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Statutory Regulation - Latest UpdatesStatutory Regulation latest update 11 May 2010Statutory Regulation latest update 23 April 2010The notes from the Society's meeting with the Health Professions Council (HPC) on 27 January have now been approved.
Statutory Regulation latest update 14 August 2009Dear ColleaguesI have been asked by the President to issue further guidance regarding the Use of Title following statutory regulation. The guidance below has been developed in conjunction with the HPC, although both they and the Society wish to make it clear that as the designation 'Chartered Psychologist' belongs to the Society then advice around use of the designation is the advice of the Society rather than that of the HPC. I apologise if any of the previous advice on this matter has caused any confusion.
Regards Stephen White Director of Communications The British Psychological Society Further guidance on the 'use of title'Further to the Society's official guidance sent out on 5 August on the 'use of title' following Statutory Regulation many members have asked for more specific examples of what should be used.The basic premise regarding usage is to not mix up titles that now 'belong' to two different organisations, therefore the Society's title is 'Chartered Psychologist', and the HPC titles are the seven domain titles (clinical psychologist, educational psychologist, counselling psychologist, occupational psychologist, forensic psychologist, health psychologist, sport and exercise psychologist) and the two generic titles (registered psychologist, practitioner psychologist). If you are, therefore, both Chartered (by the Society) and registered (with the Health Professions Council) then the titles should look like this: Chartered Psychologist (CPsychol) and Clinical Psychologist and/or Counselling Psychologist and/or Educational Psychologist and/or Health Psychologist and/or Occupational Psychologist and/or Forensic Psychologist and/or Sport and Exercise Psychologist and/or [you may use combinations of the above seven domain titles if you are qualified in more than one area (e.g. Counselling Psychologist and Sport and Exercise Psychologist)]. In addition you may use the two generic titles:
Registered Psychologist, or Practitioner Psychologist. ExamplesFor example, a forensic psychologist who is a Chartered Member of the Society and registered with the HPC and could use any of the following:
In addition to the above you may wish to add a formal job title (e.g. Consultant Clinical Psychologist; or Senior Educational Psychologist) which contains a protected title providing you are on the HPC Register. The HPC has informed us that they will be undertaking work with employers to raise awareness about the regulation of practitioner psychologists, including advising employers about the use of protected titles. If you have any queries about the above guidance above please do not hesitate to contact the Society, and/or the HPC. Statutory Regulation - President's Update - 5 August 2009Use of adjectival titles - clarificationThe Health Professions Council (HPC) have confirmed the legal position that the Society's 'adjectival titles' could only be used by those registered in the relevant domain on the HPC's Register. The HPC will make their own independent decisions based on their procedures concerning the admission of individuals to their Register and thus access to the protected titles.The Society is no longer responsible for registration standards for practice, and therefore it is important that there should be no confusion between the functions and titles of the HPC and the Society. The Trustees and the Chairs of the relevant Society Divisions have agreed that retention of the adjectival titles could encourage confusion on the part of members of the public.
The titles, therefore, no longer perform their original function and the decision stands that 'Chartered Psychologist' (CPsychol) should be the sole title awarded to those with Chartered Membership of the Society, and therefore the title that Society 'Chartered' members should use.
The HPC's advice regarding use of their titles is very clear. HPC Registered Psychologists may use:
Yours sincerely
Sue Gardner
Statutory Regulation - President's Update - 1 July 2009Dear ColleaguesToday, 1 July 2009, is the start of a new era for our Society. The Health Professions Council (HPC) Register of practitioner psychologists has opened. The data on those Chartered Psychologists eligible for automatic entry has been successfully transferred to the HPC who have informed us that they will be writing very shortly to everyone with details about their Register. Getting to where we have arrived has been a very long and highly complex process. The Society started work on gaining statutory regulation back in the early 1980s - there have been many, many individuals involved, both members and staff, to whom I must extend an enormous thank you. This includes those, both members and lay people, who have been involved in our own investigatory and disciplinary processes over many years and who have helped us to achieve the standards we have. It also includes those who have contributed to training, research and applied psychology. Our role now in terms of regulation is to work with the HPC to ensure that it is a success. Alongside this we shall be developing the new learned and professional body that members want and our new Strategic Plan for the next five years has now been agreed.
We have issued a media release today to welcome that fact that the majority of Chartered Psychologists are from today to be regulated by law, by the HPC; and guidance on such matters as the use of Society titles is being updated and will be added to the web.
Yours sincerely
Sue Gardner President Statutory Regulation - President's Update - 12 June 2009The Health Professions Council have taken the Society’s advice and set their threshold entry level the same as the Society, which we have benchmarked at Doctorate level.
We are pleased that the HPC listened to our advice about education entry levels and recognised the Society's expertise in knowing what level of education and training is required before a psychologist is deemed safe to practice independently. This level had been agreed with the largest public sector employers - the health and education services. It is disappointing that the HPC chose not to explicitly mention the Doctorate routes in forensic and health psychology. It is also disappointing that our advice to protect the title 'psychologist' was not taken on board, as this would have been comprehensive and less confusing for the public. The transfer of the data of those Chartered Psychologists automatically eligible for entry onto the HPC Register will go ahead on 1 July and I understand that the HPC will be writing to all those individuals shortly after that date. I will also be writing to all Chartered Psychologists in the first week of July. I would like to thank a number of people who have worked so hard over the past five years, including past presidents Dr Liz Campbell, Professor Pam Maras, Ray Miller and Dr Graham Powell, the Divisions and their trainers, and all the staff. They have given advice and information which proved important in helping the HPC make the decision. We will work closely with the HPC to our mutual benefit. Yours sincerely Sue Gardner
President
Statutory Regulation - President’s Update 22 May 2009Health Professions Council (HPC) - 20 May 2009 - Decisions re Standards of Proficiency, Threshold Entry level and Grandparenting criteriaDear ColleaguesThe HPC Education and Training Committee and Council met on 20 May to decide on the Standards of Proficiency, the Threshold Entry level and Grandparenting criteria for psychologists entering the HPC Register opening on 1 July. The outcome was that decisions were made on two of the three items - the Standards of Proficiency were agreed, with some very minor text changes, as were the Grandparenting criteria but the full decision on the Threshold Entry level was deferred. The Education and Training Committee and Council will meet again on 11 June to make the final decision. What was clear from yesterday's meeting is that the HPC will not agree to the Threshold being at D/level 12, despite the fact that all of the existing qualifications, which lead directly to chartered status are benchmarked at D/level 12 eg the Society’s Stage II qualifications and the professional postgraduate training courses. This, of course, was recognised by the Trustees and by Representative Council when discussions were held in the context of responding to the HPC consultation on the Threshold level, and it was agreed that the Society's corporate response should clearly state that D/level 12 was the only position that could mirror the existing arrangements. The Society has made its views clearly known to the HPC that such a decision appears to be counter to their previous practice of accepting existing entry levels when a new profession comes under regulation. We will have to await the 11 June meeting to find out exactly what entry level has been chosen for future entrants to the HPC Register. However, in the meantime we will attempt to discuss with HPC officers appropriate wording for the Threshold level. We will have to study carefully the potential implications of the decisions, and I will bring you more on the HPC outcomes as soon as I have them. Yours sincerely Sue Gardner President Statutory Regulation - President’s Update 5 May 2009Health Care and Associated Professions (Miscellaneous Amendments and Practitioner Psychologists) Order 2009Dear Colleagues Some time ago you were kind enough to meet colleagues concerning the Statutory Regulation of Psychologists and that is why I am writing to you now. The above Statutory Instrument will enable the Health Professions Council (HPC) to regulate 'practitioner psychologists' and when it was debated in the other place on 31 March 2009 the Minister of State, Ben Bradshaw MP, made two statements, which we feel should not stand without comment or uncorrected. We are therefore hoping that you might be able to raise these points in the debate that you are due to have on the Statutory Instrument on 5 May 2009. The first point refers to the Threshold Entry level to the profession, which the HPC have consulted upon, and which the HPC are due to consider and decide upon at their meeting on 20 May 2009. The Minister of State said: 'The BPS has long argued that the profession should be limited to those with doctorates. That is not accepted by our Department. Now, the HPC should determine the appropriate level of qualification for entry into the profession.' Indeed the Society has long argued that the Threshold Entry level for safe and effective practice is at ‘D’ level/level 12 because that is the level at which all the existing qualifications and training is set for all existing Chartered Psychologists (i.e. those that the Society deems fit to practice). Indeed this level has been, and is, approved by employers in both the Health and Education services. So, it is not a matter of '…should be limited…' it is a matter that it is limited to those with doctorate level/level 12 qualifications and training. This statement by the Minister also appears to contradict assurances this Society was given by his Department that quality standards would not be lowered by the transition from our voluntary register to the statutory one. If the Threshold Entry level is lowered from D/12 level to something less then obviously quality, standards will fall. We are also surprised by the Minister's statement as it would appear to be attempting to influence a decision that the independent HPC has not yet made. The Minister has given a very clear political steer to an organisation, which is meant to be independent of Government. Our second point refers to the matter raised in the debate on 31 March 2009 by the Honourable Member for Guildford, Anne Milton and the answer given by the Minister of State. Ms Milton said: 'There is concern about the 2,000-odd Chartered Psychologists, whom I understand will not be deemed to be safe to practise by the HPC, because the legislation, as drafted, will not allow automatic entry to its register. They will therefore have to go through potentially costly grandparenting scrutiny with the HPC. I quote from a letter that I received from the British Psychological Society: 'The effect of this exclusion is that these individuals may be disbarred from professional practice using one of the proposed protected titles—a restraint of trade issue - and they may potentially have to pay an extra fee to the HPC to be assessed to gain entry to the Register via one of the grand parenting routes.' The Society considers that 'the Department of Health have taken a narrow view to only recognise and therefore regulate those of our Chartered Psychologists who are members of one of our seven professional Divisions, whilst we have argued that many of the "excluded 2,000" work in areas that cross professional boundaries or in specialist subsets of professional practice, but who are nonetheless safe and independent practitioners.' It argues 'that the proposed Statutory Instrument would not achieve its purpose of fully protecting the public from the full range of existing qualified practitioner psychologists; it may disbar existing Chartered Psychologists from future employment; and it may force some 2,000 existing Chartered Psychologists to go through potentially costly…scrutiny'. In reply the Minister of State said: 'The hon. Lady asked about Chartered Psychologists. We are aware that a number of them have been issued with practising certificates by the BPS but are not entitled to be full members of one of the seven divisions of the society, whose members will automatically transfer to the HPC register. It is not clear whether the psychologists will all need to be registered. Our view is that if the BPS is unable to allow those people to use the titles associated with full membership in its divisions, it is difficult to justify giving them an automatic right to do so without further consideration by the HPC. The fact is that the proper title on the existing voluntary register is ‘Chartered Psychologist’, not ‘Chartered something Psychologist’ as is implied by the Minister's reply. The various adjectival titles that the Department of Health have chosen as the protected titles actually refer to membership of various Society Divisions, and not if the individual has been deemed fit to practice safely and independently. These extra titles were introduced by the Society as an aid to the public to enable them to more easily identify appropriate practitioners. I must re-emphasise the point made by the Honourable Member for Guildford; the Statutory Instrument as drafted will exclude some 2,000 suitably qualified Chartered Psychologists who this Society has over many years deemed fit to practice. This exclusion will therefore leave the public unprotected from this large number of independent practitioners and therefore this SI is in our view flawed. I hope that the two points I have covered above are clear and that they will be able to be made in your debate on 5 May 2009. If you have any queries or need any clarification please do not hesitate to contact me. Yours sincerely
Statutory Regulation - President's Update 8 April 2009Dear Colleagues
First, I should introduce myself, I am Sue Gardner and I took over from Liz Campbell as President at the Society's AGM held last week at a very successful Annual Conference. For my first update please find below the full transcript of the debate in the Delegated Legislation Committee, House of Commons, 31 March 2009, regarding the s60 'Health Care and Associated Professions (Miscellaneous Amendments and Practitioner Psychologists) Order 2009'. The outcome is that the Committee agreed the legislation. The same s60 was also discussed and agreed by the relevant Committee in the Scottish Parliament on Wednesday 1 April. There remain some further formal hurdles that have to be gone through, but it now appears that the scheduled start date for the HPC opening of the 'psychologists' register on 1 July 2009 is on course. I will bring you further information as soon as it is available. Yours sincerely Sue Gardner President
Update 26 March 09: Brief summary on the Health Professions Council (HPC) response to their public consultations on (1) Standards of Proficiency (SoP) and (2) Threshold entry levelStandards of Proficiency (SoP)Introduction: The HPC acknowledged our concerns about how the HPC define and describe who they are, but make no comment on it. This will come up again when they consult on the Generic SoP so the Society can raise it again at that time. They have adopted our terminology of ‘domains’ rather than ‘disciplines’ which is helpful.
Generic SoP: They have acknowledged the comments received and commit to including them in the 2009 review of the Generic SoP. They also committed to adding a statement about the role of the ‘generic standards’ to the introduction and state that the standards will be applied by members of the profession in a way which is specific to the profession. This is not quite the commitment we asked for (that if a Generic SoP was not relevant to psychology it would not be applied by HPC in either course approvals or individual conduct cases) but is a reasonable compromise. English language requirements: This was an area that the Society was very concerned about. The summary of responses is fair. A number supported our position that the minimum should be IELTS 8 with no element below 7.5. Supporters include the Department of Health, BACP, NHS Lanarkshire, and NHS Education for Scotland, and for some domains, the Scottish Government. The British Association of Arts Therapists supported a lower level (7.5 with nothing below 7) arguing that in their experience 7 was a sufficient level of competence and that this was about threshold levels. The Polish Psychologists Club supported the lower level used by HPC for most of their professions arguing that the higher level could prevent psychologists from being able to register and therefore threaten service provision to non English speaking communities.. The summary is fair as are the HPC comment.
Regulation: There were many responses about HPC as the regulator, which they have included, but they point out that this issue was not part of this consultation. Scope of practice: The Society received the reassurance we sought that individuals transferring over from our register will not have to demonstrate SoP, which are outside of their scope of practice, so long as they continue to meet all those that are within their scope of practice. On the SoP themselves: There do not appear to be any major concerns with the psychology standards (both profession specific and domain specific) which HPC put out for consultation as we were quite closely involved in their drafting. There have been some changes in light of consultation responses, and a lot of these seem to be based on our response. They haven’t made all the changes our response suggested, but the compromise seems fair. In a number of cases other respondents (AHPD & UEA for example) have echoed exactly what we said, which has added to the strength of our position. BACP have consistently suggested adding standards, or making some domain specific standards from clinical or counselling psychology generic to all psychologists. The British Association for Arts Therapists have consistently suggested that the standards are too detailed to be at the threshold level and that a number of the profession/domain specific standards should be removed because, in their opinion, they are at a level above that which would be expected of a new practitioner. In summary the HPC response to this consultation is a fair job of weighing up the responses and they have included a number of our suggested amendments to the profession/domain specific standards, and have given sensible reasons where they have chosen not to do this. Threshold Entry LevelIntroduction: the HPC paper on the SET 1 (that is, the threshold entry level for the register) sets out the possible threshold levels identified in their consultation paper, with a summary of the responses in relation to each.
Doctorate for the whole part of the Register: The paper refers to responses from the Society and the Association of Heads of Psychology Departments (AHPD) as arguing that all domains reach D Level/level 12 even though the form of the award can vary across domains. Arguments advanced in favour of this threshold included not lowering the current standard; that there was no difference in competence levels or academic standards between domains; and, that doctorates already exist as the entry route for a number of domains. Arguments against included that a doctorate was not necessary for public protection; concerns about the impact on the supply of psychology graduates to the profession; and, implications for internationally qualified psychologists. It’s fair to report that there was a fair amount of opposition to setting the threshold at ‘Doctorate’ for all domains. The British Association of Arts Therapists, the Scottish Government (Health Directorates) and Neuropsychologists UK all suggested the level should be below ‘Doctorate’. Different thresholds for different domains of psychology: The paper stated that a number of respondents argued that the threshold level should be set specific to each domain; although it also states that the Society argues that the current level is D level/level 12 across the UK for all domains. The paper suggests that setting domain specific threshold levels would be a departure from normal HPC practice. Arguments in favour included that not all domains currently require Doctorates and that it was not possible to set one threshold level for all domains. The Department of Health said they had a strong preference for a threshold to be set for the whole part of the register and, whilst not specifying their preferred standard, clearly seemed to be leaning to something below Doctorate. Quite a lot of responses have argued for having different threshold levels for different domains, based mainly on the different qualifications routes which currently exist. Masters degree, or equivalent, with further training or experience as appropriate: Some respondents argued that the Doctorate threshold is not necessary for safe and effective practice. HPC also make the point that specifying a threshold level without reference to the name of an award which leads directly to registration is problematic. The paper mentions the option of having the threshold set for some or all domains at ‘M level +’, ie with further training/experience. Summary: the paper is a balanced representation of the views of the respondents. It does not recommend a specific threshold level. This decision would emerge from the discussion of the Education and Training Committee. This briefing on both HPC responses drafted by Helen Clark, The Society’s Qualifications Manager
HPC Education and Training Committee, Wed 25 March 2009The issues above were discussed at the Health P
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