We have seen above how the HPC model is not suited to the handling of the majority of complaints in counselling and psychotherapy, and how its framework will have detrimental effects on both the profession and on the public. A more robust alternative that would reinforce public protection and preserve the ethical codes of practitioners is the Practitioner Full Disclosure model, a version of which has already proved robust in Australia, Washington State and some other parts of the US.

PFD involves the establishment of an independent body to administer a web-based national database of practitioners, giving full details of their training, their affiliations, their school of therapy, as well as the codes and complaints procedures which they abide by and details of previous professional memberships. Rather than multiple databases – the current situation – PFD allows the public a simple and direct way of finding out about therapists. It would be a statutory requirement that any practitioner of a talking therapy would have to provide full details to the PFD register. Knowingly supplying false information would be a criminal offence.

This avoids the loopholes of HPC regulation, which, since it regulates titles not functions, could allow a practitioner who had been struck off their professional register to simply set up the next day under another title not regulated by HPC. PFD, on the contrary, would prevent this through its requirement that any practitioner of any form of therapy register, and include details of previous memberships and, if it were the case, exclusions. The HPC register, in contrast, as they admit, “does not provide a means by which members of the public can find further information about an individual’s background, area of practice or (normally) any additional qualifications or experience”.

FPC thus avoids the ‘brass plate’ argument often cited in the regulation debate. Anyone, the argument goes, can set themselves up as a therapist simply by putting up a plate advertising their services. The PFD list deals with this neatly since it would immediately be clear to a member of the public whether the person they were considering seeing was on the list or not. A public information programme would at the same time inform the public of the variety of different therapeutic approaches, helping them to make an informed choice as to who to consult and alerting them to the potential risks and pitfalls of therapy. This model exists already in Canada and Australia, and allows members of the public to make their choice on the basis of full and accurate information.

Regarding the issue of complaints, in cases of sexual assault or financial fraud, the criminal justice system would be brought in, as it is currently in the UK and in other countries. For other complaints – which are in fact the vast majority in this field - if a complaint was not dealt with in a satisfactory way by the organisation handling it, the parties could appeal to have the case heard by the PFD panel, made up of lay persons with an experience of therapy as well as practitioners from the particular area of therapy which was in question. These would be handled in a non-adversarial way, with mediation a first step in the procedure, as it is in many other countries.

For each complaint, the PFD Ethics Committee would appoint a case officer, who would communicate with the complainant and establish the context of the complaint and its details. The complainant would be offered the possibilities of informal processes of mediation as a first stage. If this was not deemed satisfactory, formal complaint could be made, with the case officer and the Ethics Committee appointing a complaints panel to hear the case. This panel would be made up of lay people with a knowledge of therapy andpractitioners with a knowledge of the particular orientation of work involved.

Judgements from these hearings could result in exclusion from the PFD list. However, in keeping with the ethics of counselling and psychotherapy, the possibility of human change would not be ruled out a priori, and so strategies and models of reflection and change would be considered by the parties involved. The complaints process could be represented as follows:

 

The PFD model thus ensures protection of the public in a way that avoids gross interference with the ethics of the different schools of therapy. It does not attempt to shoehorn all therapies into one single model of ‘Health Profession’ but respects the diversity and difference between therapies, making the public aware of these and allowing a swift and efficient way of checking to see what the therapist’s qualifications are.

The PFD administrative body would have an advantage over existing structures due to its independence from professional self-interest, through being one step removed, while at the same time drawing on areas of expertise from the field, being publicly accountable and, without the need for the vast administrative and legal structure of HPC. PFD allows for the creation of a robust and responsible body while at the same time preserving the unique identity and traditions of different therapeutic approaches. PFD would provide an overarching framework for the field with clear standards as well as a structure which is flexible enough to include schools of therapy with very different philosophies and views of the self.