- 11th December 2020 - Consultation with the PSA
You will be aware that the Society holds an Accredited Register with the Professional Standards Authority and has done since 2012.
In our survey of 2018 an overwhelming number of our members supported the Accredited Registers programme and the Society continues to consider the programme to be the best way of delivering public assurance, as well as providing well deserved recognition for our members.
We and the other Registers have recently been meeting with the Professional Standards Authority and discussing the future of the programme as it enters its second decade.
The Authority has just launched a major public consultation on the future of the programme. Full details can be found here:
The key points in the consultation centre around how the programme could possibly be strengthened, giving more status to Accredited Registers and delivering more integration between Accredited Registers and our national health and social care programmes.
The main focus of the consultation is:
- How should we determine which occupations should be included in the scope of the programme?
- Should we consider the effectiveness of occupations in decisions about accreditation?
- Should there be greater consistency of standards of competence across Accredited Registers, in particular for individual occupations?
- Should we take into account proportionality and risk?
The Authority wishes to ensure the programme can:
- Support the delivery of NHS healthcare and social care workforce plans in England, NI, Scotland and Wales. This includes a greater contribution to personalised care for patients and to the Covid-19 recovery in health and social care. The pandemic has highlighted the need for greater integration of health and social care, and of the value of mental health care delivered by unregulated roles.
- Become a requirement for employers using healthcare practitioners in unregulated roles in the UK, and social care in unregulated roles in England
- Support innovation and be able to respond quickly to change. This is an advantage that voluntary assurance has above statutory regulation.
These are big questions. Of particular interest to members will be the question around consistency of standards for individual occupations. How might consistent standards be delivered in hypnotherapy, for example, while still assuring the diversity and complexity of the profession?
Another big question is over considering the “effectiveness of occupations.” To set some context here, members may be aware that a wide variety of complementary therapies (homeopathy, for example) are engaged with the AR programme. There are opposing views as to whether this is appropriate. On the one hand, the argument in favour states that offering an AR programme for complementary therapies ensures that practitioners are held to account and that complaints can be made. On the other hand, the argument against states that, where there is no evidence for a therapy, it is harmful to give what members of the public may consider to be a “seal of approval” from the AR programme.
Why this is a big question for hypnotherapy is how is “effectiveness” to be assessed? Is it the same as evidence based or evidence informed practice? For hypnotherapy these are loaded questions and we trust that the Authority will, of course, continue to view hypnotherapy as a whole with many modalities and approaches, many of which are not appropriately assessed in a narrow empirical manner.. We have no reason at present to believe otherwise.
Also of great interest will be that the Authority wishes being on an Accredited Register to be a requirement for employers using healthcare practitioners and practitioners in social care roles. This will have less impact on hypnotherapy as there are few, if any employment roles for hypnotherapy.
In the consultation document, the Authority references the concept of setting up a licensing body in order to ensure that unsafe practitioners could no longer practice. This, if applied hypnotherapy would see a fundamental shift from a voluntary scheme to one in which you held a licensing requirement to practice and your license could be revoked; for example in the event of a complaint. This, it is mooted, would be less of an imposition on practice than full statutory regulation while offering greater public assurance.
The Society will shortly launch its own consultation with our members on the Authority’s proposals, so that we can submit to the Authority our members’ democratic views and be guided by your voices as things move forward.
We would like to end this bulletin with a note of reassurance to our members. We have been dealing with the Authority since 2010 and throughout that time, as a regulator they have been flexible, fair, professional and supportive. We have every confidence that the Authority will engage with Accredited Registers, and indeed Registrants, fairly and openly, that they will listen to concerns, and we trust that the AR programme will emerge in a strengthened form beneficial to our members in the long run.
- Coronavirus COVID-19 - Guidance for Members
National Lockdown/Tier 4
The UK Government advises that we work from home where possible. This remains the case when in a Tiered system, as well as during a National Lockdown.
The Society's advice to members is to continue to offer services remotely where it is possible to do so.
Members may make individual decisions to work in the room with a client if it is not possible to work remotely due to a risk to the client.
Point 47 on page 32 of the Health Protection Regulations 2020, under businesses permitted to remain open, lists services relating to mental health.
This is reiterated by the Government's advice that support that is essential to deliver in person, where formally organised to provide therapy, can be allowed to continue. This includes support to victims of crime, people in drug and alcohol recovery, new parents and guardians, people with long-term illnesses, people facing issues relating to their sexuality or gender, and those who have suffered bereavement.
Please read the section on Face to Face Hypnotherapy - Updated Guidance if you decide to offer in-the-room therapy.
The Department of Health and Social Care (DHSC) has provided some guidance in relation to the new Covid-19 guidance and regulations for England which was published on the 4th of January:
- Personal care services provided for medical and health treatment may continue. The guidance on safer working in Close Contact Services should be followed https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/close-contact-services
- Where applicable, practitioners should also take into account any guidance issued by the healthcare regulators or a relevant professional body.
- The Government cannot provide comments on individual cases of whether or not a business is permitted to open. It is for each business to assess whether they are a business required to close having considered the Regulations and guidance on business closures: https://www.gov.uk/government/publications/further-businesses-and-premises-to-close/closing-certain-businesses-and-venues-in-england#businesses-permitted-to-remain-open
Face to Face Hypnotherapy - Updated Guidance
Members may make individual decisions to work face to face if they consider that it is not possible to work remotely with a client. Decisions should take into account:
- the heath risk factors for yourself and your client, especially those connected with age, pre-existing health conditions, and so on.
- your ability to create and maintain an appropriately socially distanced and hygienic space for face to face client work.
- the risks to yourself and your client in travelling to and from your clinic space.
- your ability to understand whether you and your client should instead self-isolate, for example, if either of you or anyone living with you has developed potential symptoms of COVID-19.
- That you continue to be aware of Government guidelines and are up to date with them.
- that alternative ways of conducting your client sessions, or postponing their sessions, are not possible or detrimental to your client's wellbeing and welfare.
Taking into account the above, it is your responsibility to make an informed decision regarding face to face practice at this time. The Society recommends raising concerns with your supervisor as well as engaging with your clients as much as possible regarding this issue.
Best Practice for Face to Face Hypnotherapy
If you do need to return to working face to face, we recommend following the guidelines below, and taking all possible steps to limit the risk of exposure for both you and your client.
- When seeing clients face to face, ensure that both you and your client practice appropriate hygiene procedures before and after meeting, including hand sanitisation.
- Maintain a good distance of at least two metres from your client.
- Refrain from shaking hands and ensure you have explained to your client why this protocol is being followed.
- Refrain from other physical contact, for example, hugging a client.
- If possible, where providing tissues do not use one central box of tissues. Pre-divide tissues into portions so that different clients do not touch the same tissue boxes. Alternatively, advise clients to bring their own tissues.
- Remember to clean surfaces: phones, laptops, door handles etc, regularly.
Other things to keep in mind:
- Be prepared in case of evolving Government advice to cancel face to face counselling again for a temporary period. It is best to communicate with all clients and inform them that their sessions could be liable to postponement or disruption on a temporary basis. Where possible, offer to clients the option of continuing sessions by phone or video conferencing.
- Be aware of your clients' increased levels of stress and anxiety, and take extra self-care during the current public health crisis. If you feel overwhelmed, seek supervisor and peer support.
- Communicate with the Society when you need to and we will try to help as much as we can
- Inform clients that future sessions will be postponed if they are advised medically to self-isolate, or if they have any symptoms of a cold, cough, respiratory issues or a raised temperature.
- Inform clients that if you are diagnosed with coronavirus the NHS will require that you divulge a list of people you have come in contact with. In such circumstances you will inform the NHS of your contact with your client.
- Make sure you are prepared to communicate with clients in the event that you must self-isolate or fall ill. Rearrange appointments if you have any relevant medical symptoms.
This advice is superceded at all times by Government advice and the law and is subject to change at short notice.
For further Government advice please click here
For further NHS advice please click here
Updated During Current Lockdown Period
Localised Restrictions & Tiers
When Localised Restrictions and a Tiered approach are in force, the following are examples of ethical practice; however, in all cases our advice is superseded by the Government at all times.
Covid Alert Levels
Tier 1: Medium - It is ok to practice in-the-room provided that you adhere to the social distancing rules, and ensure that the room and surrounding areas (if relevant) are Covid-secure including hand sanitiser, wipes/spray etc. Nonetheless, we recommend continuing to work online where possible.
Tier 2: High - This tier involves a ban on the mixing of households indoors, so we would advise using online in every case, working face-to-face only when entirely unavoidable, and maintaining the social distancing rules and a Covid-secure environment.
Tier 3: Very High - Local Government will decide whether close contact services are allowed to remain open, however this tier asks people to avoid non-essential travel. We recommend ensuring all work is online only, and we would ask you to take advice from local authority if you feel a client is at risk from discontinuation of in-the-room work.
For Tier 4 please see the National Lockdown/Tier 4 section above
Close Contact Services & Face Masks
The Government has updated its guidance for those providing close contact services including wellness businesses, as well as well-being and holistic locations. It is likely that counselling services are included under these headings, however we are seeking further clarification around this.
You can find the guidance for England here: https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/close-contact-services
The guidance for Wales is here: https://gov.wales/keep-wales-safe-work#section-47135
The guidance for Scotland is here: https://www.gov.scot/publications/coronavirus-covid-19-retail-sector-guidance/pages/close-contact-services/
The guidance for Northern Ireland is here: https://www.nibusinessinfo.co.uk/node/23151
It includes steps that will usually be needed to ensure a safe workspace, and ideas for consideration.
For guidance on working online, please read Appendix A of the Code of Ethics
Insurance Cover - Working Face-to-Face
We asked Howden and Balens if they are covering face to face client work for therapists at this time. Here were their answers:
Howden: Yes, provided that it is essential to work face to face and that you follow government guidelines you will be covered.
Balens: We can confirm your policies with Balens are in place to cover against any work you perform. This is subject to you adhering to government guidelines about practicing safely, and any advice you receive from your governing body/associations.
Your training school will be your primary source of information during the Coronavirus.
Trainers should make individual decisions based upon the way in which they wish to proceed during the current public health crisis. Particular care should be given that guidance given by trainers to students complies with up to date Government health guidelines. Trainers should inform the Society if they wish to modify the way in which they are offering practical training to their students.
In the event that practice hours and case studies are postponed, but other elements of the course are completed, the Society will process incomplete registration applications so that graduates are ready to have their registration activated as soon as they have completed their practical work. This will ensure there are no extra processing delays once practical work is finished.
Remember this will be a temporary issue and that training normality, if disrupted, will resume and there are lots of contingency plans for this.
For further Government advice please click here
For further NHS advice please click here