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Dear Mr Miller

We are responding to your e-mail dated 17 August, 2006, seeking comment from each subsystem on the British Psychological Society’s draft response to the ‘Healthcare Professional Regulation: public consultation on proposals for change’ and proposals for a Psychological Professions Council (PPC) to regulate the professions of psychology, counselling and psychotherapy.

The SGCP welcomes the opportunity to contribute to the consultation process on the regulation of the profession of applied psychology and we continue to support the principle of the regulation of applied psychologists.

In particular, we wish to confirm our support for the Society’s current position that psychological professions should be regulated by a regulator separate from the governments preferred route of a Health Professionals Council (HPC). One of the major limitations of the HPC is that it does not adequately account for the professional requirements of psychologists or understand the employment contexts in which they work. We would agree with the Society that the proposed PPC would meet these important aims.

The proposal for the establishment of a PPC as a single specialist and independent regulator of practitioners from the psychological professions has been the result of the Society undertaking a comprehensive exploration of a range of alternatives to the HPC. We believe, therefore, that the PPC option offers a more appropriate and effective system for the statutory regulation of psychologists than the proposed HPC, which is limited in the extent that it will actually instil public confidence, enhance public awareness and ensure public protection. We would support the view that there is no evidence that the HPC would more effectively meet the aims of protecting the public or engendering public confidence than the proposed PPC. Indeed, our view is that in principle the PPC would offer a more viable solution.

We also support the view that the proposed PPC sufficiently meets the five key principles set out in the Foster Review (The Regulation of the non-medical healthcare professions - a review by the Department of Health, 2006) as pre-requisites for systems of statutory regulation. By setting appropriate standards of proficiency, training and codes of conduct requirements the PPC would be able to effectively set and maintain the standards of knowledge and competence of the psychological professions. Thus the PPC would be ‘fit for purpose’ in respect of the statutory regulation of psychologists and would, therefore, meet and develop upon the aims and principles outlined in the Foster Review and Donaldson report.

To reiterate upon important points made in our previous letter to the President on the ‘Statutory Regulation - SGCP Response to the Public Consultation Document (29 April, 2005), the SGCP believe that protection of the title ‘Psychologist’ would more effectively protect the public, reduce the risk of misuse and public confusion than the HPC proposal to protect adjective titles. We are, therefore, in support of the proposals made regarding the establishment of a PPC relating to the protection of titles (sections 2.13, 2.14 and 2.15). In addition, our view is that the HPC should not set the standards for grand-parenting and the proposals outlined for the PPC would more effectively meet this function in relation to the professional requirements of psychologists.

We also specifically wish to respond to the general issues (1 and 4) outlined within the Society’s response and further outline our concern.

Issue 1: The SGCP has a large crosssubsystem membership and as the Foster Review and Donaldson Report are based on a National Health Service perspective, this excludes the activities of many coaching psychologists who are self-employed or employed within the public and or private sector working within a variety of employment contexts, often external to healthrelated settings.

Issue 4: The proposal that revalidation (via Continued Professional Development) would be based on annual performance management review processes carried out by employers is not fit for purpose with many coaching psychologists operating in private practice.

Further to this we are in support of the Society’s recommendations and proposals regarding themes 1 to 10 within the Donaldson Review and Foster Review.

Finally, the SGCP would like to acknowledge that Mike Carpenter and the Society Office have done an excellent job to date in supporting and representing the needs and views of Society members.

On behalf of the Special Group in Coaching Psychology

Yours sincerely,

Pauline Willis
SGCP Chair.


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