Health and Social Care Bill

MEMORANDUM SUBMITTED BY UNITED KINGDOM COUNCIL FOR PSYCHOTHERAPY (UKCP) (HS 80)

Summary

Details the concerns of the United Kingdom Council for Psychotherapy (UKCP) over the powers granted to statutory regulators to establish their own voluntary registers. UKCP believes this would be unhelpful, anomalous and confusing to the public.  The proposal is for the draft bill to be amended so as to restrict the power of statutory regulators to establish voluntary registers only to those professional and occupational groups that do not have existing voluntary regulators.

1. Brief introduction to UKCP

UKCP is the leading professional body for psychotherapists and psychotherapeutic counsellors in the UK and holds a register containing over 7,500 members. It has developed the most stringent professional entry standards for psychotherapy. Our members have undertaken four year training programmes to masters level or above. We approve 75 such trainings throughout the UK. UKCP is a founding member of the European Association of Psychotherapists and a member of the World Council for Psychotherapy. For further information please visit www.ukcp.org.uk .

2. UKCP evidence

2.1 We welcome the concept of assured voluntary registration. If there are no changes to the sections of the Bill that grant the renamed Council for Healthcare Regulatory Excellence the powers to accredit voluntary registers, UKCP would in all likelihood apply to CHRE for such accreditation.

2.2 However we have major concerns about the powers proposed to be granted to statutory regulators to establish their own voluntary registers (s212). As the Bill is currently drafted, this new power enables a statutory regulator to establish a voluntary register in competition with existing professional voluntary registers.

2.3 We think this constitutes an improper encroachment by an agency of the state into the existing professional voluntary regulatory field. It will be divisive and confusing, and will lead to competition of a kind that we cannot believe the Department of Health envisaged in the drafting of this Bill.

2.4 We urge that the draft Bill be amended to make clear that the statutory regulators would have a power to set up voluntary registers only in those circumstances when there are no recognised voluntary registers in existence.

2.5 This proposal would leave the Health Professions Council free to establish a voluntary register for social care workers, who are not registered voluntarily at present. But the fields of psychotherapy and counselling already work under a system of voluntary regulation that the Department is well aware of. Hence, we submit, they should not fall under a statutory regulator for the purpose of voluntary regulation.

March 2011