Summary

The Association of Clinical Psychologists UK (ACP-UK) had a significant meeting with the CEO (John Barwick) and the Director of Fitness to Practise (Laura Coffey) of HCPC on 12th November. ACP-UK was represented by the Director for External Relations (Che Rosebert), the England Co-Directors (Sarah Swan and Tori Snell) and the Chair (Mike Wang). The meeting was the most recent engagement between ACP-UK and HCPC: we have met with the HCPC on numerous occasions over the past three years to discuss concerns we have about its responsibility towards our profession, our members, and the public. Prior to this most recent meeting, and despite assurances, little progress had been made in changing HCPC’s approach.

I am pleased to report that the meeting on 12th November was constructive and the HCPC undertook to address ACP-UK’s concerns with substantive actions, as detailed below.

ACPC-UK’s concerns relate to:

1. Poor oversight and quality assurance of international qualifications for clinical psychology
2. Failure to communicate (new email only reminders) resulting in lapsed registrations
3. Inconsistent practice in relation to civil disobedience/climate change offences
4. Appointment of non-Clinical Psychologists to Clinical Psychologist panel hearings
5. Poor administrative procedures and form relating to return to practise following illness

1. Poor oversight and quality assurance of international qualifications for clinical psychology

Background

ACP-UK is concerned that the high standard of UK clinical training is not being expected of overseas applicants seeking to use the title of Clinical Psychologist and that the HCPC is not acting proportionately, consistently, transparently or in a way that is accountable when conferring the title. We are aware many of our overseas colleagues who have been conferred the Clinical Psychologist title here in the UK have done so in the correct way and that their credentials are robust.

However, we have numerous examples of overseas applicants who have been given the registered authority to hold the Clinical Psychologist title when, as evidenced by their qualifications, it remains questionable how the title could have been conferred at all.

Meanwhile, the BPS has examples of very well-qualified overseas applicants with doctoral qualifications in clinical psychology who are inexplicably delayed in receiving registration.

Furthermore, we have numerous examples of the HCPC having granted multiple protected psychology titles to overseas applicants. In some cases, this has happened despite the person only holding a masters in one psychology discipline. It begs the question: How is it possible for a masters level psychology graduate to be granted the titles of Clinical and Counselling and advertise themselves as both let alone, in some examples we have, hold a third title e.g. Educational Psychologist, and advertise themselves as all three?

Such poor practice undermines the HCPC’s reputation and the status of UK qualifications in applied psychology. It undermines our profession.  It undermines overseas colleagues who hold qualifications equivalent to their UK counterparts. It puts the public at risk.

The HCPC relies on Practitioner Psychologist registrants to review the qualifications and CVs of applicants. Based on the evidence we hold it is apparent that those responsible for doing so are not appropriately trained and/or the HCPC does not offer appropriate guidance for them.

ACP-UK Solution

ACP-UK has offered to assist the HCPC with drawing up appropriate guidance for people who are responsible for assessing and agreeing who can be conferred the protected title of Clinical Psychologist and to assist with training.

HCPC Response

The HCPC has initiated a major review of its overseas applicant approval processes and has invited ACP-UK representatives to participate. The HCPC’s Head of Education, Brendon Edmonds, will be leading this review.

2. Failure to communicate email only reminders resulting in lapsed registrations

Background

The HCPC recently changed its method of reminding registrants that their registration will soon lapse, from a postal letter to email only. This was done without warning or consultation. For many registrants, email addresses are not a reliable means of communication, for a variety of reasons. A significant number of Clinical Psychologists did not know their registration had lapsed, which demonstrates that imminent lapse warnings had not been effectively communicated and that this was not solely the fault of the registrants.

Recent cases of lapsed registrations have led to significant sanctions, including registrants being disciplined by their employers and by the HCPC. Many have been demoted with reduced remuneration.

We are aware from our members that HCPC staff are providing advice to NHS employers about pay grades following lapsed registration. For the avoidance of any doubt, we find this practice outrageous and illegitimate.

ACP-UK Solution

We made it clear at the meeting that HCPC must instruct its staff to desist from the unacceptable practice of making any such recommendations, which are completely outwith their remit. ACP-UK also suggested that HCPC write to employers to explain that registrants had not been provided with the hitherto usual postal reminder and this might have contributed to any elapsed registrations.

HCPC Response

The HCPC CEO agreed to instruct those HCPC employees providing this “advice” to cease doing so.

The HCPC CEO undertook that when registrants fail to respond to email correspondence such as imminent registration lapse reminders, they will follow up with postal communication.

3. The handling of civil disobedience/climate change offences

Background

Given the climate emergency, our members are exercising and will continue to exercise their right to peaceful demonstration. Some have been and some intend to commit acts of (non-violent) civil disobedience during public demonstrations, such as those organised by Extinction Rebellion (XR), where the motivation is for the public good, rather than self-interest. The ACP-UK successfully supported one of our members recently whose case inexplicably went to a full tribunal hearing.

The GMC and the NMC have sensibly developed processes that dismiss uncomplicated civil disobedience cases at an early stage.

Whilst ACP-UK understands that the HCPC Fitness to Practise process is different to those of the GMC and NMC, we are concerned that the ambiguous and inconsistent position of HCPC serves to deter registrants from exercising their right to peaceful demonstration.

ACP-UK Solution

We have requested that HCPC issue specific guidance for investigatory panels in these cases going forward and it was proposed that panels see a summary of the case described above.

HCPC Response

The HCPC stated they had changed their investigatory panel training in light of the above case and offered to share the relevant training materials relating to low level conviction cases (e.g., arising from Extinction Rebellion protests) in the New Year with ACP-UK representatives. 

4. Appointment of non-Clinical Psychologists to Clinical Psychologist panel hearings

Background

It remains our professional opinion that it is not appropriate for Clinical Psychology registrants to be judged by other types of Practitioner Psychologists. With all due respect, Educational, Forensic, Occupational, Counselling, Health and/or Sports and Exercise Psychologists are not able – nor should they be expected – to judge the ethics, work context and healthcare obligations of an NHS or third sector Clinical Psychologist.

ACP-UK Solution

Whilst ACP-UK understands that the Health and Care Professions Tribunal Service (HCPTS) strives to match practitioner domains, it is nevertheless restricted by the numbers of modality registrants it has available for a particular tribunal and logistics. The ACP-UK has previously offered to provide Clinical Psychology registrants to serve on the panels. Our offer still stands.

HCPC Response

The HCPC responded to the question about the number of Clinical Psychologist partners currently serving as registrant panel members for fitness to practise proceedings: there are currently 27 Practitioner Psychologist partners representing the seven modalities of the profession. Of those 27 partners, seven (25.9%) are from the Clinical Psychologist modality.

The HCPC expressed appreciation for our offer to help promote our next registrant panel member recruitment campaign for Clinical Psychologists. They have asked to link up with ACP-UK on this, and have made the HCPTS aware so they can take this forward at the relevant time.

ACP-UK’s Ongoing Concern

ACP-UK remains concerned that this may not be representative of the proportions of complaints against practitioner psychologists by domain.

5. Poor administrative procedures and form relating to return to practice following illness

Background

We have been contacted by our membership about the frustrations they have been experiencing when completing return to practise forms as required by the HCPC.

There have been significant delays and bureaucracy associated with return to practice following a period of illness or maternity leave. The HCPC form being used appears to be a generic one for all health and care professions. As relates to Clinical Psychology, the form is not fit for purpose. It is unnecessarily complicated and misleading.

Significant delays by the HCPC have significant consequences, including financial, for Clinical Psychologists who clearly would not be able to return to practice until the forms are verified and signed off by the HCPC.

ACP-UK Solution

ACP-UK recommends co-producing forms that are fit for purpose for our profession and, further, would be willing to advise on how best to achieve this.

HCPC Response

This item came at the end of our 12 November meeting and there wasn’t time to fully discuss it. However, we will be following up on this issue and requesting joint review of the return to practice form.

Conclusion

This was a constructive meeting in which, for the first time, the HCPC acknowledged its shortcomings and offered substantive undertakings to rectify these.

ACP-UK will need to monitor the HCPC’s progress and evaluate member feedback going forward to ensure commitments described above are implemented. We urge all members to contact us with any concerns and/or any information that may be of help in our effort to support the HCPC to improve its practice and standards.