BABCP welcomes the opportunity to submit evidence to the Commission for the Future of Counselling and Psychotherapy call for evidence on the future of the profession. Our response aims to contribute to the Commission’s aim of examining the current and future landscape of the professions to identify the key issues affecting the sector, professionals, and services.
State of the sector
What experience and/or evidence do you have about how counselling and psychotherapy positively contributes to mental health support across the UK?
How well do different groups (members of the public, government and decision-makers, commissioners) understand the benefits of counselling and psychotherapy?
What makes it difficult to access counselling and psychotherapy professionals/services?
There is substantial evidence on how psychotherapy contributes to mental health support in the UK. CBT is one of the most effective, evidence-based treatments for a range of mental health challenges and it accounts for over 70% of all courses of therapy given by NHS Talking Therapies (1). Data from NHS England shows that with more than 5,000 courses in 2022-23, the highest rates of therapy-based recovery and improvement are amongst Cognitive Behaviour Therapy (45.0% and 60.7%), Interpersonal Psychotherapy (48.7% and 62.4%), and Counselling for Depression (47.6% and 58.6%) showcasing the positive contribution of psychotherapy to society (2).
Furthermore, CBT is one of the most evidence-based cost-effective treatments. According to research by David M Clark, for every £1 spent on NHS Talking Therapies, the program saves £2–3 through reduced welfare benefits, sick leave, and healthcare costs (3).
CBT is also recommended by the National Institute for Health and Care Excellence (NICE) for a range of mental health conditions including depression and anxiety disorders such as obsessive-compulsive disorder (OCD), panic, and social anxiety, as well as more complex disorders including psychosis and PTSD (4). CBT is also recommended as an intervention in The Matrix Cymru (5) and in Scotland’s Matrix (6) for addressing various conditions, including anxiety disorders, depression, Obsessive compulsive disorder (OCD), trauma and associated symptoms, eating disorders, personality disorders amongst others as well as to help people cope with symptoms of many other conditions such as chronic pain.
There is not much evidence on whether different groups understand the benefits and psychotherapy. Members of the public who may have received psychotherapy interventions or those policy makers involved in the development of NICE guidelines may understand it better. However, one could assume that the Government and Commissioners do not understand the benefits enough as the current funding for psychological therapies is not matching the funding given to other types of treatment, such as cancer or cardiovascular disease despite parity of esteem being enshrined in law by the Health and Social Care Act 2012.
There are a variety of barriers to accessing counselling and psychotherapy. These include
- Individual stigma: while there has been some progress in recent years, there is still individual stigma associated with seeking psychological help prevalent among many people, particularly men
- Accessibility issues: people with disabilities or in rural areas may not have access to getting to the place where psychotherapy is being delivered or have access to equipment and knowledge/skill in using it for remotely delivered therapy
- Cultural barriers: some communities may be less likely to access psychotherapy or counselling due to cultural barriers and the lack of interpreters within NHS that could facilitate psychotherapy interventions
- Waiting list: often after a referral being made, there is a waiting list to accept the type of intervention that is needed when going through the NHS route. This is particularly acute for children and young people with over half a million children waiting for mental health support (7) .
- Cost: if treatment isn’t available in the NHS when needed – due to waiting list or other factors- private psychotherapy can be cost prohibitive for many people.
Regulation of the professions
Following increased political and public attention on counselling and psychotherapy and how the professions are regulated, the Commission for the Future of Counselling and Psychotherapy has included regulation within its scope.
Any move towards statutory regulation, including protected titles or criminal sanctions, can only be introduced by government through legislation and is outside the direct powers of the PCPB. At present, we are not aware of any government plans to bring forward statutory regulation of the professions. However, the Commission will also consider non-statutory and voluntary enhancements, including the role of PSA-accredited registers and other measures that could strengthen public protection within the existing framework.
How should counsellors and psychotherapists be regulated to protect the public and maintain good standards?
What are the strengths and weaknesses of the current voluntary registration scheme?
What are the strengths and weaknesses of other forms of regulation, such as statutory regulation?
The main aim of statutory regulation of healthcare professions is to ensure public protection. This is a principle that we wholeheartedly agree with.
Some of the benefits of statutory regulation include:
- Public protection: statutory regulation may ensure that only those with appropriate training, specialist additional training where needed and those who are registered with the regulator are able to treat people using the appropriate evidence-based interventions for the presenting issues. This includes the need to ensure that there are clear and consistent criteria for additional and/or specialist training and supervision to work with people who have more complex needs.
- Protection of title: Statutory regulation would also ensure that only those meeting agreed professional standards should be able to use protected professional titles. The list of agreed titles that should be put forward for statutory regulation and therefore protection should be agreed by all professional organisations.
- Enforcement mechanisms: statutory regulation has processes for holding people to account, keeping records of sanctions and publishing outcomes of disciplinary and fitness to practice processes; and data sharing.
The biggest weakness of the current voluntary model allows for non-registered practitioners to call themselves psychotherapists, CBT therapists, or Counsellors even if they have only done a two-day training course, or even none, which can bring the profession into disrepute and mislead or harm people seeking help.
The biggest strength is the PSA’s oversight over the voluntary registers which allows for a robust enforcement mechanism as well as the knowledge that each professional body and register has of its individual discipline. Currently, PSA-Accredited registers ensure public protection, by setting and promoting ethical standards of conduct and professional practice as well as providing the public with clear complaints and fitness to practice route enforcement mechanisms.
We believe that for statutory regulation to be successful, the framework will have to be developed in collaboration with professional bodies representing each therapeutic modality and with members of the public, particularly those with lived experience. This is particularly important for training pathways and standards where professional organisations have expertise in the training and competency standards for that modality and should be responsible for defining its own requirements if proceeding with statutory regulation.
Statutory regulation should also ensure transparency, equity and accessibility so members of the public can check a practitioner’s registration status –including any conditions placed on registration- and the standards they are accountable to. They will be able to access clear, understandable information about their rights, how to raise a concern, or make a complaint.
We believe that both statutory and voluntary registration models have advantages and can provide high protection for the public. One drawback of voluntary registration is that it relies on employers or independent practitioners valuing and requiring PSA registration. It also relies on members of the public being well informed about what registration means, so that they seek a registered practitioner.
Evidence and research
How can existing research be better used to show the value of counselling and psychotherapy?
What areas of counselling and psychotherapy need more research and funding?
Currently, NHS England is committed to funding evidence-based counselling and psychotherapies which are safe and cost-effective. It is specifically guided by NICE guidance in making decisions about funding services and treatments. We believe that this is appropriate and balanced.
Where outcomes are not good, or the evidence for psychotherapies and counselling is emerging but not established, funding for research should be prioritised. In particular, for people with multiple and complex needs, outcomes are currently poor despite high-cost interventions. For all services delivering interventions, the service model should include outcome monitoring.
Future of the professions
What are the biggest opportunities and threats for counselling and psychotherapy over the next five years?
What would you like to see from governments across the UK to maximise the value and contribution of counselling and psychotherapy?
What should be the priorities of the Partnership of Counselling and Psychotherapy Bodies over the next five years?
The biggest opportunities include:
- Delivering large-scale evidence-based outcome-measured projects like NHS Talking therapies in the other nations in the UK – Northern Ireland, Wales and Scotland-
- Properly resourced mental health care, across all age groups and levels of need in the home nations, recognising that properly funded, structured, evidence-based services where outcomes are measured provide a net gain to the Treasury, in addition to alleviating suffering
- Funding for children and young people’s services which are greatly under-resourced and underfunded – In 2023/24, there were 78,577 young people waiting over a year for mental health treatment from the NHS, with 44% of these waiting over two years (8).
- Educate the public about evidence-based psychotherapies.
The threats include: the potential for underfunding as it is perceived to be easier to defund psychological therapies than other areas of medicine such as cancer treatment despite the potentially life-saving nature of evidence-based psychological therapies being provided. As a consequence of underfunding, people may not receive the right dose of treatment or as urgently as needed, which in turn may not be as effective, thus risking more defunding. Lastly, internal disagreements amongst professional psychological bodies and the profession as a whole are an important threat.
We believe that one of the key priorities for the Partnership of Counselling and Psychotherapy Bodies in the next five years should be to collaborate successfully with each other and potentially educate the public, policy makers and commissioners about the evidence-base and the cost-effectiveness of psychological therapies.
