Dear Professor Rawlins
I am writing in advance of the imminent consultation process on revisions to the NICE guideline for depression. This letter represents the views of the Chair and senior staff at the British Association for Counselling and Psychotherapy (BACP), as well as our colleagues Malcolm Allen (Chief Executive of the British Psychoanalytic Council) and James Antrican (Chair of the United Kingdom Council for Psychotherapy), on behalf of their organisations.

In principle, we wholly support the NICE guideline development process and applaud its rigour. However, we have serious concerns about the current update of the depression guideline that we wish to bring to your attention. 
 
There have been indications, both in print and through verbal interchange^{1, 2} that the current evidence base for counselling, utilising randomised control trial (RCT) evidence from a Health Technology Assessment (HTA) funded trial³ may be excised from the guideline, and that, in consequence, the NICE recommendation for counselling as an intervention for those suffering mild to moderate depression will be dropped. We would expect NICE to follow a robust scientific process, including early agreement of the guideline's inclusion and exclusion criteria, and would be surprised to see a well conducted RCT excluded at a late stage in the process. At present the rationale for the possibility of excluding the trial is not at all clear, hence our serious concern. 
 
We welcome your own statements, both written4 and verbal⁵ about the need to include in NICE guidelines a range of good quality data from non-RCT sources, including practice based data. Our submissions to the Health Select Committee6, 7 underline your argument. We sincerely hope your commitment to expanding the evidence base is made manifest in the update of the depression guideline.
 
The delivery of a range of psychological therapies (including counselling, couples therapy and psychodynamic psychotherapy) as evidenced in existing NICE guidelines is at the heart of the recently framed Statement of Intent. In his speech at the New Savoy Partnership Annual Conference, the Rt Hon Alan Johnson MP, Secretary of State for Health, underlined his ‘commitment to improving access to talking therapies – not just CBT but all NICE-approved psychological therapies’ (27 November 2008). The clinical utility of NICE guidelines is critical to improving the mental health and wellbeing of patients in England and Wales, and it is important that the current revision enables the Secretary of State's commitment to be upheld. Limiting choice and the range of recommended treatments, without a very clear rationale for doing so, is likely to be challenged in many quarters. 
 
We welcome your response to the points raised here, and are, of course, willing to meet to discuss these issues if further clarification is needed.

Laurie Clarke
Chief Executive, BACP

1. Andrews B. NICE guidance. Therapy Today. Lutterworth: BACP. 2008; 19(9):12-16. 
2. Pilling S. New ways of working evidence stream 1. 8 December 2008.
3. King M, Sibbald B, Ward E et al.  HTA. 2000; 4(19)
4. Harveian lecture 2008.
5. Psychological Therapies in the NHS:  Science, Policy and Practice conference. 1 December 2007.
6. BACP (2007) (NICE): Written evidence to the House of Commons Health Committee, Ev-69-72.
7. Barkham M (2007) (NICE): Written evidence to the House of Commons Health Committee, Ev-244-248.