Response to SCoPEd

Dear BACP

Please find below our feedback on the 2nd iteration of SCoPEd, as a registered organisation with the BACP.
This feedback has been shared and agreed by the counsellor members of our CIC. We offer this feedback to you in good faith in order to support and protect the future of our profession.
We would ask that you confirm receipt of this feedback so we can communicate this to our counsellors.
Kind regards
The Board of Directors of HCCG CIC & the Counselling Team
Principal observations of the 2nd iteration of SCoPEd – Horsham and Crawley Counselling Group CIC 
As a stakeholder organisation registered with the BACP, we acknowledge the good intention behind SCoPEd.  We share the view that a review of standards around training courses and competencies within the profession are clearly in need of an overhaul.
We recognise the fundamental long standing tensions between different bodies of theory, therapy modalities, professional bodies and training, and the great difficulty in trying to reach common ground. We acknowledge and thank those who undertook the huge amount of work involved in this process.
However, we’re aware of how divisive this iteration has already become and share the frustration that individual members have expressed regarding the BACP’s reluctance to engage in direct debate.  We await the BACP’s response.  It would appear removing the titles from the columns has done little to abate the idea that counsellors remain at the bottom of the therapy ‘food chain’.
We understand it was to await members’ questionnaire responses, but given there is now disappointment about the level of response to the iteration it might have been more helpful to have come forward and given more prominence to the debate.
We found the processes used to engage with individual members and registered organisations to have been very fragmented.  This made it harder for us as an organisation to encourage our counsellors as individual members to add their views.
The BACP constitutes the largest membership body within this process – therefore our members’ views should carry a consequential amount of weight.  Refusing to debate with members or describing their genuine questions or concerns as ‘myths’ seems to have done little to help this process move forward.
As an organisation, we are troubled by what the public, be it current or future clients, might make of the way this debate is being handled by us as a profession.  It concerns us greatly that the views and voices of clients seem silent in this iteration – given it is in their interests that this is being carried out.
Our specific concerns:
We believe this iteration creates an unhelpful and complex conflation, between the idea of a professional register, that the public may consult in order to determine if someone is qualified and accreditation, (currently a voluntary process only undertaken by BACP members in order to demonstrate higher levels of training).
In our view, it would have been more helpful to have considered them as two separate issues, each needing clarity, but for different reasons.
Points of admission to both the PSA Register and the BACP accreditation process, as currently constructed, contain inconsistencies that in our view, warranted separate and careful consideration.
PSA register – purpose
We believe that this iteration may be at odds with our current understanding of the purpose of the Professional Register, as defined by them, namely:
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We note that SCoPEd is currently a tiered iteration and sets out with the intent to demonstrate quality of practice.  We would welcome the opportunity to understand BACP’s view on the reasoning behind aligning registration and accreditation.
We note that the BACP’s own re-accreditation to the PSA Register was delayed by some 5 months, without any explanation from either the BACP or the PSA to the membership, as far as we can establish.
Whilst recognising the pandemic clearly had some part to play, this was concerning to both the membership and registered organisations.
We note now the findings of the PSA in relation to BACP’s re-accreditation to the Register. In particular, their requirement that the BACP examine the barriers to entry to the profession, created by the iteration’s requirement for further voluntary, i.e. unpaid work, by fully qualified registrants.
Timings:
It felt a particularly unhelpful time to ask professional members and organisations to consider a detailed and complex iteration, when we were already dealing with maintaining ourselves in the face of a pandemic, both professionally and personally, whilst still supporting our clients and our own counsellors.  We wonder if it might have been possible to delay it.
Stakeholder organisations:
We were most concerned, that as a registered stakeholder organisation, it seemed our views and feedback were not being sought by the BACP, nor were we given any indication how or when our views would be collated, until we asked the direct question.  As a long standing registered organisation we were deeply disappointed by this.
Students:
As a student incubator, we’ve heard the student population’s confusion and distress.  In particular how SCoPEd may affect their current training course or any possible training they may embark on.  There seems to be considerable confusion about the status of particular training courses and the iteration.
Clients:
We would like to understand how clients’ views were built into this iteration.
Supervision
We await more detailed information on how supervision will operate for the different tiers.  We need to understand the potential impact on us, as an organisation, that currently runs many supervision groups.
Inclusivity and Diversity
There is a strong emphasis in this iteration on academic training and further CPD as the gateway routes to moving up the tiers.  This caused us to wonder how the diversity and inclusivity of our profession can be maintained.
The potential closing off of entry routes into the profession for groups underrepresented in our profession, due to the financial costs or the need for academic ability, on top of the requirement to do more unpaid voluntary work, (simply in order to meet tier requirements), seems to us a retrograde step and a move away from a non-linear model which has always been valued by us as a profession in the past.
Little weight seems to have been given to life experience, independent learning or previous careers.  The iteration seems founded on the idea that only academic learning with higher levels of qualification or specific CPD are the only routes by which the evaluation of a counsellor’s abilities can be gauged.  This will disenfranchise some of the most experienced counsellors within our profession, who may have chosen not to become accredited or for whom post graduate qualification was not possible.
We would like to see far more information on post gateway entry points, as a priority for all those counsellors already registered BACP members with significant experience, who will remain stranded at particular tier levels unless they undertake further academic courses.