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The importance and benefits of state regulation for psychotherapy in Ireland

by Anne Colgan

Editorial note: Anne Colgan was present at the conference chaired by Dr. Finian Fallon on ‘What is the future for counselling and psychotherapy in Ireland?’, City Colleges, Dublin, March 25th, 2018. At the invitation of the Editorial Board, Anne wrote from a counterpoint position to the previous article.

Historical
IAHIP is a member of The Irish Council for Psychotherapy (ICP, www.psychotherapycouncil. ie) which was founded in 1990 in Dublin. It unites psychotherapy organisations into a common association which organises individual psychotherapists of different approaches in Ireland based on the 1990 Strasbourg Declaration of Psychotherapy. ICP, as the national umbrella body, represents five psychotherapeutic approaches or disciplines, eleven professional organisations and more than 1,500 psychotherapy practitioners who operate to rigorous standards of competence and professionalism. In 2005, all the modalities of ICP and other organisations met the then Minister for Health, Tim O’Malley, demanding statutory regulation. This is an old concern and aspiration for the profession, and it has been on the agenda since IAHIP co-founded the Irish Standing Conference of Psychotherapy in the early 1990s, which later became ICP.

In August 2016, the Minister for Health, Mr. Simon Harris TD, invited interested parties, organisations and other bodies to make representations to him concerning the proposed designation under the 2005 Act. In November 2016, ICP, IAHIP and individuals within IAHIP submitted papers to the Department of Health as a response to Mr. Harris’ open invitation. Much of what was presented by ICP was in line with the Minister’s vision, in particular, the importance and benefits of state regulation for psychotherapy in Ireland (a copy of the ICP paper is available on the ICP website).

Training
IAHIP has long advocated for statutory regulation of the profession of psychotherapy as a means of protecting the public and to promote excellence in the profession. While IAHIP is currently regulated on a voluntary basis, IAHIP and the other modalities of ICP see statutory regulation as providing many advantages for the public, psychotherapists and employers, not least increased confidence in the profession. Crucially, only those practitioners who have achieved the necessary standards as accredited psychotherapists will be able to practice, thereby protecting the public.

IAHIP-accredited psychotherapists are currently on a par with the highest European-wide standards for psychotherapy, as evidenced by their eligibility for the European Certificate for Psychotherapy (ECP). To be granted the ECP, a psychotherapist has to fulfil a set of criteria in relation to the level of training, supervision and practice (http://www.europsyche.org/download/cms/100510/ECP-document-version-6-0-voted-AGM-Vienna-Feb-2016_ fin-o.pdf). IAHIP argues for the retention of these current academic, clinical training and accreditation standards to maintain excellence in psychotherapy practice, to sustain the current high standing of Irish psychotherapy in the European context, and to ensure the continued development of the profession in Ireland. Level 9 on the National Framework of Qualifications, or its equivalent, represents the minimum current academic qualification for ICP registered psychotherapists and ECP holders.

Protection of title and external threats
IAHIP and ICP support the Minister’s position in relation to two registers. There are clear distinctions between psychotherapy and counselling, including the length and depth of training, the length required for personal reflective practice, the ability to work with deep- seated problems, including mental illness and personality disorders, and the length of the therapy itself. The length, depth and breadth of psychotherapy training and professional formation ensures that the psychotherapist is skilled and competent to manage complexity in clinical practice. It is clear that failure to draw a distinction between the two professions in Ireland would create confusion and a misunderstanding of the practice of the profession of psychotherapy accepted throughout Europe. Further, it is the Council’s view that by not holding to the distinction between the two professions, the protection of the public is thereby undermined, as clarity in relation to clinical training, academic qualifications and professional intent would be blurred.

It would be an extraordinary paradox if regulation of a profession resulted in lowering the standards of training rather than preserving current rigorous and internationally recognised standards. We operate increasingly in a European context – professionally, economically, politically and socially. Numerous countries, like Russia, Ukraine, and many Eastern European countries, are working with energy and commitment to develop psychotherapy training standards in line with the European Association for Psychotherapy (EAP) standards. To lower minimum training standards here would undermine, isolate and entirely dismantle the gains made and recognition earned internationally for the profession in Ireland and abroad. The EAP was convened in 1991, and the Strasbourg Declaration signed in 1990, to protect the profession from becoming an add-on of other professions, which had already happened in some European countries. To remain outside regulation is unwise in a world increasingly regulated, particularly in the European context, and regulation is one of the aims of the European Common Training Framework (CFT) and European Skills Competencies and Occupations (ESCO). These organisations set professional skill standards that are recognised and facilitate movement across member states. We are in a very good position in Ireland as the Government is going to regulate and protect the titles of the two different professions of psychotherapy and counselling, which has been the position lobbied by ICP.

Divide and conquer
When ICP met with the then Minister for Health, Mr. Leo Varadkar, in December 2016, he indicated to those at the meeting that the Government’s determination to regulate the two professions was a ‘fait accompli’. As psychotherapists we are all stronger together. IAHIP is one of the founding member organisations of ICP and it both contributes and benefits from the association. Over recent years ICP has worked hard and consistently to build a relationship with government ministers, civil servants and CORU that represents a unified, cohesive and standards-based professional body that incorporates ethical values, operates with integrity and holds the well-being of the public as a central tenet. If there is a split now in our position (for versus against regulation) in IAHIP or even ICP, we would make ourselves totally exposed to be regulated without having any influence on the process.

To date, CORU has regulated seven professions, professions that are still represented by professional organisations which did not cease to exist post-regulation.

The function of CORU and the future of the professional associations
The national multi-profession health regulator, CORU, is designed “…to protect the public by promoting high standards of professional conduct, education, training and competence through statutory registration of health and social care professionals” (https://www.coru. ie/en/about_us/what_is_coru). This important step is about ensuring public safety through state regulation which will require practitioners to have achieved certain minimum standards in order to use the title of ‘Psychotherapist’. As a result, it is hoped that the current, unclear usage of the title will cease.

Economically
ICP has been informed by the HSE that once the profession is regulated, the position of psychotherapist will be recognised as a ‘freestanding’ profession, with a separate and commensurate pay-grade, within the organisation. A national register of psychotherapists will raise the status of the profession; recently the issue has been exploited by the Irish media as a non-regulated field. To date, the Revenue will not discuss exemption from VAT or tax redemption for psychotherapeutic treatment.

Psychotherapy and the European Union
Mr. Theo Koutroubas, the general secretary of The European Council for Liberal Professions (CEPLIS), is networking in the European Union on behalf of the European Association of Psychotherapy. Currently, the Working Group in EAP is supporting Mr. Koutroubas in his work on the ‘European Act of Psychotherapy’. EAP promotes statutory regulation as a means of protecting the profession from being hijacked by other professions.

Conclusion
The public need to know that they will be safe, to know that there is consistency in how they are treated and that they will be respected and listened to. The rigorous training standards of IAHIP and the other ICP modalities demonstrate the depth and experience of learning of its psychotherapists.