Newsletter against the BACP, BPC & UKCP SCoPEd project : Alliance for Counselling & Psychotherapy

by Julia Evans on February 8, 2019

Newsletter against the BACP, BPC & UKCP SCoPEd project

12th February 2019

from Alliance for Counselling & Psychotherapy

(Blog :, Contact :



You are asked to forward this to everyone interested in the future of Counselling & Psychotherapy


To oppose the BACP, BPC & UKCP’s SCoPEd project, as it is a move towards standardisation of practices & state regulation


What this is all about :

The three leading regulatory bodies for the counselling and psychotherapy profession have created a new competence framework as a response to the mental health crisis (Letter to the Guardian : 30/11/2018[i]): A survey was announced in January 2019 which is open to comment until 22ndFebruary 2019. In the documentation[ii]the framework, competencies & a ‘before and after’ comparison of training is given. Prior to this announcement there has been no consultation with the membership – the practitioners. When the SCoPEd project was being presented last May at the BACP Research Conference, the panel and chair refused categorically to rule out that this was about statutory regulation.


– this whole project has been imposed without consultation, on the basis that the big 3 must know best.

– it ignores difference in training, practice, supervision and development of practice.

– it, without evidence, sets standards for practice and training and supervision & what constitutes a Senior Practitioner

– the framework once applied means everyone’s practice has to fit within – if you do not then you will be declared ‘unsafe’ or a ‘charlatan’. From BACP web-site:

‘How will the SCoPEd Framework affect my existing membership, registration or accreditation?

…over time existing members may be asked to benchmark themselves against the framework (including any post registration skills and experience) as part of ongoing registration requirements and as evidence of working within their competence.’

– it invents the need for the public to be told which practitioner they should trust.  Only the big 3 can guarantee a practice by applying their framework.

– From the Q&A quotes on BACP website: “The outcome of the SCoPEd project, and the collaborative nature of SCoPEd, puts us in a strong position to respond to the challenge of statutory regulation if it does happen.” So, without consulting anyone, they are moving from regulation by PSA to regulation by HCPC.

– BACP accreditation is the only access route to ‘advanced qualified counsellor’ and its more autonomous competencies. This locks out anyone who is not a member and generates a large steady income stream for BACP.

– there is no evidence that this accreditation process which uses competencies works.  Why change what has worked for decades?

– the distinction between the various levels is driven from the top-down instead of being based in practice (bottom-up).

See Footnote ii for links to information on the SCoPEd project



Read the following and tweet, twitter your comments to as many people as possible


TEXTS  So far:

– The Alliance for Psychotherapy & Counselling : Newsletter against the BACP, BPC & UKCP SCoPEd project : 12th February 2019 : as posted to BAPCA now The Person Centred Association (TPCA) blog at

– Keith BarberA damaging business paradigm : Latest SCoPEd response 20th February  2019

– SCoPEd: new consultation responses

Two therapists – Arthur Musgrave, a BACP Senior Accredited counsellor and supervisor & member of the Independent Practitioner’s Network & Joe Suart a UKCP Registered psychoanalytic psychotherapist working and living in Cornwall  – share their SCoPEd consultation responses with the Alliance. 15th February 2019

– David Murphy ‘The Questionable Evidence Base of SCoPEd’ 31st January 2019 David Murphy, Associate Professor at the University of Nottingham, interrogates the claim that the SCoPEd framework is ‘evidence-based’.

– Andy Rogers ‘SCoPEd Denial, Distortion & Deception’ 30th January 2019

– Andrew Samuels ‘’Psychoanalytic Coup’ – Andrew Samuels on the SCoPEd competence framework’ 30th January 2019 

– Denis Postle ‘Regulation, Professionalism & Cultures of Dominance’ 25th January 2018

National Counselling Society (NCS), open letter to BACP highlighting all the contradictions between BACP’s 2009 HPC response and the SCoPEd project: February 2019  //

Counsellors Together ‘Initial response to BACP re: SCoPEd project : 4th February 2019. //

PCSR have released an excellent 10-point statement of opposition :

Maria Albertsen has an inspired twitter thread (52 tweets long!) of all the things SCoPEd says ‘counsellors’ can’t do… :


From, twitter profile, of Susanna Abse  @SusannaAbse Psychotherapist/Org consultant/Chair, British Psychoanalytic Council/Past CEO of Tavistock Rels. Tweeting on #relationships/#mentalhealth/#psychoanalysis

TWEET 1, 6th February 2019,

“It’s v. good that many #counsellors and #psychotherapists engaged with #SCoPEd. But wonder if we C &P’s find it difficult to trust our colleagues? #SCoPEd is a building block to bringing us closer together not, I repeat, not designed to divide us. Splitting…again? Hope not.”


So, because the Alliance challenges what the big 3 have done, in secret and without consultation, the Chair of the BPC takes a stand from within her certainties and sticks the blame on us. The Alliance (C & P’s), not the BPC, cannot trust colleagues (who exclude them and work in secret).  The Alliance is stupid to see ScoPEd as divisive rather than a building block to closeness. She asserts that bringing us closer together, that is standardising our practices to her design, is a good thing with no evidence that this is so. Then she throws ‘splitting’ at us, in the mistaken belief that the BPC’s use of this term is valid throughout the practice of counselling and psychotherapy and psychoanalysis. What a breathtaking insular view of our practices, which covers us with the cloth of standardisation for our own good, from a pedestal somewhere in the clouds.

TWEET 2, 7th February 2019,

“Is outlining potential differences in competency divisive? These are minimum competencies – they don’t define me – it’s a framework, not meant to be a personal slur. Take a step back. #ScoPEd


“Take a step back”..??!   We are arguing from the outside, the position which has been given to us by this SCoPEd project.  “they don’t define me”, says the person at top of the proposed hierarchy to people at the bottom.







The current consultation does not ask for your views on the content of the draft framework, rather it seeks to garner empirical justification for the standardisation of practice. Perhaps, if you are registered with the BACP, BPC or UKCP, you could respond to the consultation and tell them how you disagree with their ambitions.

If you are registered with one of the big 3 and have not received the invitation to take part in the consultation, please contact them and insist.

In the comments section, you can use the above texts to critique the whole project.

If you are not registered with the big 3, you should anyway take note of this latest attempt to define practice standards, one that will play a role in a future push to state regulation.

This project can be used to lock out all who are not registered with the big 3.

In 2009, the Maresfield Report, a response to an attempt to regulate the field by the Health & Care Professions Council endorsed by ten psychoanalytic training organisations, successfully argued that the diversity and the range of practice in the field of counselling and psychotherapy in the UK served to benefit the public, offering choice as to the aims, techniques and the theories and ethics that underpin practice. Standardisation would reduce choice and diversity. You can find the Maresfield Report on the Alliance front page at

The Expert Reference Group (ERG) proposing standardisation have chosen to interpret some concepts in ways that ignore the history, development and inherent tensions that exist in the psy-field. For example, it is claimed that ‘unconscious could refer to non-conscious, and transference or counter-transference could be described as the client or patient’s internal experience of the therapist, and one’s own experience in response.’ Not all psychotherapists would agree with such definitions.


It is regrettable that the following surely brings up conflicts of interest in relation to the Expert Reference Group who were assembled for this collaboration between BACP, UKCP and BPC.

It is already known that the chair co-wrote a paper with Anthony Roth and Stephen Pilling whose methodology is said to be important to the scoping exercise. Hence, her designation as an ‘independent chair’ is questionable. Moreover, she is of course a registrant of BPC.

And we have noted from the names on the ERG that several have held senior administrative/political posts in the registering bodies.

Now this:

Item 2.1 of the competencies document proposes that ‘qualified counsellors’, when assessing clients, must have the ‘Ability to collaborate with supervisor and (or) other professionals to decide if a client or patient is suitable for therapy’ –  but not the ‘Ability to undertake a competent clinical assessment that is consistent with own therapeutic approach.’ This competency manifestly belongs to ‘advanced counsellors’ and ‘psychotherapists’ only.

Our informant takes this to mean – and we are inclined to agree – that unless you are an ‘advanced counsellor’ you could not therefore function autonomously in private practice or generally regard yourself as competent to make a choice as to whether or not you could see a client.

Research has now shown that there is one particular counselling training system that prefigures this approach. This organisation requires its qualified graduates to do further training before being allowed/permitted to see private clients.

It seems that a member of the ERG used to run this organisation, and this is where the conflict of interest may arise. The more so if this approach is likely to penetrate into the two organisations that register counsellors: BACP and UKCP.

The issue, as it strikes the Alliance, is less about what one might think of the restriction on private practice on the part of ‘qualified counsellors’ per se, and more on how this scoping edifice has been constituted and managed.

Hence, many future ‘qualified counsellors’ the Alliance doubts, could buy into the lists of competencies in relation to their practices. Therefore, anyone who imagines that, were this hierarchical system to become concretely established, they would only be a ‘qualified counsellor’ must do everything possible, when replying to the survey, to indicate that they strongly oppose what is being put forward.


BACP – British Association of Counselling & Psychotherapy –

BPC – British Psychoanalytic Council –

UKCP – United Kingdom Council for Psychotherapy –

PSA – (to which all the big 3 belong) Professional Standards Authority for Health and Social Care – : Until 30 November 2012, it was known as the Council for Healthcare Regulatory Excellence (CHRE). It is an independent body, which is accountable to the Parliament of the United Kingdom. It assesses the performance of each regulator, conducts audits, scrutinises their decisions and reports to Parliament. It seeks to achieve balance in the oversight of regulation through the application of the concept of right-touch regulation

HCPC – The Health and Care Professions Council (HCPC) | –, From the HCPC’s website:

– How we protect the public

We set the standards for the professionals on our Register

We approve programmes which professionals must complete to register with us

We take action when professionals on our Register do not meet our standards

NCS – National Counselling Society –

PCSR – Psychotherapists & Counsellors for Social Responsibility :


[i] Comments at

[ii]Information about the BACP, BPC & UKCP competency framework & survey


View the framework by theme

Theme 1: Professional framework

Theme 2: Assessment

Theme 3: Relationship

Theme 4: Knowledge and skills

Theme 5: Self-awareness and reflection

Appendix: Comparison of current training and practice requirements of BACP, BPC and UKCP


SCoPEd competency framework (pdf 0.3MB)

SCoPEd methodology (pdf 0.5MB)


Compiled by Julia Evans. With contributions from David Murphy, Arthur Musgrave, Ian Parker, Denis Postle, Andy Rogers, Andrew Samuels and many others

Alliance for Counselling & Psychotherapy

(Blog :



Related Texts

Letter signed by Alliance for Counselling and Psychotherapy, Psychotherapists and Counsellors for Social Responsibility, the Psychotherapy and Counselling Union and the College of Psychoanalysts : Against UK political moves towards Statutory Legislation & locking out the clinics of  all practitioners who do not comply (17th  March 2019) : Information here

Three leading professional regulatory bodies create a new competence framework. by Julia Evans on 15th January 2019 or here

The dream of living with no risks by Gustavo Dessal : 1st December 2018 : The Lacanian review online : here

What the Government’s strategy of implementation by force produces – fear, and worse  by Julia Evans on 1st December 2012 or here

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How Government Action goes wrong…. ‘The report says the department pushed ahead without undertaking basic project approval checks, taking decisions before testing the ideas for feasibility.’  by Julia Evans on 20th September 2011  or here

Quotation from Jacques Lacan

Seminar XVII : 14thJanuary 1970 : Jacques Lacan

See  Seminar XVII: Psychoanalysis upside down/The reverse side of psychoanalysis: 1969-1970 : from 26th November 1969: Jacques Lacan or here

p IV 3 of Cormac Gallagher’s translation (

That is my situation and the status of this situation as such has not been regulated, up to the present, in any way that is appropriate to it, except by imitating, except by encouraging, a resemblance to numerous other established situations. In the event, this leads to hypersensitive selection (of) practices, to a certain identification to an image, to a way of behaving, even to a human type that nothing seems to suggest should be obligatory, even to a ritual, indeed to some other measure that, at a better time, a time long past, I compared to that of a driving school, without moreover provoking from anyone any protest whatsoever.


Julia Evans

Practicing Lacanian Psychoanalyst in Earl’s Court, London


7th December 2018 : To request a copy of any text whose weblink does not work, contact Julia Evans: : For fuller details, see Notice : Availability of texts from LacanianWorks by Julia Evans or here


Relevant texts by Jacques Lacan

Some Lacanian history : here

The Direction of the Treatment and the Principles of its Power:10th-13th July 1958 : Jacques Lacan or here

‘Founding Act’ 21st June 1964: Jacques Lacan or here

See also Note for the Year Book : 28th February 1971 : Jacques Lacan or here

‘Proposal of 9th October 1967  on the psychoanalyst of the School’: Jacques Lacan   or here

Talk on Teaching : 19th April 1970 : Jacques Lacan or here

‘The Italian Note’ 1973 : Jacques Lacan   or here

On the Experience of the Pass : 3rd November 1973 (Afternoon in Paris) : Jacques Lacan  or here

Other texts

The Context for the APPG’s survey on prescribed drug dependence by Julia Evans on 30th November 2018 or here

The progress of a bill against Conversion Therapy : a reply from the Minister for Women & Equalities : 12th November 2018 by Julia Evans on 12th November 2018 or here

Further on the progress of the Counsellors and Psychotherapy Regulation Bill (Conversion Therapy) by Julia Evans on 30th October 2018 or here

Opposing the Counsellors and Psychotherapists (Regulation) and Conversion Therapy Bill by Julia Evans 23rd  August 2018 or here

Psychoanalysis and the Post-DSM Crisis : 2014 : Éric Laurent or here

Politics, ethics, regulation and the talking therapies : current positions emerging from Parliamentary debate by Julia Evans on 20th November 2013 or here

Psychotherapy is imposed:  Psycho-analysis© works: Psychoanalysis operates’: 15th December 2010 : by Julia Evans : See here

Challenges to Government’s principles used to define the care of mental ill-health by Julia Evans on 15th July 2010 or here

Why is the Ideology of Evaluation Pernicious? by Jean-Claude Maleval on 14th April 2010 : See here

Use of power here

Ethics here

Definitions of humanness here  & here

Responses to the UK Government action here

UK Government & Government action here

Lacanian Transmission : here

Of the clinic here

Texts on ‘The Symbolic Order in the XXIst Century’ here

Some Lacanian History here

Topology here

By Éric Laurent here

By Jean-Claude Maleval here

By Sigmund Freud here

Notes on texts by Sigmund Freud here

By Jacques Lacan here

Notes on texts by Jacques Lacan here