10th October 2022
Imagine you decide to see a UK psychotherapist or counsellor privately and something goes wrong. Perhaps they are sexually or financially exploitive or they fuel an unhealthy dependency. You decided to make a complaint. I imagine you would hope that there was an organisation you could turn to who would take your complaint seriously, treat both sides fairly and act quickly (if needed) to keep other people safe. In the UK, psychotherapists and counsellors are not regulated by law. In fact anyone can set up in business as a therapist without: training, qualifications, insurance, DBS check or any of the qualities likely to be needed to help people. However, most therapists belong to one of eleven professional bodies, signed up to a voluntary scheme run by the Professional Standards Authority (PSA). The PSA has a minimum set of criteria which must be met for an organisation to gain and maintain accreditation. The scheme aims to improve the safety and effectiveness of UK therapy. It is a good idea to choose a therapist who is on one of these registers, otherwise you may have almost no protection if something goes wrong. You can find out if a therapist is on an Accredited Register (AR) here: https://www.professionalstandards.org.uk/check-practitioners In an ideal world, all ARs would work to the same high standard with respect to complaints handling regarding therapists' conduct. However, evidence suggests this is not the case. When evaluating prospective therapists, it is worth bearing this in mind, especially given the worrying lack of an independent appeals process if you are unhappy with an AR’s decision. The PSA’s powers to intervene in complaints decisions by ARs are limited. The only step they can take, is to incorporate concerns about complaints management into their periodic assessments of registers. At that point they can suspend accreditation or impose sanctions, if the AR has failed to meet specified standards.
The PSA is very approachable and encourages anyone to contact them if they have concerns about the way an AR has handled a complaint
(firstname.lastname@example.org). Following concerns that the lack of regulation of UK psychotherapy and counselling was putting people at risk of harm, exploitation and abuse, Phil Dore set up the Unsafe Spaces website over a decade ago to highlight these issues. Little appears to have changed in the interim. An area they explored, was how well ARs were handling complaints. One way Unsafe Spaces looked into this (2016), was to compare the number of concerns received by the PSA regarding alleged complaints mishandling, for each AR. The premise being that if some ARs generated more concerns than others (after accounting for AR size) it would suggest shortcomings in their complaints procedures. The article can be viewed here: https://notsobigsociety.wordpress.com/2016/10/02/are-some-accredited-registers-better-than-others-at-handling-complaints/ The report found that UKCP had more than three times the number of complaints when compared to BACP, after accounting for AR size. From November 2015 to January 2016 the UKCP also had its accreditation suspended by the PSA, for not meeting minimum standards, partly because of the apparent mishandling of a sexual misconduct case. Phil Dore ended Unsafe Spaces in 2017. We thought it was important to update this work to see if anything had changed. Using data from 2016-2021, obtained via a Freedom of Information (FOI) request to the PSA, we explored the current evidence that some ARs are potentially mishandling complaints more than others. Table 1 shows the number of concerns that the PSA received each year regarding ARs complaints handling.
ARs vary greatly in size. The smallest is the UK Association of Humanistic Psychology Practitioners (AHPP) which has fewer than 200 members. The largest is the British Association for Counselling & Psychotherapy (BACP) with over 40,000 members. Numbers also vary by year. To make a fair comparison we accounted for annual AR size. This information is shown in Table 2.
To help interpret the data fairly, we generated rates for each AR, by dividing the total number of complaints received over the whole six years, by the sum of the number of therapists registered with each organisation each year. This rate of complaints per therapist per registered year was then multiplied up to give the number of complaints per 10,000 therapist-years for each AR. This allowed us to report whole numbers for ease of comparison.
So imagine there were 10,000 therapists from each AR who were followed for one year. The number of complaints about each AR (based on extrapolating the data provided by the PSA) would be as shown in Table 3 (*rate column).
The rows in light grey in Table 3 are small ARs. Data on these registers should be viewed with caution, due to the limited follow-up. Minor fluctuations in the number of concerns raised, could have a big impact on apparent rates and lead us to draw the wrong conclusions about their complaints handling processes. The largest ARs in order of size are: BACP, UKCP, NCS and BPC.
UKCP is less than a quarter of the size of BACP.
However, it had a larger absolute number of concerns raised (31 vs. 22) and a rate of 6.5 (4.2-8.9) complaints/10k therapist(person)-years (py). That is 6 times the rate of BACP and >20 times that of NCS! There was a lack of statistical evidence NCS's rate of 0.3 (95%CI, 0.02-1.5) complaints/10k py differed from that of BACP 1.1 (0.7-1.6) complaints/10k py. There was however, strong statistical evidence the rate for UKCP was higher than that of NCS and BACP (p<0.0001). BCP had an intermediate rate of 4.1 (1.1-10.5) complaints/10k py, but no strong statistical evidence that their rate differed from NCS, BACP or even UKCP. The Association of Christian Counsellors and Counselling & Psychotherapy in Scotland (COSCA) had no recorded concerns with the PSA regarding their complaints handling. Although these are small organisations, this is encouraging. There was a great deal of uncertainty about the true rates for the other smaller ARs including the Association of Child Psychotherapists and the Human Givens Institute. The Association for Humanistic Psychology Practitioners (AHPP) data suggested it had a much higher rate of complaints than other ARs. However, robust conclusion cannot be draw about AHPP; the removal of a couple of complaints would have a big impact on the apparent rate and three-quarters of its complaints occurred in the year it became accredited. Our results are similar to those of the Unsafe Space (2016) report, although we now have many more years of follow-up. This strengthens the evidence base for our findings and highlights their enduring nature. UKCP had many more complaints made about it to the PSA regarding the potential mishandling of concerns regarding therapists' conduct, than BACP or NCS, after accounting for AR size.
Other work by Unsafe Spaces found that ~75% of UKCP therapists and ~22% of BACP therapists struck off their registers (often for gross professional misconduct) continued to practice.
Nearly a third of people in the UK have ever undertaken psychotherapy or counselling. This proportion is growing every year. Therefore, the lack of effective regulation of UK therapy appears to be a substantial and growing risk to public health.