Following the above, the government would reach its own conclusions on those proposals and the Secretary of State would then be obliged to open the government’s own separate consultation process, prior to finalisation and introduction of any proposals for regulation.
As an initial stage in the above process, HPC will, within the next two weeks or so, be announcing the names of those representatives of stakeholders who will constitute the Professional Liaison Group. That group will consider the above objectives with a view to advising HPC on how, if at all, regulation might proceed. The deliberations of the group will be held in public and anyone will be free to attend. Minutes of all those deliberations and recommendations will also be published by HPC, as the deliberations proceed. Any group not directly represented on the PLG will be free to submit representations which the PLG will be obliged to consider.
MS then made the following points:
The main concern of HPC will be how many practitioners from the professions concerned are likely, in the end, not to be regulated by them and how many avoid regulation.
Ideally, they would like one standard of education for each profession regulated by them.
The professional title counsellor will not be acceptable without some additional descriptor but psychotherapist would be.
HPC wants as few regulated professional titles as possible.
HPC wants short documents wherever possible e.g. for standards of proficiency. DL questioned why brevity of documents should be an aim in itself. It seemed clear that they wanted a series of equal-sized pamphlets, even if this risked compromising the complexity of a discipline.
CPD is likely to be dealt with very much along the lines of relying on practitioners to use their own discretion to ensure CPD input but regular audits will be carried out by HPC on a spot-check basis.
DL then attempted to inform the representatives of HPC about how their proposals are likely to affect psychoanalysis. For example, does HPC include psychoanalysis within the remit they have given themselves to regulate psychotherapy? The response from MS was vague and clearly they have not yet begun to address this issue. It was very clear that they have little understanding of what psychoanalysis entails. MS did, however, state that, if a suitable case could be made, it would be possible, in theory, for HPC to recommend specifically to government that psychoanalysis should be excluded from any proposals to regulate psychotherapy.
DL then went on the explain how psychoanalysis is considered to differ significantly from many forms of psychotherapy. In particular, he explained the importance of the difference between conscious and unconscious motivation and the significance of transference phenomena in the relationship between analyst and patient and how these might have very serious consequences for issues relating to complaints, under fitness to practise provisions. It became clear that MS and SM had some difficulty in understanding the concept of transference but they were very willing to listen to the points made by DL, particularly in relation to specific examples that he was able to give them, namely libidinal and other issues and their effect on the transference. DL emphasised how analytic work aimed to undermine any ritualisation of the experience, so that the analyst endeavours never to be in the expected place, a fact which runs counter to the standardisation of technique. Analytic work also has no fixed outcome and makes no promises regarding healthcare goals.