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• In a recent letter dated 28 July 2009 to the membership, Lynne Gabriel, Chair of BACP, has asked us to respond to the Professional Liaison Group’s (PLG) ‘Consultation Draft’ on the ‘Standards of proficiency for psychotherapists and counsellors’. In particular, she has asked members to focus on the proposed differentiation between psychotherapists and counsellors, which is a highly contentious area but one that is hugely significant in terms of future recognition and status. Many therapists from different orientations know that, at the level of practice, there are no meaningful differences between psychotherapy and counselling. Therefore any attempt to separate them will tend to be arbitrary and contrived. Many people will view this as political and economic manoeuvring rather than as meaningful differences in theory or practice. I would support the argument that it is impossible to demarcate the two activities. It is not sustainable to simply reduce the argument to ‘quantifiables’ like length of training or the number of personal therapy and pre-qualifying client contact hours. To most practitioners the criteria selected for differentiation between psychotherapists and counsellors, relating to ‘severe mental disorder’, are nonsensical. Unsurprisingly, in this Health Professions Council (HPC) document the emphasis is on diagnosis and medical model terminology. It feels like someone has closed their eyes and just stuck a pin in a chart. I hope that many members galvanise themselves and complain to the PLG about the absurdity of this aspect of the process.
   
  However, it would be a mistake just to focus on these items alone because to do so would miss another more serious point. Seen in the context of the overall document, it is not that incongruous. For example, the constant use of the description ‘service user’ in the document, where most therapists would say ‘client’. This basic criticism is not simply about careless language – this is meant to be a serious document, directly relevant to the work we do. It should at least be recognisable to the majority of practitioners. On that count alone it fails the test.
   
  But there are other serious weaknesses in the document as a whole. In fact, I would say that most practitioners will not be able to recognise themselves or their work from the bulk of this draft consultation. Much of the document is concerned with generic HPC standards, which take up most of the body of the text but the ‘profession specific’ standards, which address counselling and psychotherapy especially, are notable by their brevity and paucity. The sections that are directly relevant to counsellors and psychotherapists seem to be secondary to the overarching need to ‘fit’ the profession into the regulatory structures of the HPC. The imperative seems to have been just make it fit somehow, but it simply doesn’t. Taken as a whole the document reads like something slightly alien; the majority of it refers to a generic healthcare professional and has been cut and pasted with a few profession-specific bits grafted on as an afterthought. The bulk of its contents are either inappropriate or irrelevant to counselling and psychotherapy. Does this mean we can simply ignore it? No, not at all; to do so would be a strategic misjudgement.
   
  So, what does all this mean? Does it mean that the HPC is simply incapable of grasping the nature of psychotherapy and counselling? If some organisations and individuals were initially suspicious or critical of the HPC being imposed as regulator, their fears may be confirmed by the evidence supplied by this document. It is now possible to see why people were nervous at the beginning about the ability of this body to undertake the task of regulation. The proposals contained within the document will fuel doubt about the legitimacy of the HPC to be an effective regulator.
   
  It seems odd that despite several high-level meetings of the PLG over many months, it has not been possible to come up with a better set of recommendations than this. However, there is an opportunity for members to voice their objections during this consultation period (through to October) and I believe that it is important to engage with the whole document, not just a few items abstracted from the text.
   
  
   
  
  

• Paul McGahey
  MBACP (Snr Accred) 
Counsellor