Initial response to BACP re: SCoPEd project

Dear BACP, 

We are submitting this letter to state our disagreement with and disapproval of the proposed Scope of Practice and Education for the counselling and psychotherapy professions (SCoPEd) framework which has been presented to the membership as a collaborative project between the British Association for Counselling and Psychotherapy (BACP), the British Psychoanalytic Council (BPC) and the UK Council for Psychotherapy (UKCP).

Amongst other issues with this project, the key issues we wish to highlight are as follows: 

1. Arbitrary Hierarchy within the profession

The proposed framework creates a false hierarchy within the profession. It will further reinforce the mistaken view that counsellors are not professionally on par with colleagues that identify as psychotherapists and psychoanalysts. 

Most counsellors train to a very high standard, often incorporating placements which includes direct work with clients; gaining valuable hands-on experience in a supervised environment. They work with clients experiencing some of the most complex psychological difficulties, often propping up failing front line statutory services. They work with some of society’s most vulnerable people, in charitable organisations, often over long periods of time and usually on a voluntary basis – long after their training courses have been completed.

The proposed framework supports a false notion that psychotherapists are ‘better’ than counsellors; creates a very clear hierarchy within the profession. 

We are surprised that BACP would propose and support this framework that considerably disadvantages the majority of its members. A framework that would put most of its membership at the bottom of the hierarchy.

Until now, very few have spoken out about this elephant in the room, which we all know is there. The elephant being the belief that psychotherapists are ‘more than,’ or ‘better than’ counsellors and how counsellors are kept in their place by those above them, e.g. psychotherapists and analysts. Discussions have taken place in small groups about this issue, behind closed doors, mostly because people are scared to speak out. 

For BACP to support this framework is contradictory to the needs of its members,  especially those who choose for various reasons, not to be accredited despite fulfilling criteria to do so. It’s a public admittance from BACP of a lack of value in its members, a lack of value in the counselling profession and an open statement that BACP aims to keep said members at the bottom of a false hierarchy. 

2. Misrepresentation of membership

The 12-person Expert Reference Group (ERG) and Technical Group (TG) members tasked with proposing this Framework consisted of 5 members representing BACP for SCoPEd, only 2 of which are humanistic/integrative therapists. and the majority of which (7) are psychoanalytic.

How can this panel be an accurate representation of your membership? How can a project such as SCoPEd which is being developed without adequate representation of your humanistic membership offer a fair representation of knowledge, skills and attitudes which is what you seem to be trying to measure, when the panel is so deeply rooted in psychoanalytic theory? The criteria as set out in the document seem to make it impossible for a practitioner to rise up the hierarchy if practicing from a purely humanistic modality; demanding attachment theory and theory of transference, for example, that are not utilised in a humanistic framework. We ask the BACP how you plan on rectifying this under representation and are the BACP going to offer free trainings to humanistic counsellors in order to be able to fulfil these criteria? 

As you say that you have a 50,000+ strong membership, there appears to have been a lack of mapping to the modalities of your membership to ensure they are proportionately represented on the project. There is no indication of how many of your members are students, qualified counsellors and those who have chosen to voluntarily acquire ‘Accreditation‘ – an arbitrary non-educational exercise to gain certification of being able to write case studies and keep records. 

3. ‘Accreditation’ and ‘Advanced Counsellor’ removing autonomy for BACP majority

If this framework was to be implemented, the majority of change would be for BACP members only. UKCP and BPC members would remain largely unaffected. The main change is that there will be Qualified Counsellors and Advanced Counsellors within BACP, with Psychotherapists (at the top). 

Regarding the changes for BACP members, they’d fall into either the Qualified Counsellor or Advanced Counsellor categories. 

BACP members may choose to be psychotherapists if they undergo personal therapy and meet other criteria only relevant to UKCP and BPC training. However, most members would predominantly fall into the first two categories. In those two categories the ONLY thing separating Qualified Counsellors and Advanced Counsellors is arbitrary BACP ‘Accreditation’. There is no other criterion on which to base these separate categories. 

Hence, those who choose not to become ‘Accredited’ stay as Qualified and are not classed as Advanced regardless of experience, responsibilities and training. To achieve ‘Accreditation’, BACP members would have to pay the fee to achieve this; as well as increased membership fees.

If 2/3 of the membership are yet to be accredited, then assuring accreditation of those 2/3 would bring in an estimated income of £3.3 million, not to mention the increase in membership fees. Furthermore, BACP is continuing to promote voluntary work by promoting its voluntary accreditation process via supporting this framework. If this framework was implemented then it would mean to be recognised as an ‘Advanced Counsellor’ accreditation would be essential. This surely sits in opposition to the BACP’s own ethical principal of autonomy as it takes away members’ choices as to how they advance post qualification. 

We would like to reiterate to BACP that Accreditation is supposed to be a voluntary process. Once qualified, counsellors are deemed fit and competent to practice. Accreditation is a process BACP members can opt to take. In choosing not doing so, they should not be penalised by being ranked below those who have chosen to pay for a voluntary process. 

The consequences of this are that accreditation promotes voluntary work, post qualification, as many employers already won’t consider applicants without accreditation. In adopting the proposed Framework, it only seeks to enhance this issue even further. 

Counsellors, upon qualification, are either fit to practice or they are not. BACP need to decide which they feel is true. If BACP feels that once qualified, people are fit to work then they should aim to work with employers and tell them so. This Framework shouldn’t be the basis on which employment is decided. 

We challenge the fact that BACP’s ‘Accreditation’ makes an individual a better ‘Advanced’ Counsellor. All it proves is that the individual has more time (and financial resource) to continue working voluntarily to gain further client hours; has the money to pay for ‘Accreditation’; and has a proclivity to write further reflective pieces / case studies, over and above their academic training. 

4. Public confusion

You have proposed a set of criteria that confuse BACP members, never mind the public. Such an exercise undertaken without input from your members only serves to enhance confusion. In alienating us from this process, you take away our voice and do not seek to represent us but rather dictate to us. 

You also state that this project is in the publics’ best interest. However, by demarcating ‘Qualified’, ‘Advanced’ and ‘Psychotherapist’, yet by labelling those Qualified as not ‘advanced’ or not psychotherapists you are confusing the public about their therapist options.

More so, we all know that psychologists and psychotherapists tend to charge more for therapy. This may mean that those desperate for counselling who cannot wait on the long lists for public services may be forced to pay higher fees under the belief that those above counsellors are better suited to meet their needs, when this simply is not true. 

Further confusion will be caused by the implication that ‘Accreditation’ equates to a necessity for employment (which it isn’t) and that ‘Accreditation’ equates to competent and ethical. It will make employers even less likely to employ those who have chosen not to pay for ’Accreditation’.

5. Consultation with members

Your consultation process is being rolled out near completion of the project. In your consultation process, you ask four leading questions about what has already been drawn up with some space for members’ thoughts. 

BACP members should have been consulted on the methodology and emerging framework from the outset; and as it was being framed. What we have is a membership body making decisions on behalf of its members in a way which is not membership led. The resultant Framework reflects the hierarchal system of qualification you have developed for your members. Therefore, we don’t believe that the proposed criteria reflect your membership’s view, but reflect the agenda of those who sit on the panel. 

As this Framework is being proposed to inform training requirements, competencies and practise standards, how are these measured and assessed? Where does a trainee, on placement who has lived experience of working in a multi-disciplinary team with other professionals to maximise therapeutic outcomes (Theme 1.10b) or who regularly undertakes a competent clinical assessment that is consistent with own therapeutic approach (Theme 2.1a) sit within this Framewoek? Do they not demonstrably emulate the ‘Advanced Counsellor’ criteria? Or a placement student or Qualified Counsellor who regularly demonstrates the skills and critical awareness of unconscious process and ethical understanding, to work therapeutically with ruptures and difficulties within the relationship… are they then not working within the criteria to be classed as a ‘Psychotherapist’?

You seek to inform practice standards, yet those at the bottom won’t get a look in. What this does is keep UKCP and BPC members at the top and in a position to secure paid work whilst those who fall into the qualified counsellor bracket will struggle to gain employment or are forced to become accredited. 

You speak about differences in competencies but you are unable to clarify what level of training people can be deemed as a qualified counsellor and you simply state it is ‘varied.’ How can you measure competence when you can’t even say what level equals qualified?

6. Variation in training across all membership associations

The variation in course criteria and training across all the training organisations, even within BACP membership is vast. You would need to have analysed the criteria for each and every single training programme in order to decide which criteria leads to consistency and ethical practice across the profession. With so many modalities and difference in training for each, one size cannot fit all. The nature of the Framework seriously disadvantages some modalities, such as the Humanistic therapists.

There are far too many discrepancies for this proposal to be applied professionally, fairly and consistently. A Framework for the profession should be attainable by all members of all participating organisations. Not just advantage a few, dependent on if they chose to pay to become ‘Accredited’ or the client hours / therapy hours arbitrarily dictated by their training course.

You would also need to be able to measure client issues and how they responded to therapy to show who is best suited to work with such issues and you would need to have some form of tool to measure the therapeutic relationship, which is not scientifically measurable. To say this process is flawed is an understatement. In the spirit of transparency, we’d like to ask what the total percentage of BACP membership fee’s for this project are being used in comparison to what is being contributed by both UKCP and BPC? And also what the total cost of this project is? 

We’d also like BACP to clarify what the academic levels for being a qualified counsellor will be? You say this is varied for qualified counsellors but are clear on your guidelines for advanced counsellors and psychotherapists. Does this mean that some counsellors who are qualified to level 7 or above but who have chosen not to proceed with accreditation will be in the qualified counsellor bracket with counsellors who are below level 4 training for example? We feel there needs to be much more thought around this and much clearer guidelines provided before members can agree to anything. 

Conclusion

As a collaborative body of counsellors ourselves, Counsellors Together UK (CTUK) receives feedback from its membership on how they feel disenfranchised, unsupported; and treated unfairly and unethically by BACP. From our members’ viewpoint, BACP does little to help counsellors progress in their careers; and campaign, support or champion counsellors in securing paid employment, despite the fact you are aware that 49% of your membership state one of their biggest struggles is gaining paid employment.

BACP, rightly so, insists that we work within the Ethical Framework, yet from the point of view of its membership, BACP seem to be able to make decisions without consultation or consequence for their actions – outside the spirit of their own guidelines of the Ethical Framework. 

BACP members now have two choices. They can sit down and let this happen or they can stand up and have their voices heard. We at CTUK have chosen to have our voices heard and insist that BACP starts to work for us, its members, and in our best interests. We request that this insulting project does not continue. We, as BACP members, are furious about this proposal because what you are offering us is the downgrading of the counselling profession. 

Again, we reiterate our disagreement with and disapproval of the proposed Scope of Practice and Education for the counselling and psychotherapy professions (SCoPEd) framework which has been presented to the BACP membership.

We strongly put forward a counterproposal to rethink on the need for such a Framework; and reconsider whether a collaboration with other organisations which seek to introduce hierarchy – which benefits their own members only and not the entirety of the BACP membership – is the best for our profession; and for the clients we all have chosen to serve.

Yours sincerely

Maria Albertsen & Dr Emma Radway-Bright

On behalf of Counsellors Together UK