The Privy Council’s production via regulation of the one treatment, excluding all others, from the area known as Mental Health : 27th September 2021 : Julia Evans

by Julia Evans on September 28, 2021

For the attention of the Privy Council, 1 Horse Guards Road, London, SW1A 2HQ. Sent by email.

Copy : Mr Craig Mackinlay MP, Member of Parliament for South Thanet

From : Julia Evans, Lacanian Psychoanalyst, Sandwich, Kent

27th September 2021

The Privy Council’s production via regulation of the one treatment, excluding all others from the area known as Mental Health

The purpose of this message is to draw your attention to the clash 

between the aspirations of the Privy Council in implementing the Health Professions Order 2001 to practitioners providing treatments to subjects, defined by the Government’s NICE clinical guidelines, as having mental health issues, 

and what practitioners trained in many different perspectives & traditions bring to this clinic.  

There is no one correct solution.  

Further, the pretence contained in HPO 2001, and driven by Privy Council power, that there is a safe way of practicing which always produces a standard result, prevents many experienced practitioners from being within the Government’s provision of mental health services.  This limits availability of treatments.

My message adds to a Public Briefing Paper from the UK Association for Humanistic Psychology Practitioners. It should be attached or is available  https://ahpp.org.uk/wp-content/uploads/2021/08/BRIEFING-PAPER-PSA-Changes-V3-Aug-2021.pdf This Public Briefing Paper explores : Concerns about proposed regulatory changes to the ethos of the voluntary Accredited Registers Programme and impact on the accessibility of psychotherapy and counselling and service user choice in the UK

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I, Julia Evans, have been raising concerns about the Privy Council operating the clinic for those subjects defined as having Mental Health issues, within Parliament since 2005.  My involvement commenced in 2000, prior to the promulgation of the Health Professionals’ Order 2001.  At issue is the object of the Order and the use of Privy Council power to obtain this perverse end:

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From Health Professions’ Order 2001 :

Section 3 (4) The main objective of the Council in exercising its functions shall be to safeguard the health and well-being of persons using or needing the services of registrants.

(5) In exercising its functions, the Council shall—

(a) have proper regard to the interests of all registrants and prospective registrants and persons referred to in paragraph (4) in each of the countries of the United Kingdom and to any differing considerations applying to the professions to which this Order applies and to groups within them; and

(b) cooperate wherever reasonably practicable with—   (i) employers and prospective employers of registrants,  (ii)   persons who provide, assess or fund education or training for registrants or prospective registrants, or who propose to do so,   (iii)  persons who are responsible for regulating or coordinating the regulation of other health or social care professions, or of those who carry out activities in connection with the services provided by those professions or the professions regulated under this Order,  (iv)   persons responsible for regulating services in the provision of which registrants are engaged.

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What, about safeguarding the mental health and well-being of subjects, is possible?

When does safeguarding become perverse, as with for example the Inquisition who guarded your soul from hell?

How do you know when you are operating a perverse system of regulation?

What does this form of megalomaniac control add to the use of legislation on financial abuse or fraud, physical abuse, sexual or physical assault, grooming or stalking. 

So what HPO 2001 sets up is rules, regulations and codes with the force of Privy Council power behind them, to ensure that only procedures agreed by the Privy Council’s agents, can be used.  There is the one, Privy Council-guaranteed way of giving talking treatments to subjects categorised as in need by NICE clinical guidelines, so they can be returned to an acceptable standard of humanness (presumably as defined by Privy Council agents or maybe using the Government’s economic definition of not receiving benefits).

I have been deconstructing this position for 20 years, as it devalues what it is to be a human subject & supports treatments which actually do not work, though they register well on your/the Government’s evaluation procedures.

Further the Privy Council approach to regimenting practitioners, produces Professionals, plastered in certificates allowing them to apply permitted procedures (usually cbt) to unique subjects defined as ‘ill’ or suffering substandard mental health.  This is based on the medical model, with the difference being that in medicine, usually symptoms can be verified by physical examination or x-rays or … & the intervention is directly onto the subject’s body. In the area of mental health, there are problems of definition. Is how I perceive an anxiety state the same as your perception?  Is my definition of well-being (sitting in a gutter drinking a bottle of vodka) the same as yours?  

So the Privy Council, in HPO2001, assumes that wellbeing can be defined, that mental health can be defined, that it can regulate practitioners and prevent harm (the Privy Council should tell their secret to the Police, so they too can prevent all crime which harms), and can measure all this up using a standard of normal mental health.

I draw your attention to further texts by Julia Evans  Index of texts by Julia Evans  or here  

& two recent texts

The Royal College of Psychiatrists & Lacanian in the UK : Comments following Éric Laurent’s ‘The Culture of Abusive Treatments’ (LQ 930/LRO 308) (8th January 2021) : Julia Evans : 3rd July 2021   or  here  

Alliance for Counselling & Psychotherapy Newsletter : SCoPEd & a new APPG? co-ordinated by Julia Evans on 31st  October 2019 or here     

Further I strongly recommend a Public Briefing Paper from the UK Association for Humanistic Psychology Practitioners. It should be attached or is available  https://ahpp.org.uk/wp-content/uploads/2021/08/BRIEFING-PAPER-PSA-Changes-V3-Aug-2021.pdf 

Julia Evans

www.LacanianWorks.net & www.LacanianWorksExchange.net  

a Lacanian

– member of the London Society of the New Lacanian School, which is part of the New Lacanian School of Psychoanalysis, which is a member of the World Association of Psychoanalysis (https://www.wapol.org/en/Template.asp)  I practiced as a Chartered Psychologist for 20 years, then in the Lacanian field for 30 years – having trained for 10 years.  Your Privy Council rules & regulations forbid me from practicing with your stamp of approval, registration, on the grounds that I am a dangerous charlatan.  What is your, the members of the Privy Council, evidence for defining me thus?

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Public Briefing Paper from the UK Association for Humanistic Psychology Practitioners,  available https://ahpp.org.uk/wp-content/uploads/2021/08/BRIEFING-PAPER-PSA-Changes-V3-Aug-2021.pdf   August 2021 : An extract

PUBLIC BRIEFING PAPER: Concerns about proposed regulatory changes to the ethos of the voluntary Accredited Registers Programme and impact on the accessibility of psychotherapy and counselling and service user choice in the UK

Background

The purpose of this paper is to highlight how proposed regulatory changes to the Accredited Registers (AR) Programmeunder the Professional Standards Authority (PSA) will potentially impact on the accessibility of psychotherapy and counselling in the UK. 

The PSA which is accountable to the government via the Privy Council is responsible for overseeing ten statutory bodies regulating health and social care in the UK. The Accredited Register Programme was launched in 2012 to promote best practice and good governance for voluntary professional registers and over two million unregulated health and social care providers. 

To date the AR programme has accredited 23 voluntary registers, accounting for 102,330 registrants over a wide range of professions including counselling and psychotherapy (see Appendix 1). Organisations have joined the programme for different reasons, some registers see it as a way of gaining recognition and access to the National Health Service (NHS); some see it as a stepping stone toward statutory regulation, whilst others see it as vehicle for expanding market influence – all registers are committed to enhancing public confidence in the programme through the maintenance of high professional standards. 

There has been an abundance of enthusiasm and goodwill in support of the AR programme since it was launched in 2012. However, following the first Coronavirus lockdown in 2020 the PSA published a consultation paper in which it mapped out its vision for the future. This vision is not, as it could have been, the product of collaborative enquiry with register holders about how the programme could evolve. In essence the PSA is proposing a departure from the fundamental ethos of the programme as a government endorsed voluntary registration assurance scheme. 

The PSA’s vision for the future is based on the understanding that ‘patients’ have difficulty in navigating multiple registers and that for a voluntary assurance scheme to be effective there must be greater standardisation and consistency between registers. The measures the PSA intends to implement include:

  • Financial Self-Sustainability of the Programme: Following the withdrawal of funding by the Department of Health and Social Care (DHSC) the programme will have to be financially self-sustainable by 2022. 
  • Efficacy of Treatments and Therapies Covered by the Programme: The introduction of a mechanism in alignment with the NHS Commissioning Frameworks and the National Institute of Clinical Excellence (NICE) for assessing the risk posed to the public by health care occupations and the treatments and therapies provided by registrants.
  • Access to the AR Programme:  Restricting access to the AR programme through the establishment of conditions for the amalgamation, merger or takeover of registers, so as to pave the way for single profession monopolies and a single register for all non-statutory health care professions.
  • Change of Ethos: Shifting the ethos of the programme from an organisational perspective to an occupationalperspective with greater emphasis on determining what service users can and cannot access. 
  • Raising Awareness about the Programme: A campaign to raise awareness and recognition about the AR programme and to deter service users, employers and service commissioners from accessing the services of any health care professional whose name is not included on a statutory or accredited register.

Without consultation with register holders and other stakeholders, the PSA gave notice of its intention to abandon all but the first of the five design principles the programme was founded upon and which all registers holders signed up to:

  1. Ensure that any restrictions developed through the creation of the Standards, or the operation of the programme, would reflect the potential risks of harm to the public. 
  2. Not unfairly or unnecessarily restrict the market by creating monopolies. It should be open to any eligible register, including those relating to the same occupation.
  3. Be affordable for applicants, and not price small registers out of the market, making it open to registers clustering under umbrella organisations.
  4. Should not set the education and training requirements for entry onto a register. 
  5. Would not make any judgement about the effectiveness of any therapy or health or care practice. 

The redesign of these principles suggests that the programme as originally envisaged as a voluntary assurance scheme will cease to exist and be replaced with a framework for regulating professional occupations and the delivery of health care provisions in the independent sector (charities, voluntary services, private practice, commercial etc.). 

If left unchallenged the consequences of these measures will have far reaching effect within the wider field of counselling and psychotherapy. Diversity of care and service user choice will be further diminished and the employment/livelihood of many health care professionals who remain committed to upholding high professional standards will be threatened. 

The following sections consider some of the consequences the PSA’s decisions are likely to have on the wider field of counselling and psychotherapy and service user choice.  ….

Continued at https://ahpp.org.uk/wp-content/uploads/2021/08/BRIEFING-PAPER-PSA-Changes-V3-Aug-2021.pdf 

NOTE

John Fletcher – UKAHPP Chair – requests that you forward a copy of the UAHPP’s paper to the Privy Council, adding your comments, with a copy to your constituency MP & also send an e-copy of the briefing paper to colleagues and others who may be interested. 

Additional texts

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

Against UK political moves towards Statutory Legislation & locking out the clinics of all practitioners who do not comply by Julia Evans on 17th  March 2019 or here

Newsletter against the BACP, BPC & UKCPs’ SCoPEd project : 8th February 2019 : Alliance for Counselling & Psychotherapy, compiled by Julia Evans : information here    

Julia Evans :  Three leading professional regulatory bodies create a new competence framework. (15th  January 2019) : Information here    

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

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

Julia Evans : Further on the progress of the Counsellors and Psychotherapy Regulation Bill (Conversion Therapy) : 30thOctober 2018 : Information here

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

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

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

CHRE(PSA) trumpets its success in creating a ghetto of wellbeing practitioners who are compliant (for a fee) to the Government’s fantasy of safeguarding. by Julia Evans on 3rd   October 2012 or here

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

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

Use of power here

Ethics here

Definitions of humanness here  & here

Responses to the UK Government action here

UK Government & Government action here

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Note : If links to any required text do not work, check www.LacanianWorksExchange.net. If a particular text or book remains absent, contact Julia Evans

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Julia Evans

Practicing Lacanian Psychoanalyst

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Further posts:

Some Lacanian history here

Lacanian Transmission here 

Politics   here   

Of the clinic here 

Translation Working Group here 

Use of power here 

By Sigmund Freud here 

Notes on texts by Sigmund Freud  here 

By Jacques Lacan here 

Notes on texts by Jacques Lacan here 

By Julia Evans   here