PCSR response to SCoPEd

Psychotherapists and Counsellors for Social Responsibility (www.pcsr.org.uk) are opposed to the SCoPEd project.

1. Many BACP members have not received the draft SCoPEd consultation. On this basis alone responses will be unrepresentative.
2. The BACP treats its members with suspicion, believing that therapists are inherently a potential threat to clients and the public.
3. The competence frameworks were developed using Anthony Roth and Stephen Pilling’s methodology designed for manualised IAPT work. It is not appropriate or sufficient for the relational, dialogical encounter that typifies the practice of most therapists, and does not represent the core values of therapy.
4. Attempting to align training to competency frameworks undermines training by prioritising means over ends. Standardisation entails a shift from education to compliance.
5. The Expert Reference Group (ERG) is made up of 14 practitioners, only two of whom are explicitly humanistic. Eight are explicitly psychoanalytic. The Chair is a psychoanalysist and co-author with Roth and Pilling of their paper on psychodynamic therapies.
6. A generation of work evidencing the equal value of training, experience and work of counsellors as being equal to that of psychotherapists has been casually swept aside.
7. Embedding a hierarchy of therapists does not protect clients: an ‘Advanced’ counsellor may be much less experienced and skilful than a ‘Qualified’ counsellor who has not completed an expensive, time-consuming assessment. Both may be wiser, more experienced, better trained, have more insight and be more effective than a ‘Psychotherapist.’
8. Once more, the BACP mistake the understanding of the word ‘voluntary.’ ‘Advanced’ status – like the current ‘Accredited’ and ‘Senior Accredited’ statuses – are presented as voluntary assessments, but are essentially marketing tools. It is entirely reasonable for clients to seek the most skilful, qualified practitioners and the proposed scheme, like accreditation, misleads clients and applies unreasonable pressure onto therapists to pay professional bodies for unnecessary assessment.
9. The constant drive towards normalisation, standardisation and competition will not improve opportunities for employment for therapists. Our professional bodies continue to distort the fundamental core of our professions in an attempt to conform to political changes, while ignoring the professions’ deeply embedded structural problems around who may access therapy training and practice.
10. The desire to seek equal status with prestige professions by over-valuing and imitating the language, methods and culture of those professions denies, distorts and distracts from the fundamental value of the individual, therapeutic relationship without which all other ‘competencies’ are meaningless.PCSR values the individuality of clients, therapists and professional body staff, whether we agree with them or not. We believe this to be more important than ever at a time when tribalism and marginalising has become routine.
We respect and understand the desire of all involved in SCoPEd to ensure that clients are offered the highest quality therapy and to increase employment opportunities for members. We believe that this can only be sustainably achieved by constantly returning to the fundamental philosophical foundations of our professions, which must be rooted in trust in and respect for the members of each professional body; and in values that are not altered by political or economic vagaries, or the desire for acceptance, influence or dominance.


No therapists on National Advisory Panel for LGBT Health

Sent to BACP, UKCP, BPC, BABCP, BPS Pink Therapy, COSRT and NCS

21 March 2019


We welcome the announcement that Dr Michael Brady has been appointed as the first National Adviser for LGBT+ Health, and that an Advisory Panel has also been appointed to focus on key issues for people who are LGBT+ “such as conversion therapy.” 1

There are no therapists on the Advisory Panel, a particularly striking omission for a group with an explicit focus on conversion therapy.

The Memorandum of Understanding on Conversion Therapy in the UK is an important document that represents many years of therapist engagement with this subject. We recognise our professional bodies’ commitment to this vital issue.

We urge the BACP, BABCP, BPC, BPS, COSRT, NCS, Pink Therapy and UKCP to join us in urgently contacting Penny Mordaunt, Minister for Women and Equalities, to ask why therapists have not been invited to join the panel.


Bea Millar

Chair, Psychotherapists and Counsellors for Social Responsibility




Correspondence with Penny Mordaunt MP re Advisory Panel on LGBT Health

2nd letter from PCSR to Equalities Office

Rt Hon Penny Mordaunt MP, Minister for Women and Equalities,

Government Equalities Office,1 Sanctuary Buildings, 20 Great Smith Street SW1P 3BT

1st May 2019

Dear Minister,

LGBT Advisory Panel

Thank you for your letter of 18 April 2019 in response to our letter of 21 March.

We are not asking for reassurance. We are requesting urgent information on the reasoning behind excluding therapists from the Advisory Panel. We are advising the National Advisor, the Advisory Panel and the government, through your office, to immediately bring therapist knowledge and skill to the Advisory Panel.

Your colleague, Geraint Davies MP, has over two years proposed two bills to end conversion ‘therapy’. His concern for LGBT+ people and for the ethical practice of counselling and psychotherapy are not in question, yet both bills demonstrate a profound confusion of the issues around State regulation, protected titles, professional standards and even the practice of counselling and psychotherapy.

We do not believe that you would create an Advisory Panel to focus on issues specific to surgery or the automotive industry without involving a single surgeon or automotive industry executive. To create an Advisory Panel “which will focus on key issues such as conversion therapy,” that does not contain a single therapist strongly suggests that you do not hold counsellors, psychotherapists or indeed LGBT+ people in high esteem.

Please feel free to contact us for a full briefing on this complex and delicate matter.


Bea Millar


Response from Government Equalities Office to our first letter (see below)

Our reference GEO-01519

18 April 2019

Dear Ms Miller,

Thank you for your letter of 21 March regarding the advisory panel and conversion therapy.  I am responding on behalf of the Minister for Women and Equalities.

We would like to thank you for your support on this issue, and the work you are already doing to tackle conversion therapy by signing the MoU.

In the LGBT Action Plan we committed to exploring both legislative and non-legislative issues to prevent conducting, offering or promoting conversion therapy activities.  In particular we are concerned with these issue (sic) in three areas: medical, faith and cultural, and commercial contexts.

We are committed to this work, and GEO officials are proactively working on it now.  Our current focus is on getting better evidence about where these practices are taking place, what they are, and how they can most effectively be stopped.

We are engaging with faith groups, healthcare stakeholder groups, and others to ensure that our proposals are proportionate, targeted and effective.  We have also commissioned qualitative research into the experiences of those who have undergone conversion therapy.  This research looks at the impact on individuals and how they think we should end its practice.

The evidence we have gathered to date suggests the practice of conversion therapy is not limited to the medical profession.  Additionally, whilst there has been much discussion of counselling and psychotherapy within the wider debate on this issue, we have limited evidence that this should be an area of particular focus in our response.  Our work suggests there are much larger challenges with regards to cultural and faith-based practices which deserve thorough consideration; 51% of respondents who had undergone conversion therapy said that it had been conducted by faith groups.

We are proud that our robust recruitment process for the LGBT Advisory Panel has led to a diverse Panel in terms of expertise and demography.  The members of the panel were appointed based on their extensive knowledge and understanding of the experiences of LGBT+ people, developed over multiple years. The Panel will also be able to draw on extensive expertise as the need arises, and so will be able to bring in an even greater diversity of voices during the course of their work.

I hope this information is reassuring.  Thank  you again for writing to us on this important issue.

Yours sincerely

pp    P.Mordaunt

Government Equalities Office


1st letter from PCSR to Hon Penny Mordaunt MP,  Minister for Women and Equalities

Government Equalities Office, 16-20 Great Smith Street,  SW1P 3BT

21 March 2019

Dear Minister

We welcome the appointment of a National Adviser for LGBT Health in the NHS, and the creation of an Advisory Panel that will “focus on key issues such as conversion therapy…” 1

Conversion therapy has been a particular concern for counsellors and psychotherapists for many years. The ‘Memorandum of Understanding on Conversion Therapy in the UK’ emerged from 10 years of debate informed by LGBT+ people and groups, engaging 11 therapy bodies, the NHS, the Royal College of GP’s, The Association of LGBT Doctors and Dentists, and supported by Stonewall. 2

We are therefore astonished and alarmed that there are no therapists on the Advisory Panel, a particularly striking omission for a group with an explicit focus on conversion therapy.

We request urgent information on the reasoning behind excluding therapists from the Advisory Panel. 

We strongly urge the National Advisor, the Advisory Panel and the government to immediately bring therapist knowledge and skill to the Panel. 

The exclusion of therapists from a group that has been created to ‘focus on key issues such as conversion therapy’ leaves the Advisory Panel open to accusations of ignorance of the significance of therapy for LGBT Health, and of gullibility. The setting up of Advisory Panels is an established way for powerful groups to enact a pretence of interest and concern.


Bea Millar,

Chair, Psychotherapists and Counsellors for Social Responsibility       www.pcsr.org.uk