On line responses to call for ideas
Respondents
People responded via an online form or through email. We had 75 responses in total from the online
call for ideas and the email responses. Of these 75 responses, 61 were online form responses of
which all but one was a therapist or student therapist (five). 47 were members of UKCP. There was a
geographic spread; however, there were no responses from Northern Ireland or Wales.
In addition to these 61 online responses we had 14 email contributions to the Shape email address.
Some of these were structured around the questions, some were more free form.
There were email responses from four organisations – British Association for Counselling &
Psychotherapy (BACP), British Association for Behavioural and Cognitive Psychotherapies (BABCP)
Medical Psychotherapy Faculty of the Royal College of Psychiatrists and the Association of Family
Therapy (AFT).
A number of people took part in different LinkedIn discussions. These involved less people but were
in depth (for example one thread on membership at the time of writing had 66 comments, half of
which were from three people). A very top line summary of the Direct Membership (DM) discussions
is included later on in this report.
There were four regional events held: Bristol (22 attendees), Canterbury (8), Leeds (21) and London
(10).
Key messages
A wide range of views were expressed on some of the key issues. Equally some points while
forcefully put, did not appear to be widely shared. There were some clear messages:
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There was a majority of respondents who feel that “regulation” is the most important role for
UKCP. This was also reflected in some of the local meetings. Some of those who cited
membership or charity as the most important linked this to regulatory issues:
o Being a membership body was important to a significant number of respondents for
different reasons including: services; help finding work; sense of community;
professional mark
o There was recognition of both the tension between the three masters (Regulator,
Charity and Membership body), and of a positive inter-relationship between them. The
need to separate particularly the membership and regulatory functions came up in a
number of different ways
o There was some sense of the UKCP having addressed regulation well but now needing to
focus on other aspects of its work.
The need to raise UKCP’s profile was a common theme:
o There were several references to other organisations having a higher profile and
therefore diminishing the value of the UKCP register/regulation
o This has a direct impact on the ability to get work
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o
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There was a feeling that UKCP should be doing more to increase access to
psychotherapy – and that its lack of profile prevents this
The structure of UKCP came up several times – but in different ways:
o A number of people cited factionalism within UKCP as a barrier to engagement and/or
effectiveness
o Inconsistency across colleges and across Organisational Members (OMs)
o The complexity of the structure came up
o The need for greater involvement of psychotherapists came up (although this was also
cited by one person as the cause of factionalism and there were two calls for much
greater service user involvement throughout)
o Desire for greater transparency
The issue of DM did not come up much in the responses to the on line call for ideas beyond one
respondent who clearly felt it was the key issue. Gauging by the LinkedIn discussion, those who
hold a view on it hold it strongly (this is discussed further in the section below on LinkedIn).
The issue of how UKCP communicates with its members was a key theme at the local meetings and
was indicated through the on line responses. There were several aspects where members were not
aware of what UKCP was doing or how it worked. The feedback at some of the regional events was
very positive about the fact that UKCP had taken the time to come out and listen to people.
On-line call for ideas
This section summarises some of the key points from the emails and online form responses to the
call for ideas paper.
Q 3 UKCP is a charity, a regulator and a membership organisation. Which of UKCP’s
functions is most important to you and why?
There were several more respondents who felt regulation was the most important role than felt
membership was. However, the subtlety of the issue was not missed and many felt that there was a
cross over or that different roles were equally important. Furthermore for some of those answering
that the charitable role was import there was a direct reference to the need to ensure high
standards in the public interest.
The reasons for regulation being important included: ensuring quality; protecting/helping clients;
maintaining ethical standards; a higher level of training than other organisations; and providing
credibility.
The reasons for citing membership as important included: helping to find work; promoting
psychotherapy; the need to increase the income of therapists; member benefits.
The charitable role was seen as important to raise access to therapy as well as ensuring standards in
therapy.
There were several people who recognised the inter relationship between these areas, either
positively or as a tension. Those who argued that there was a positive relation also said that there
was a need to separate the membership role of UKCP from its regulatory function. For example:
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These are equally important functions, and they are in a number of ways interdependent. By
supporting members, UKCP is also helping to fulfill its responsibilities to the general public.
By raising the profile of the profession amongst the general public, UKCP is also helping its
members. There are though important differences and indeed tensions between these
functions that can lead to conflicts of interest. For example, as a regulator UKCP has
responsibilities to service users regarding good practice, and as a membership body it has a
responsibility to support its members. For UKCP to be effective in both instances, there need
to be clear distinctions in place between its regulatory and membership support functions, in
order to maintain the confidence and trust of service-users on the one hand, and of members
on the other.
There were a couple of voices who argued either that UKCP should not be a regulator at all – or that
it should either be a membership organisation or a regulator, not both.
Q4 How successful to you feel that UKCP is as a charity working for the public benefit and
how could we improve this?
The UKCP’s low profile was viewed as major problem. Comparisons with other organisations were
made which were seen as more visible. Notable exceptions to this included another professional
organisation that said it felt that UKCP had a high profile in lobbying terms but a low profile with the
public; and a member who felt that they valued the UKCP influence with Government. While UKCP
may be actively lobbying responses suggest this has not been visible to members.
There were one or two people who were expressly not interested in UKCP as a charity, either
assuming this was for tax purposes or simply not wanting their membership body to do anything else
than work for their interests. This linked to conflicting points made about on the one hand there not
being a conflict between therapists’ and clients’ interests; and on the other “supporting counsellors”
not being about the public benefit. There were also several people who did not understand why
UKCP was a charity or felt they knew too little to comment on this.
UKCP’s performance as a charity was criticised by some in relation to its low visibility mentioned
above. There was also one specific criticism of mismanagement, one of a failure to ensure adequate
statutory regulation and one of failing to ensure the protection of therapy within the NHS.
The issue of factionalism within UKCP came up as a barrier to UKCP achieving its charitable aims.
In terms of what people would like to see UKCP do the following were raised as charitable activities:
promoting the profile and benefits of therapy; raising standards; increasing access to therapy
(including providing access to low cost therapy); promoting the right to therapy. Factors felt
important to achieving this included greater diversity; more reporting to members; putting
therapists in charge of the organisation not staff; and improving the website.
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Q5 How successful to you feel that UKCP is as a professional regulator and how could we
improve this?
Several people felt UKCP was doing well as a regulator – with the complaints system mentioned a
few times. A common criticism reflecting the feedback on the previous question was that the UKCP
register needs to have better profile and recognition. This led one person to highlight that they paid
three fees, one to their OM, one to UKCP and one to BACP which was raising the question of
whether that was worth it
A couple of people directly mentioned the potential for conflict of interests:
Be a regulator or be an organisation to support therapists. Doing both is a clear conflict of
interests – protecting our own
The Royal College of Psychiatrists argued that the focus should be on regulation and point the
history of medical regulation:
For the medical profession, the three functions of regulation; professional representation and
professional facilitation are syndicated into three separate organisational structures,
regulation by the GMC; representation by the BMA with its union function; and academic and
professional development with the Royal Colleges.
Unfortunately, with the decline in trust in the professions, there is a public and professional
demand for regulation that is at an arm’s length from the profession that it is regulating, this
being achieved by the inclusion of heavy lay representation. Arguably the UKCP’s primary
role has to be this externally legitimate professional regulation role, leaving the professional
development role for the training organisations.
This was a view shared by some members, while there were also some mentions of not liking
regulation or wanting more self directed regulation:
I am a firm advocate of psychotherapists developing their ability to self authorise, through
their training and their ongoing CPD.
There were two direct calls for statutory regulation, although there were also indirect calls in that
people called for Psychotherapist to be a protected term (which would imply a legal framework).
There were also some who said they would like to see stronger UKCP regulation, with one comment
that while UKCP regulation was good; it would be even better if it were the only regulator.
Suggestions for improving the register/regulation included: getting rid of inconsistencies;
standardising CPD requirements etc; standardising fees; decentralise; place more emphasis on
distinguishing psychotherapy as a level of registration; ensure UKCP is acting within the Equalities
Act and that training organisations understand the importance of this (include the Diversity, Equality
and Social Responsibility Committee (DESRC) as part of the regulatory structure); monitor the
performance of the regulation system.
Q6 How successful to you feel that UKCP is as a membership organisation and how could we
improve this?
There was a group of respondents who felt that UKCP membership was good. For example:
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I feel consulted and included.
At the other end of the spectrum there were a group of people were very dismissive or felt the
membership was very poor. For example:
I pay a huge amount of money and don’t see any benefit yet
Within this spectrum of views there were some common themes of either criticism or suggestions
for improvement (i.e. some people were either saying you would be better if you… some were
saying UKCP is rubbish because…..).
A number of people raised the issue of the structure. It was seen as over complicated, keeping
people at bay. For example:
A further complication is the collegiate structure, which adds to the complexity of the
relationship between the organisation as a whole and its end user.
The structure was also seen as divisive and some saw it as designed to keep power with the training
schools rather than the members. There was a sense of it being a factionalist organization expressed
by some, for example:
This appears problematic with a myriad of organisations within UKCP that at times present
themselves as rivals to each other as well as to UKCP
One person reflected that the downside of volunteer involvement in UKCP was that it fed
factionalism. One respondent suggested that a way forward was to have more psychotherapy users
throughout the structure.
There were a few people who highlighted the desire to see UKCP be more of a trade union type
organisation with greater democracy (with one person mentioning Annual General Meetings (AGMs)
here).
You try to combine being the regulator and running an ethics code with trying to be a trades
union - this is like the GMC pretending to be the BMA. Decide to be either the one or the
other. I’d suggest you drop regulation and ethics entirely and concentrate on being a trades
union and join the TUC.
Linked to this one person talked about wanting more support through a complaint, but also noted
the importance of helping those who had breached ethics to move forward.
There were also a small number who called for UKCP to be less London centric – with more meetings
out of London, a greater presence in Scotland etc.
There were a number of other suggestions for improvement: on line registration; support
psychotherapists to get employment; provide more services; more CPD; better website. There was a
call for improved communications with the Complaints and Conduct Process (CCP) (and possibly the
shape review) held up as good examples.
One person, perhaps inadvertently, highlighted a central tension UKCP faces when thinking about
offering more services:
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UKCP should complement, not duplicate, the membership support activities of the OMs. In
the case of the smaller OMs, as well as for direct members, UKCP can provide a number of
functions that might otherwise be the reserve of the OM.
Q7 Do you feel that we have the balance right between our different areas of activity or how
could we improve it?
Five respondents said UKCP had the balance right, the clear majority felt it had not. This ranged in
view from those who felt everything UKCP did was poor:
You don’t do anything well at all except self aggrandise
Through to those who recognized that UKCP did some things well but would like to see more of
other activities:
I think the work done on regulation of the profession has been very important but now we
need to look more at the needs of our clients
In terms of the criticisms they ranged across different issues. There was a view that more should be
done to support clients while also some wanted more to be done to support therapists. One
individual said that UKCP should be aiming to balance these functions; it should primarily be about
regulation. If this is right members will be proud to be part of UKCP and won’t care about getting an
extra £10 pounds off their insurance.
Some of the specific improvements mentioned echoed previous comments: more promotion and
profile for UKCP registration; lobbying; bring back the AGM; separate investigation from support;
more on things that matter to therapists (rather than internal UKCP things such as shape).
Q 8 Do you have any other comments you would like to make?
Many of the comments in this section repeated previous answers, for example the low profile of
UKCP registration, the call for more regional out of London presence.
Additionally there were some specific suggestions. One person talked about the desire for the
different professional bodies to come together. Another wanted to see parity of esteem with
psychologists and psychotherapists. There were calls for more private practitioners to be involved in
UKCP committees, and a call for more non practitioners at all levels. There was also a feeling that
UKCP was too balanced towards psychoanalysis while another saw the introduction of DM as directly
linked to the decline of psychoanalysis.
A theme mentioned a couple of times that links to the issues previously mentioned is the use of the
term registrants rather than members.
Here again the fact that UKCP is a membership organisation as well as a regulator, brings
some confusion to the situation. If we could refer to registrants rather than members it
would be helpful.
LinkedIn
There has been a lively discussion on LinkedIn. This report will not describe this in detail, some of the
themes described here feature in the discussions. However, it is worth highlighting that the issue of
Direct Membership came up both in a discussion thread of its own: UKCP/CPJA issue of direct
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membership. And then again in the discussion started specifically around Shape: Have your say in the
future of UKCP
Aware of the risks of oversimplifying the debate here, broadly the following points were being put
forward about this argument:
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Against direct membership
o Challenge it presents to the OMs in terms of losing members (and revenue – which
may in turn reduce the range of training available)
o Potential to undermine communities of practice
o Challenge to standards
o Lack of infrastructure to support the DM system
o Rejection of the OM may be a transferential issue that should be addressed within
the container of the OM
In support of the new system
o Allows movement of therapists who may have fallen out with their OM
o Creates a challenge to OMs to encourage them to offer value for money for ongoing
membership
o Recognises that members develop and change and may want to change either to
different modalities/groups of interest; or into local communities of therapists who
organize their own CPD etc; or may simply live some way away from their OM
o Costs of both memberships (and a feeling qualified therapists should not be
subsidizing the training of others through their OM fees)
Of those who were not great fans of DM there seemed to be some sense (not universally) that there
was no going back, and the focus should be on improving the processes around it.
One Council for Psychoanalysis and Jungian Analysis (CJPA) contributor highlighted that CPJA were
addressing the issues of process:
Here at this college (CPJA) we have nearly finished devising a process where DM's are reaccredited by their peers (who offer themselves as auditors) of a written statement of how
the individual DM meets the general College re-accreditation criteria and the College CDP
policy. This statement is discussed between the DM and peer reviewer. This conversation, in
turn, is reviewed by a college committee which includes DM's and OM representation. All this
to defined timescales. And for all details to be available on the college website - to minimise
the scope for fantasy.
This will be done pretty much at cost price, to the DM. We're reckoning £250, which should
include contributions to college admin.
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Glossary
Organisational members (OMs)
UKCP organisational members assess individuals’ suitability, in accordance with UKCP requirements,
and are able sponsor individuals for UKCP registration. Our organisational members are grouped
together in modality colleges representing the main traditions of psychotherapy in the UK. All
members, whether individual or organisational, must be affiliated to one of UKCP’s colleges.
Direct members
Direct Membership allows individual members to leave their UKCP organisation and register directly
with UKCP (they must be members in good standing and have been on our registers for at least one
year). All direct members must be affiliated to one of UKCP’s colleges.
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