moved into ‘B’)?
20c) Do you intend to have all supervisors now meet the requirements of a particular column?
20d) What impact do you foresee this to have on your members and stakeholders?
Answer. The framework’s remit is core training for working with adults. The project does not include mapping the standards and competences of supervisors.
Questions addressing how the SCoPEd project is impacting counsellors now.
Question 1. Do the BACP value diploma trained Counsellors within their membership body and can they explain how they value them?
Answer. Yes, most definitely. We believe that setting out the skills and knowledge of counsellors in column A (taken from diploma learning outcomes and assessment criteria) clearly identifies the skills of diploma trained counsellors. It gives us a much stronger platform to argue for paid roles for our members and distinguishes them from therapists whose training does not meet minimum standards. It also makes it very clear that these practitioners are offering a lot more than non-directive support or ‘tea and sympathy’ which is often how counsellors are dismissed by other professionals.
Question 2. What words do you offer those members who sit in Column A feel that BACP is now telling them they are no longer good enough?
Answer. We are not telling them they are not good enough. We are advocating their value and worth and showing the importance of these therapists as part of an underutilised workforce.
Question 3. How can we trust BACP is acting in our best interests when they have stated multiple times they will implement this project without knowing the impact it will have on all of us?
Answer. BACP is acting in the best interests of all its members as well as working collaboratively to be able to represent all our members as a valuable workforce. All decisions need to take account of the impact on members.
Question 4. “I can’t afford to work for free for years before I meet this next hoop ‘into’ the profession.” What is BACP doing to stop people like this from leaving a profession which is becoming untenable to maintain?
Answer. The framework makes it clear that every one of our members is qualified and should be part of a paid workforce. No one is expected to work for free and we know that services will want to employ therapists in all three columns.
Question 5. What response to you offer to the following statement? “We know that many charities are being propped up by unpaid therapists, who are then replaced in favour of trainees”.
Answers. Some individuals choose to work for free but BACP’s position is that all qualified therapists in all three columns should be paid. For the first time the framework clearly articulates the existing competences and standards of those in column A. As stated earlier, this increases our ability to advocate for paid work for these members.
We have discussed these concerns and signposted members to various responses that cover these in the FAQs, on the live member Q&A session and more recently on the #TherapistConnect debate. SCoPEd won’t solve all issues, but it is intended to be enabling, not restrictive, and will allow for progression without retraining which puts us in a better position to advocate for more paid opportunities for members.
How do you plan to address the fact that this project does not meet its aims as demonstrated below?
Aim 1: The framework will improve a client’s or patient’s ability to find a therapist best suited to their needs.
Members comment. There are no focus groups asking what clients want to be demystified and none following up to see if the framework achieves its goal in this area. It seems the independent market research company didn’t feel that conducting actual market research was necessary for this project. Or, maybe, they didn’t have any remit to “conduct” the research beyond being the survey host? Regardless, there is no way to measure the success of this framework in this aim.
Answer. The framework is not a public facing document and should SCoPEd be adopted, a public facing document will be designed that is appropriate for the public. SCoPEd should help with the general public’s understanding of, and access to, appropriately trained therapists. The independent market research agency’s remit was BACP, BPC and UKCP’s members response to the latest iteration of the framework. The client voice will be represented within the new governance model (SOC) from 2021 to ensure the client perspective is part of any finalised framework.
Aim 2: The framework will enable employers to establish which counsellors and psychotherapists to employ in their services
Members comment. Specifically, what were employers misunderstanding and where is your evidence for this? It is only BACP claiming to not be able to quantify the role of the counsellor. Individual counsellors are explaining their role to clients and their non-counselling colleagues every day; in those multidisciplinary teams the frameworks say the majority of counsellors have no competence to work in.
This hierarchal framework does nothing to address this. Particularly when the leading assumption can be that counsellors are not fit for employment; despite BACP taking their membership money and telling counsellors they are so.
Answer. The evidence lies in the lack of (and lack of access to) paid employment opportunities for qualified members. SCoPEd hopes to be a framework of shared competences and practice standards that illustrates why employers should have an appropriate workforce which includes members across all three columns. There were several employability issues covered within the live member Q&A session.
Aim 3: The framework will provide clarity for trainees wanting to understanding training pathways for core training.
Members comment. This is perhaps the only aim the framework gets close to achieving and even then, it is flawed. There is a clearer path available to those who engage with higher education than those looking at further education colleges and training centres. It is not the graduates of higher education institutes that are having to justify their qualifications to employers against a backdrop of, “anyone can be a counsellor, you can get a diploma online for £30.”
At the point when the majority of trainees are looking towards a course that allows them to qualify, the damage has sometimes already been done. We keep fearmongering with the idea of a person just signing up to a short-course on a whim and then behaving completely unethically. The rates of this occurring are unknown. The real risk is trainees being exploited as they meander through an unclear and largely inaccessible field – accessibility being measured in the context of localised courses, reasonable fees and available placements. This contributes to people starting their training journey online. Sometimes the financial loss is small. A £30 course through an online coupon website is little outlay for most. However, for some, the realisation that their course is not fit for purpose succeeded after building a substantial debt reaching into quadruple figures.
Answer. We completely agree that the training pathways are unclear and potentially disadvantage new learners. This is one of the major benefits of having a clear framework which recognises different entry points but which also enables individuals to make choices. Being able to answer the question ‘How do I train to become a counsellor or psychotherapist?’ using a common framework would be a real step forward while still honouring the different routes and different individual needs.
Aim 4: The framework will improve the ability of the professional bodies to promote the skills and services of their members
Members comment. What is specifically so difficult about this that counselling cannot be described in a way that shows competence to “stakeholders” without this arbitrary segregation of competencies based on the biases held within the SCoPEd development groups? Which professionals are we being compared to in order to require a competence that can be overlaid over theirs?
If there hasn’t been an ability to promote the profession and counselling developed and fine-tuned over the course of 40 years of operation (in BACP’s case), it seems unlikely that there has been a stumbling upon the magic solution. When we drill this down, what this is, is a failure to quantify counselling to service commissioners who cannot see beyond the medical model and have no interest of providing alternatives. This framework therefore fails on the aim of promoting the profession. It’s not a promotion of the profession, it is an act of seeing how the profession can be bent around an inflexible view of providing mental health “treatments”.
Answer. A shared framework is an approach to evidencing an appropriately trained and qualified workforce, which removes the confusion that is currently embedded within the profession. From an employer’s perspective, numerous membership bodies operating in silo, with their own interchangeable terminology does not invoke confidence in understanding which type of therapist can meet their requirements. It has the opposite effect in that commissioners and employers struggle how to identify the therapists they need for different services. We also find it difficult to argue for opportunities when we are unable to differentiate between the skills of 65,000 members when their titles and terminology are used differently based on custom and tradition rather than evidence of their training and experience.
Valuing all members and what they have to offer is not the same as saying all our members are the same.
*CTUK would like to thank BACP and the SCoPEd group for taking the time to answer members questions.