Urgent - Regulation Update and 451

The London Society of the New Lacanian School

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Dear Colleagues,

On Tuesday, June 10th there was a meeting of the National Counselling and Psychotherapy Reference Group. This forum has been convening bi-annually for some 3 years now. Although the machine rolls on and the process of government regulation continues, there have been some unexpected developments noted in updates to the group by various institutional representatives.

- The large organisations: BACP, UKCP, and BPS are going along with the process but each is unhappy, albeit for different reasons. The BPC position was not clearly stated and the SfH issue narrated below may indicate something of why this was. There have been significant changes in the position of some organisations, with increasing disquiet about what regulation will mean and mounting criticism by some of those responding to consultations (The College and the Guild). The representative from the Guild reported that a poll of their members recently found that almost half are against regulation, with the remainder being divided between being in favour and not knowing. The Guild called for non-cooperation with the process together with a collective response in opposition to it. The College has produced an extended critique of the SfH draft discussed below and has declared its opposition to regulation after having initially been in favour. The IPN has sustained its position of being against regulation; a position openly declared at the beginning of the process 3 years ago when it was a very difficult one to hold.

- In a report by the BPS representative, we learned that the new Director of Professional Regulation, at the HPC, Gavin Larner, is not sure whether the government wants to regulate on the basis of 'patient safety' only or on 'public protection' as well. He is now seeking clarification of this point from the Department of Health. Regulation has so far encompassed both these concepts; the latter being far wider in scope than the former. So, this may come to be significant. The presentation from the BPS concluded that the situation was now a 'muddle'. This was very good to hear since 'muddle', though a simple enough word, speaks of the complexity presented by the real. So, it was possible to feel somewhat reassured that the detrimentally delusional certainties are losing their consistency; at least within government circles, if not necessarily among those who would seek influence in them. The BPS continues to ask the government to make 'Psychologist' the protected title. The government continues to reply by insisting on a more limited scope for regulation, specifying only adjectival titles, such as: 'Clinical Psychologist', Educational Psychologist.

- The Chief Executive of the BACP indicated that the 'political will appears to be waning'. This too was a welcome surprise; especially so because at a meeting of this group last year, it was concluded that the way to engage with the process of state regulation was to aim to change the 'political will' behind it. This is precisely what colleagues have been working very hard to achieve.

- The position taken by the London Society was that we maintain our objection to this process, which we consider to be ill founded and ill conceived. Further, that we have been working very hard to sustain this objection, so are very pleased to hear that the political will is waning.

- The bad news is the scandalous and absurd action of the Skills for Health working group on 'psychodynamic competences', which has produced a draft version of what are now called Psychodynamic/Psychoanalytic National Occupational Standards. This document crushes psychoanalytic practice under the weight of 451 rules that the practitioner will be required to follow in order to comply with the competences required for working in the field of health. For further reading on the question of a regulatory policy, you might wish to look at the "Guiding Principles for Any Psychoanalytic Act", adopted by the WAP in Rome in 2006. http://www.londonsociety-nls.org.uk

It has since become clear that the 'competences' were published on the SfH website: www.skillsforhealth.org.uk on May 28th with a deadline for this Sunday, which permits only two weeks for the practitioner to wade through the 451 weeds that aspire to choke his voice and, thereby, his practice. If you would like take a sample, the documents are attached. The introductory comments on the SfH website read as follows:

"The draft Psychoanalytic/Psychodynamic National Occupational Standards are available here for comment. These relate to work that has been undertaken to date by the Expert Reference Group. This Group has appraised those manuals of dynamic therapy that have been used in research trials and which have been shown to be effective when applied. It is with this in mind that any comments and suggested amendments should be made. The contents of the NOS need to ensure that they are advocating practice which is based in evidence and efficacy. Please send your comments and any suggested amendments to Darren.Buxton@skillsforhealth.org.uk by with a consultation deadline for this Sunday, June 15th.

"It should be noted that the 'manuals' providing the sources for these rules are qualified by being based on 'evidence and efficacy'. In this, we can note the shadow of a CBT intent on remaking the entire world of psychoanalysis and psychotherapy in its own image. The clone, the ominous figure of 451, has its own historical resonance - Fahrenheit 451 - and stands 450 degrees away from the 1st rule of psychoanalysis: Free Association.

We can act: a simple way to do so would be take Darren Buxton at his word and emailing him by Sunday, even if only to object to the 'thief-in-the-night' approach to 'consultation', with possible notice of further objections to be sent in time. There is also the possibility to write to your MP with your concerns at: www.writetothem.com .

Regards,

Penny Georgiou

Chair