BABCP submission to the Independent review into mental health conditions, ADHD and autism
The British Association for Behavioural and Cognitive Psychotherapies (BABCP) welcomes the opportunity to contribute to the Independent review into mental health conditions, ADHD and autism.
As the leading organisation for Cognitive Behavioural Therapy (CBT) in the UK and Ireland with over 26,000 members, we are committed to promoting the highest standards of CBT practice, training, and supervision. We hold all our members to the highest professional standards, which they commit to by adhering to our Standards of Conduct, Performance, and Ethics. Alongside the Association for Rational Emotive Behaviour Therapy (AREBT) we keep the CBT Register UK and Ireland. This is the only officially recognised register of BABCP and AREBT accredited CBT therapists, supervisors and trainers, Wellbeing Practitioners and evidence-based Parent Trainers. The CBT Register is a Professional Standards Authority (PSA) Accredited register.
CBT is one of the most effective, evidence-based treatments for a range of mental health conditions and it is recommended by the National Institute for Care and Health Excellence (NICE) guidelines as a possible treatment for adults and young people with ADHD and for a range of mental health conditions including depression (1) and anxiety disorders such as obsessive-compulsive disorder (OCD) (2), panic disorder (3), as well as more complex disorders including psychosis (4) and PTSD (5). CBT is also recommended for long-term health conditions (Abichi et al., 2026).
BABCP has several Special Interest Groups (SIGs) which drive the development of CBT by focusing on specific areas to create new ideas that drive meaningful progress. This response has been developed alongside the Neurodiversity SIG and its subgroup, NDeavour, which is a group of neurodivergent (ND) therapists committed to championing the voice of lived experience.
Due to the nature of our organisation, we will only be submitting evidence on prevalence, inequalities, diagnosis, medicalisation and prevention. BABCP will not comment on medication, as CBT therapists do not prescribe.
BABCP would welcome the opportunity to support further stages of the review. While we do not speak on behalf of neurodivergent communities as a whole, we have sought and incorporated input from BABCP members within the Neurodiversity SIG and NDeavour who are part of these communities.
Trends in prevalence and demand
One in five adults in England are living with a common mental health problem, and rates are steadily rising, according to Mind’s latest Mental Health Report (6). In January alone, 2.24 million people were in contact with mental health services: 1.52 million adults, 526,642 children and young people and 302,652 people accessing learning disability and autism services (7). While this data helps illustrate the scale of service use, it is likely that many more individuals have not yet sought support or referral.
BABCP welcomes the interim report’s recognition that rising demand for mental health support is not confined to a single diagnosis or experience, but reflects broader system-wide pressures. The increase in referrals across services, including NHS Talking Therapies, alongside growing waiting lists for neurodevelopmental assessment, highlights the scale of need within the population. In ADHD, for example, open referrals for children and young people awaiting assessment have increased from approximately 21,000 in April 2019 to around 270,000 by December 2025 (8), representing a substantial rise over a relatively short period.
However, estimates of ADHD prevalence should be interpreted with caution due to differences in how the condition is defined and measured. ADHD is defined within DSM-5, whereas ICD-10 uses a narrower category of hyperkinetic disorder, and some approaches adopt broader, less medicalised frameworks. These differences limit direct comparability between data sources and make it more difficult to interpret changes in prevalence over time (9). BABCP would therefore welcome greater clarity on how the review has accounted for these variations when drawing conclusions from the available evidence.
From our perspective, rising demand for ADHD assessment is likely to reflect a combination of factors rather than a simple increase in underlying prevalence. These include increased public and professional awareness, reduced stigma, and improved recognition of ADHD, particularly among groups who have historically been under-identified, such as adults, women, and individuals from underserved communities (10). As more people come forward for assessment, demand for services has increased significantly. UK Government sources note that reduced stigma and increased awareness have encouraged more people to come forward for assessment indicating that increasing demand is largely the result of previously unrecognised or unsupported needs rather than rapid changes in underlying rates.
At the same time, the scale of current waiting lists indicates that service capacity has not kept pace with this demand. Waiting lists therefore reflect not only rising referrals but also substantial unmet need, and administrative data on diagnoses are likely to underestimate true prevalence due to delays within the assessment pathway.
Long waiting lists further distort the picture of current prevalence as “diagnostic data” is always years behind the real-world demand. The NHS England ADHD Taskforce highlighted that waiting times across NHS services continue to rise, with children facing delays of more than four years and adults waiting up to eight years, as demand increasingly exceeds available service capacity (11).
BABCP has concerns about the framing of ADHD primarily in terms of “overdiagnosis” within the interim report. We believe this framing does not reflect the observations of clinicians and BABCP members, who consistently report supporting individuals with long-standing, previously unrecognised difficulties. In clinical practice, overdiagnosis is typically understood as the identification of a condition that would not cause harm or require treatment (12). However, this differs from the definition used within the review. BABCP would welcome further clarity on how this definition was developed, the evidence base underpinning it, and how consistency of interpretation will be ensured across the review. Without this, there is a risk of variable application in different policy and clinical contexts.
In contrast to an “overdiagnosis” framing, prevalence estimates and clinical evidence suggest that many individuals who meet diagnostic thresholds remain undiagnosed or unsupported. NHS primary care data indicate underdiagnosis of autism in specific populations (O’Nions et al., 2023), suggesting a broader pattern of under-recognition across neurodevelopmental conditions. Similarly, a recent paper published in the British Journal of Psychiatry concludes that “there is no evidence that ADHD is over-diagnosed in the UK (13). Indeed, available data point to under-diagnosis, even though rigorous updated post-COVID-19 pandemic data are not available” (14). This same study estimates ADHD diagnosis at 5% and highlights the risks of an “overdiagnosis” narrative which can be used to delay or deny people access to appropriate care. A global metanalysis had earlier identified an ADHD prevalence of 7.6% in children (Salari et al., 2023). This reinforces the likelihood of an unmet need.
The rapid growth in referrals and waiting lists does not, in itself, provide evidence of overdiagnosis, but may instead reflect a system responding to previously unmet need alongside increased help-seeking. This reinforces the importance of considering both prevalence and service capacity when interpreting current patterns of demand (15).
Having reviewed the Interim report BABCP welcomes the careful view that ADHD cannot be described simply as either over-diagnosed or underdiagnosed and agrees that the situation is complex. However, we continue to re-iterate that in the original report, framing ADHD mainly as “overdiagnosis” does not match what our members see in practice.
While this interim report focuses primarily on common mental disorders, BABCP welcomes its broader consideration of mental health trends, including rising rates of eating disorders, self-harm, and suicide attempts. These trends represent important indicators of distress, particularly among younger people, and highlight the importance of timely access to evidence-based psychological therapies. There is also a growing evidence base supporting CBT-based interventions across these presentations.
Inequalities: differences in access, experience and outcomes
BABCP welcomes the interim report’s acknowledgement of inequities in access to services and it is important that future policy responses do not unintentionally reinforce existing disparities or lead to reduced provision for groups already experiencing barriers to care, particularly in the context of managing rising demand.
Higher demand for mental health support has not been met with higher resource and often those who reach out for mental health support face a long waiting list before being able to access the treatment they need (16). 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 (17). CBT is also recommended by the National Institute for Care and Health Excellence (NICE) for a range of mental health conditions including depression and anxiety disorders such as obsessive-compulsive disorder (OCD), panic, and social anxiety (18). CBT is also recommended by the National Institute for Care and Health Excellence (NICE) guidelines as a possible treatment for adults and young people with ADHD (19)
Neurodivergent people often face barriers to timely assessment and support, including long waiting times, unclear referral pathways, and stigma within services. Evidence from the Children’s Commissioner’s 2024 report on neurodevelopmental services highlights that children can experience waiting times of up to approximately two years and five months for assessment. Adults also face significant delays, with waiting times varying by region and, in some cases, extending to several years (20).
People who are neurodivergent may face additional challenges that increase their risk of experiencing common mental health problems such as anxiety and depression (21). Prompt access to evidence‑based therapies, such as CBT, is therefore crucial to ensure they receive the support they need.
Inequalities in access to diagnosis and support are not only linked to poorer mental health outcomes; they also carry serious physical health and life expectancy consequences for autistic and ADHD people. Research has identified associations between neurodivergence and a range of physical health differences, such as connective tissue conditions (Baeza-Velasco, C. et al., 2018) (22). Studies also show that both autistic and ADHD people face a higher risk of early mortality (Catalá-López,et al., 2022) (23), while ADHD medication is associated with lower rates of all–cause mortality (Li et al., 2024) (24).
The interim report highlighted that inequalities in mental health and neurodevelopmental conditions are a central concern for the overall review, and as we also highlighted, they are also complex and multidimensional. BABCP acknowledges that less equitable outcomes were identified for Autistic people accessing NHS Talking Therapies between 2012-2019 (El Baou et al., 2023). No community should be underserved by public provision, and significant steps have been taken to improve equitable outcomes, including the outcome of research which commenced prior to 2019 and the release of an updated curriculum for High-Intensity CBT Training (NHS England, 2025).
BABCP welcomes the acknowledgement within the interim report that the distress experienced by these communities is genuine and is not currently treated equitably. BABCP is aware of concerns within these communities following previous experiences of engaging in consultations where outcomes have maintained systemic issues. While we do not anticipate a repeat of these experiences, we acknowledge the concern expressed that efforts to reduce pressures on services and manage limited resources could lead to continued under-provision.
Diagnosis pathways
Diagnosis is essential for many people to understand themselves, access adjustments, or engage effectively in therapy. However, waiting times for assessment remain unacceptably long and vary considerably by region and pathway. Some reports indicate waits of around two years and five months for children, while the NHS England ADHD Taskforce has highlighted delays of more than four years for some children and up to eight years for some adults (25). These delays significantly postpone diagnosis and can worsen mental health outcomes. This falls far short of NICE guidance, which states that people with suspected autism should have a diagnostic assessment started within three months of referral. This falls far short of the National Institute for Health and Care Excellence (NICE) guidance which states that people with suspected autism should have a diagnostic assessment started within three months of their referral, so that appropriate health and social care interventions and support can be provided (26).
In addition to delays in access, the process of assessment itself presents challenges. CBT delivery and wider psychological research rely on validated psychometric tools; however, BABCP is aware of evidence suggesting that some screening tools may be sensitive to the choice of scoring thresholds. For example, the AQ-10 may result in suboptimal classification in certain contexts (Waldren et al., 2025). This highlights the importance of interpreting screening-based prevalence estimates with caution (27).
Because different services use different (and sometimes outdated) assessment tools, people receive unequal and inconsistent diagnostic experiences across the country. Poor quality or outdated diagnostic letters may reinforce deficit-based narratives of neurodiversity, contributing to shame and internalised stigma that can hinder engagement with CBT by increasing negative core beliefs and reducing self-efficacy (Wood, L., Byrne, R., Varese, F. and Morrison, A.P. 2016) (28).
Although NICE provides clear guidance on autism and ADHD assessment, this is often not followed in practice due to capacity pressures, inconsistent tools and long waits, creating significant stress for patients and families who cannot access the assessments and support, and patients.
Evidence suggests that CBT can be particularly beneficial when it is delivered in a flexible, neurodiversity-informed way, and when practitioners are well trained to adapt approaches to individual needs and lived experience (Horwood et al., 2024) (29). Research indicates that Autistic and ADHD people report more positive experiences of CBT when their perspectives are actively understood and affirmed within therapy (Cooper et al., 2018) (30).
However, the effectiveness of CBT is influenced by how and when it is delivered by accredited, appropriately trained cognitive behavioural psychotherapists. Timely access to appropriately adapted interventions is important, as delays in support and variation in service quality may limit effectiveness and contribute to ongoing distress.
The Government must ensure that NICE guidelines are followed when diagnosing ADHD, Autism and common mental health conditions. It must also reduce delays in access to assessment and potential diagnosis services as prompt assessment could lead to earlier treatment thus improving the mental health of those affected.
National data suggest that with approximately 61.6% of adults and 65.8% of children waiting more than one year for an ADHD assessment (31), while other reports have identified much longer waits in some local areas, with some children waiting more than four years and some adults up to eight years.
Medicalisation
The Review’s early framing around “medicalisation” risks misunderstanding what diagnosis actually does and may inadvertently reinforce stigma. It is important to emphasise that diagnosis does not pathologise identity; rather, it provides a framework that enables access to appropriate support and accommodations.
Current NICE guidelines recommend medication in some cases for ADHD, Autism and some common mental health conditions including anxiety and depression. Such guidance remains relevant and inevitably this means that those who have any of these conditions may need to access clinical help to manage their symptoms.
NICE guidance also states the importance of CBT as a recommended treatment for many common mental health conditions including anxiety (32) and depression (33). CBT is also recommended by the National Institute for Care and Health Excellence (NICE) guidelines as a possible treatment for adults and young people with ADHD (34). CBT is accessible not only in clinical settings but also in education and community settings through different Government initiatives including Mental Health Support Teams (MHSTs), Early Support Hubs and Young Future Hub – increasing access beyond traditional healthcare pathways.
In considering concerns around medicalisation, BABCP recognises the interim report, noting that while diagnostic and clinical frameworks are essential for identifying need, there is a risk that distress, particularly where it arises from social or environmental factors, may be overly framed as a medical issue. This can result in diagnosis becoming the primary route to support, even when non-clinical interventions may also be appropriate.
At the same time, as expressed above, diagnosis is very important for many people to understand their experiences and access care. CBT plays an important role as a non-medical, evidence-based treatment option. For many people, it can provide effective support for managing anxiety, depression, ADHD-related challenges, and distress linked to life circumstances, and may be used alongside medication or as an alternative to medication-based approaches.
BABCP therefore supports a balanced, needs-led approach where people can access the right type of support for them. This includes evidence-based psychological therapies such as CBT, as well as social, educational, and community support. It is important that concerns about medicalisation do not create barriers to getting timely and effective help, especially for people with high levels of unmet need.
Evidence also shows that autistic people often report identity a‑affirming, adapted CBT as the most helpful therapeutic approach(Cooper et al., 2018; Horwood et al., 2021). Moreover, a growing evidence base supports the value of neurodiversity-affirming therapy. Studies consistently find that affirming approaches improve both clinical outcomes and treatment satisfaction for autistic clients (Pantazkos & Vanaken, 2023; Kroll et al., 2024; Paynter et al., 2025) (35).
Prevention and early intervention
BABCP supports early identification and timely access to evidence-based psychological support, particularly where this can reduce distress, improve functioning, and prevent escalation of difficulties.
However, prevention and early intervention should not be interpreted as reducing the number of people with neurodevelopmental conditions in the population. ADHD and autism are neurodevelopmental differences. Government action on neurodiversity should focus on preventing harm, ensuring early intervention and guaranteeing prompt access to assessment, diagnosis and appropriate support.
We further support the interim report’s mention of a move towards more community-based and stepped approaches to care, where people can access lower-intensity support earlier and be referred to more specialist services when needed. This is positive to see as early support can prevent issues such as school exclusion, mental health deterioration and crisis escalation, or the development of secondary conditions such as depression or post-traumatic stress. Therefore, Child and Adolescent Mental Health Services (CAMHS) are a strategic hotspot, crucially situated at the intersection of neurodevelopmental trajectories and putative early indicators of risk for later severe mental illness. This increases the likelihood of detecting these signs early, enabling secondary prevention strategies to mitigate the risk of progression to full-blown disorders (36). Early identification also supports more effective CBT (37). However, this should not replace timely access to assessment or specialist care where needed, particularly for individuals with complex or long-standing difficulties.
Furthermore, ‘equipping dedicated educators with foundational CBT principles and practical strategies to support student well-being in the classroom can empower staff to recognise early signs of distress and implement proactive, supportive approaches’.
The focus on functional need is also helpful, as it supports a more flexible system where people are not assessed only by diagnosis, but by how their difficulties affect daily life. The Government should also ensure that the workforce is well-trained to assist those who come forward seeking assessment for a potential diagnosis. Negative experiences of seeking help have been shown to increase hopelessness among autistic people, including increased thoughts of suicide when they do not receive the support expected from services (Camm-Crosbie et al., 2019).
For common mental health conditions, such as anxiety and depression, prevention is key and so is early intervention. We have welcomed recent moves from the Government aiming to move to a preventative approach and more community care. However, while there is increasing provision and training of psychological therapists who can provide such intervention, demand continues to outstrip capacity, leaving too many people facing long waits for support and risking their conditions worsening before they receive the help they need.
Education is a key setting for the prevention of emerging mental health difficulties, early identification of need, and promotion of emotional wellbeing among children and young people (38). As such, children and young people should be a central focus for investment. Demand and complexity have increased significantly since the COVID-19 pandemic (39), yet there is still no equivalent national guidance for increasing access to evidence-based psychological therapies for children, young people and families, unlike the established frameworks available for adults and older people. This means that many CYPMHS continue to manage high levels of risk and complexity without sufficient psychologically informed or accessible practice (40).
Whilst the introduction of MHSTs is credible and desirable, in terms of prevention and early intervention there needs to be national guidance on a stepped/matched model of psychological therapies. This will ensure children and young people in need of secondary care also receive evidence-based approaches for early intervention and prevent escalation to hospital.
Children should also learn about mental health and neurodiversity (41). Other healthy habits – such as drinking water during the day and ensuring everyone coming to school has free or (genuinely) affordable healthy foods – should also be promoted.
Lastly, it is crucial to also embed mental health and neurodiversity awareness in every area of society, from early years education to older adult care. This will provide the population with an opportunity to take care of one’s mental health by building it into school curricula, social care and the workplace acting as a preventative tool allowing early identification of any challenges (42).
Additional considerations for the review
It is crucial for the Government to invest in people who are delivering health and care services, in particular mental health support. These should include training and career pathways, providing reasonable income and support to increase staff wellbeing and retention. NHS Talking Therapies published a Staff Wellbeing Strategy (43) which includes a model for workforce wellbeing. The paper argues that improved outcomes for staff and clients/patients could be achieved by using compassionate leadership, collaborative management, effective teamwork and belonging – for and by all – and evaluation. Good staff wellbeing should be proactively maintained and improved within the changing NHSTT and working environment as this would reduce the risk of burnout enabling services to respond to patient need.
Neurodivergent healthcare staff also face additional barriers. Research shows that they often face prejudice (Beagan et al., 2025) and feel unsafe disclosing their neurodivergence within the profession than in wider society (Iacobucci, 2025) (44).
Clinicians who are neurodivergent often face sensory overload in clinical environments, burnout due to high administrative load, unsuitable adjustments or toxic workplace cultures that misunderstand or stigmatise neurodivergence. This leads to people leaving the profession and services losing skilled staff (45).
We believe the review should recognise not only neurodiverse people but neurodivergent clinicians as an affected group and that national guidance should set expectations for neurodiversity inclusive workplaces across NHS Talking Therapies and wider services. This would ensure workforce retention, which in turn will assist in reducing the waiting list and helping with achieving better mental health for the country as a whole.
