European Union Political Framework
- The European Union uses the concept of “professional competencies” or “functional competencies” to assess the different ‘training standards’ within a particular profession, trade or vocational employment across Europe, and also to differentiate between one profession (or trade) and another – on a purely ‘functional’ basis. Example: If a person has demonstrated that they are ‘functionally competent’ to install a domestic central heating system, irrespective of their country of origin or the type of their training, then that person will have demonstrated one of the ‘professional competencies’ of a European plumber.All this is happening in line with the European Union’s primary function of establishing and maintaining a ‘free labour market’ across Europe and establishing and evaluating the Professional Qualifications Directive.
- Some seven professions were originally regulated under a "Sectoral Directive". These professions are: doctors, nurses, midwives, dentists, pharmacists, veterinary surgeons and architects. Some other professions (teachers, engineers, social workers, physiotherapists, tourist guides, sport professions and also professional activities falling under Annex IV [crafts, industries & trades]) have had 'competent authorities' established under the "General System".
- Work has been done on some "temporary systems" - for the regulated professions - under Directive 2005/36 whereby legally established professionals in a Member State should be free to provide services on a temporary or occasional basis in another Member State. In such cases, the host Member State may only request a prior declaration and require a pro-forma registration with the relevant professional body: it may not carry out a prior check of professional qualifications, except when justified on grounds of health & safety. However, there is a preference in many professions (not covered by a Sectoral Directive) for a system for more permanent registration and a relatively simple registration system for trans-nationals.
- The " General System" for recognising professional qualifications across Europe (established in 1989 and supplemented in 1992 and 1999) currently applies. However, this also has its deficiencies. It established the concept of a "Common Platform" for a profession, but this instrument is proving very complicated and - to date - no Common Platform in any profession has yet been established (see short article here). However, the system of the EU free labour market is not working very well and the EU is (at last) acknowledging this. Recently (7 Jan, 2011), a consultation paper came out on the Professional Qualifications Directive and the internal market system, inviting comment and answers to a number of questions. To read this paper, click here. To read a short synopsis of all this: 'Working as a Psychotherapist in Europe' - an article by Tom Warnecke, Vice-Chair, UKCP, click here.
- Work has also been done on the European Qualifications Framework (Directive - Article 11), which establishes five levels of qualification. For a "profession" such as psychotherapy, the 5th level is the one that is relevant: a 'diploma' would be issued certifying that the holder has successfully completed a "post-secondary" (tertiary) level training course of at least four years duration. For the 'liberal professions' [organised under the European Council of Liberal Professions (CEPLIS): www.ceplis.org], this '5th level diploma' essentially means a 'post-graduate' training course of 4 years, i.e. post-graduate = coming after a relevant university first degree (BA, BSc), or the equivalent.
- Within all these different levels of professional regulations, the EU is attempting to identify the 'professional competencies', 'national occupational standards', 'training standards' or 'occupational profiles' of any particular profession, or trade, that essentially describes the work and the tasks that should normally be expected to be carried out by someone working within the framework of that specific ‘occupational activity’ or ‘trade’ or ‘profession’, as well as the related knowledge, skills, abilities, training, and experience necessary for the person involved to carry out these occupational or professional activities competently and successfully.
Two Different Conceptual Frameworks
Within the ‘profession’ and 'practice' of European psychotherapy today, there are two fundamental, but very different (even contradictory), perspectives:
- The predominant perspective is that:
Psychotherapy is a multi-disciplinary, professional activity that can be done ‘professionally’ by a variety of professions and people (as long as they have received a proper professional training), in a variety of different circumstances, and with a wide variety of different methods.
This ‘pluralistic’ perspective forms the basis of: the Austrian law on psychotherapy; the proposed UK & Ireland regulations on psychotherapy; the status quo in many European countries; and this view was also endorsed by the EU in its proposal for a directive in Feb. 2005 (click here). This is essentially the view of the European Association for Psychotherapy (EAP), enshrined in the 1990 Strasbourg Declaration on Psychotherapy.
- The other basic perspective is that:
‘Psychotherapy’ as an activity that could, or should, only be done by certain professionals – usually psychiatrists or clinical psychologists.
In some European countries (like Germany, Italy & Holland), laws have even been passed to this effect.
However, there then follows a complication: if a person is “state-registered” as a psychotherapist in one European country, they have the legal ‘right’ to practice (trans-nationally) as a ‘psychotherapist’ in any other EU country and which is the basis of the European Union as a free labour market.
In such instances, the national ‘law’ cannot apply to trans-nationals: and this has already been established as a legal precedent in a number of court cases. These national ‘laws’ also tend to restrict the ‘practice’ of psychotherapy to a few generally accepted modalities or methods (traditionally psychodynamic, cognitive-behavioural, systemic, and occasionally a few humanistic methods, like ‘Gestalt psychotherapy’); largely irrespective of any scientific evidence.
These national ‘laws’ on psychotherapy can therefore be considered as a form of a ‘restrictive practice’, which may or may not have been made legal in that particular country - for the moment!
- There is a third (somewhat pervasive) perspective: that psychotherapy is a 'medical treatment' and thus all psychotherapy methods (or modalities) should present 'scientific' research data to 'prove' the efficacy and effectiveness of this method. Whilst this is not necessarily a bad idea: this view is often taken to limit the types of psychotherapy that are 'allowed' by any particular country (especially where there are laws about psychotherapy): in essence, this can be another form of restrictive practice, as psychotherapy is much more than 'just' a treatment for certain 'conditions' (like anxiety, depression, etc.), or a 'treatment' for certain forms of 'mental health' issues. This 'medical model' is thus being used to limit and restrict the general practice and public accesssability of psychotherapy. The EAP is very much for psychotherapy being considered as 'scientific', but not being restricted by the medical definition of 'science' - as applied to pharmacology, as basically the 'scientific' criteria used to assess methods almost totally ignores the very important human interactive component. (For more about the "Scientific Background" see here.)
The EAP has therefore been pursuing a "Common Platform" on Psychotherapy with the European Union Parliament, and, to this end, is also developing this project to establish the Professional Competencies of a European Psychotherapist. This will also help define what a European psychotherapist 'should' be able to do, and thus - in due course - help to clarify what are the essential differences between the profession of psychotherapy and other professions like psychiatry, clinical psychology, counselling etc.
ISCO: International Standard Classification of Occupations:
Over, above and beyond all this:
Currently the independent 'profession' or 'occupation' of "Psychotherapist" does not officially exist - according to the ISCO: part of the International Labour Organization: (here) - a specialized agency of the United Nations - which maintains the International Standard Classification of Occupations. This is updated about every 20 years and the most recent version draft ISCO-08 was adopted in Dec 2007, though it does not seem to be fully published yet.
In the previous (published) version: ISCO-88, we can find:
Psychologists are listed - 2445 1-92.30, with a job description (here): with various sub-divisions of Clinical; Educational; Experimental; Industrial; and Social - but these sub-divisions do not seem to be explained much.
Looking at the alphabetical listing (here) - 'Psychotherapist' does not appear at all, nor does 'Counsellor' except for employment and occupational guidance, 2412 1-94.30. Psychiatrists are listed under medical doctors: 2221 0-61.20; Social workers have lots of categories: 3460 1-93.10-90 & 2446 1-93.10-50.
In the ISCO-08, final draft of 'Group Definitions' (here), 'Psychotherapist' is listed as a sub-category of 'Psychologist' (now 2634) on p. 165., along with 'Clinical Psychologist', 'Educational Psychologist', 'Organizational Psychologist' and 'Sports Psychologis't - and seemingly 'Experimental, Industrial and Social Psychologists' no longer exist.
We may need to do a lot of work over the next 15-16 years to ensure psychotherapists as also listed - if we are serious about psychotherapy being an independent profession.