The UK network of psychotherapy, counselling and psychoanalytic organisations contains a wide range of trainings with different entry requirements, different systems of assessment and evaluation and radically different philosophies. This variety reflects different theories of human growth and change. With HPC regulation, all training programmes will have to meet HPC standards of education and training to ensure that they successfully deliver the Standards of Proficiency relevant to the modality in question. These Standards have been discussed in the previous section, and a detailed commentary on them may be found in Appendix 3 below.

The Standards suppose a largely medicalised model of healthcare intervention, inappropriate to the talking therapies, reducing them to the application of health
‘management’ procedures’ and problem solving techniques. The person about to embark on a therapy is described more as a patient about to undergo surgery, with a team seeking out data on their case to be collated and discussed by a group of health professionals. The patient’s participation as the main agent in the therapeutic process is completely ignored, to give a set of Standards that trainings will be obliged to deliver that change the very definition of therapy itself.

As well as teaching a radically different version of therapy, trainings will have to ensure that all the latest health and safety instructions are transmitted to trainees and members. The example of how such measures have increasingly affected teaching and social work illustrate what kind of stakes are at play here: aside from the absurdity of many of the regulations, trainings will have to outsource ‘trainers’ to teach trainees what are vaunted as the ‘latest’ developments that they need to know about.

The other key issue here is the question of personal therapy as the central variable of training. For many schools, the main element of any training in therapy or analysis is the person’s own therapy or analysis. This is crucial since it explores the reasons why the person wished to become a therapist. By questioning the person’s aims in wishing to work with human suffering, therapy hopefully allows the person to challenge their own motives. Indeed, deciding to give up one’s aspirations to be a therapist is seen as a positive result by many schools of therapy and analysis. If there is a distinction between conscious and unconscious motivation, the conscious wish to ‘be’ a therapist must be explored and questioned.

This poses serious problems for any training which claims to offer a university-style approach to teaching and learning. For many schools, there can be no linear path through a training, and since one’s own therapy is the central component of training, results can never be predicted in advance and, indeed, no standardised feedback can be given. Questions such as ‘How am I progressing through the training?’ make no sense according to these models. Accordingly, while maintaining rigorous assessment procedures should the trainee wish to apply for membership, they see their role as providing a space for the individual to critically reflect on the discipline, discuss clinical work, engage with new ideas and so forth.

The result of many therapies or analyses is certainly that the individual does take up a position as a therapist or analyst. But this is the effect of profound subjective changes at the psychic level and not of having learned any ‘knowledge’ or acquired any ‘skills’. For many schools of analysis and therapy, taking up the position of clinician is like the scar of one’s own psychic journey, defined and understood in different ways by different groups, but always in terms of the psychic work in their own therapy. Freud defined it as being able to forget anything that one ‘knew’ each time one saw a patient.

This view poses many problems for the HPC model, which relies on a linear, universitystyle model of knowledge acquisition, a model also adopted by Skills for Health in their NOS. On this model, one progresses through a course, learning more and acquiring new skills, receiving feedback that allows the trainee to know exactly where they are in the process. As the HPC Standards of Education documents spells out, trainings have to answer the question, ‘How would you explain the overall programme and how a student progresses from day one to graduation?’.

The view of human knowledge here is very different from that of many schools of therapy and analysis, which believe that the result of one’s own therapy must be a critical attitude to any kind of knowledge that claims to answer basic human questions. The HPC and SfH models effectively fail to recognise that the main component in a training, for many schools, is the personal therapy of the individual.

Once this fact is recognised, the whole idea of knowledge and skills and of student progression is put in question. The very concept of CPD also becomes problematic. Trainees don’t graduate and then go on to improve themselves by learning more and updating their knowledge, since their own therapy or analysis will have taught them the vanity of human knowledge. If making the psychic journey that allows one to become a therapist involves, say, moving through one’s Oedipus complex or one’s depressive position, this can hardly be ‘topped up’ each year through CPD. CPD in fact supposes a notion of the self as a project for realisation of betterment, exactly the view of self rejected by many schools of therapy and analysis, which see it as based on a market-led vision
of human life, where the individual must acquire/buy more attributes to make them an effective competitor in the marketplace.

HPC regulation would risk imposing this view on trainings which have been based for decades on a totally different view of human life, more in line with a Buddhist attitude to human knowledge and self than that of market-based visions. There is also the serious risk that HPC regulation will weaken the organisations in the field due to its policy of individual membership. Once one is HPC-registered, there would be no need to remain a member of one’s own organisation. This would obviously have detrimental effects on trainings and may even lead to the collapse of institutions with a long and distinguished history. The very life of the profession risks being sapped by this centralising process.

There are also concerns about entry requirements. Many therapy organisations conduct extensive interviewing procedures which are based not on a set of formal requirements but the sense of the candidate as a human being. This time-honoured process allows many people who come from underprivileged backgrounds to enter therapy training organisations. Many will not have done an MA, and some will not have been through higher education, yet their qualities nonetheless make them well-suited to the field of therapeutic work. The rigid HPC set of formal requirements will result in the exclusion of these candidates, and effectively make therapy trainings open only to a small subset of the population (a privileged white middle class group). This was recognised by the Health Professions Council of British Columbia, which, after being approached by some stakeholder groups, concluded that its regulatory framework was not suitable for many of the groups under consideration, and would exclude potential trainees from trainings.

The HPC accreditation of trainings poses the further threat of introducing new parameters and coercing training courses to adopt particular models of the psyche or of what HPC consider to be ‘best practice’. Notions of ‘best practice’ are widely used within HPC at present and are also found in their discussions of therapy and counselling, as if there was just one model of best practice. This relies generally on techniques that are inapplicable to the therapies, such as RCTs, and assumes that there is such a thing as “what is known”, a phrase that appears in HPC generic standards.

As well as adopting a model of best practice that is rejected by most therapy and analytic organisations today, HPC ignores the fact that for many schools it is precisely moments of poor practice that may have crucial effects in a therapy. Engaging with the therapist’s mistakes, blunders and insensitivities will play an important part in the therapeutic work and allow it to move through critical periods. For many schools, realising that the therapist is human too and gets things wrong is essential in the process of engaging with the risks of life and undermining phantasies of expertise or omnipotence. There is likewise no such thing as a single and correct way to practise, a fact made obvious by recognising that most work is done not by the therapist but by the patient. Patients find very diverse
ways of using the therapeutic space and each therapy will be tailored to these unique and individual details.

HPC regulation would thus have detrimental effects for trainings which are based on philosophies at odds with the HPC vision of what therapy is about. The meaning of psychotherapy would, for many organisations and traditions, be changed radically. HPC’s medical-style model would restructure existing trainings, which would have to conform to the Standards of Proficiency established by HPC. The imposition of linear, university-style models of training would undermine the personal therapy-based paradigm currently dominant in the field where the focus is on psychical change rather than surface knowledge. It would also have detrimental effects for trainings which do in fact accept the HPC vision, by weakening their own membership bases.