SCoPed and trans (and other marginalised) people

This is a post that got started some time ago but was neglected until now. The arguments still stand and so we are posting it with ‘better late, than never’ in mind. 

The 2023 BACP announcement that ‘all partners’ had decided to adopt SCoPEd is going to reframe what training means for qualified counsellors, along with who gets what, when, and how. What it will eventually mean is that according to your training you will enter at one of three points A, B or C (originally these columns were called ‘counsellor’ ‘psychotherapeutic counsellor’ and ‘psychotherapist’, but this was changed after an outcry- as if labelling the column differently is going to make a significant difference to the stratification of our profession). Jobs will likely be stratified according to at least the competences listed in the columns, if not clearly by the columns themselves.

We’d like to concentrate here on both the EDI assessment, and the impact that SCoPed will have on LGBTQIA+ practitioners and trainees as we move forward.

We will use the term ‘therapist’ here to cover anything that we would consider either ‘counselling’ or ‘psychotherapy’ in that whatever you call it, we are all aiming to be of some kind of therapeutic benefit when working with our clients.

Your TL;DR is: Without Membership Body (MB) data, we do not know if those in ‘protected characteristics’ will be discriminated against, and there is no MB data (and currently no suggestion that this will change). Whilst there will be the ability to move between (up through) columns post-training, it is likely to more significantly impact those with less privilege. A ‘column A’ therapist is expected to have less competences (and will be seen as less competent) than a column B therapist. It follows then that a column B therapist will likely be a higher paid role. 

So, those with less financial privilege (uniformly those who are more marginalised in society) will be most likely to participate in a ‘column A’ ranked training, ending them in a lower-paid job, which will render undertaking further training to get into column B (and C) more difficult (and it is likely that people will be unable to find out definitively from BACP BEFORE they pay for an additional training, whether that would qualify them to apply for the ‘next column’), and once that has happened, the individual will then have to pay to move into that next column.

For this EDI assessment, six therapists, a miniscule fraction of the 50,000+ therapists currently registered with BACP, were consulted, and the qualifications of the consultees is not disclosed. Despite there being very little actual EDI work in this EDI impact assessment, and the results suggesting that there will be at least some impact on those more marginalised, the EDI assessment suggests we make a start on SCoPEd as it is and trust that the rest is worked out along the way.

The EDI impact assessment

We believe that as a process, this EDI impact was flawed. There are six member organisations that have signed up to SCoPEd. Whilst there will be a percentage of people who are in multiple organisations, the membership for NCPS sits at over 9000, the membership for BACP sits at over 50,000, UKCP sits at over 11,000. That’s half the memberships listed, and although we expect BACP to be the largest, if we assume even 5000 for the others, that’s about 85,000 therapists (the SCoPEd announcement says 75,000), and more joining every year.

An ‘EDI impact assessment’ was commissioned to (one presumes) look at the impact of SCoPEd across all demographics.

This impact assessment was conducted by a company called Eastside Primetimers, who state: “The strategic objectives that the Partners set for SCoPEd draw our attention to the dependency of its success on equality, diversity and inclusion (EDI) considerations”. Before they started on this project, Eastside Primers were calling SCoPEd a ‘groundbreaking project’ and a ‘pioneering project’. We wonder how easy that would be to turn back on if you were to find significant issues with the project.

The report states that it has struggled to get any information about those who might be in protected characteristics from the membership bodies (MBs) and they state at the start of the document that they cannot say (yet) what the impact on those people who might experience less privilege will be. None of the data collected is cited as being race/ethnicity, cis/trans status or sexuality, or disability (pg 13). In those where gender was collected, the average number of men in the profession is 16%. The report suggests (pg 11) that should SCoPEd NOT go ahead, that this will disadvantage people who have less privilege. It does not seem clear on why this is so.

The EDI report acknowledges that the framework is not a public-facing document so it asks ‘a small number’ of the public (12 people who’d had experience of counselling) to consult with it about SCoPEd. They approached six counsellors, 3 of whom were men (meaning that men proportionally have more of a voice as a reflection of the profession here), five were white, five didn’t identity as disabled, and none stated any LGBTQIA+ identity. There is no suggestion of their socio-economic status either. Four people interviewed were in private practice. Again an interesting choice, as those in private practice are potentially least likely to be impacted by SCoPEd. 

They gathered six people for interview. There is no suggestion that, in this ‘equality and diversity impact’ consultation, they interviewed six people who might be qualified to speak about these topics. In fact, their report states “Some communities (such as those identifying beyond the gender binary) are not represented due to factors, such as not responding to the invitation to interview or not meeting the survey criteria in some way, such as not being a member of a registered professional body” (pg15).  Dominic Davies from Pink Therapy, “the UK’s largest independent therapy organisation working with gender, sex and relationship diverse clients” has stated that he was not contacted for any help, and that had he been so, he would have facilitated the reaching out. There are over 200 people listed on the Pink Therapy directory who have a specialism in LGBTQIA+ topics, and at the time of the consultation, 45 of these have ticked the ‘trans’ box as part of their own identity, suggesting that at a minimum there were 45 people listed with an MB who might have been open to being contacted. Several of those people are TACTT members and were not asked

We do not know for certain that The Black, African and Asian Therapy Network (BAATN) or Black therapy matters had a similar experience, but we’re willing to take a guess. This EDI ‘consultation’ didn’t try very hard to find a trans person (or any LGBTQIA+ person), interviews ONE disabled person, and ONE person from a minority racialised background, and gives no real impact on what SCoPEd might mean for therapists with marginalised identities.

We do not really see any EDI impact in this 27 page document until pg 19 when we find  “There is a risk that Partners’ membership data systems do not facilitate EDI-relevant analysis of progress in widening access to and progression within the profession, and so in turn ensuring that the framework does not exacerbate barriers to access and progression”. This says to us that there is no way that we can know if SCoPEd will have an impact on the most marginalised counsellors because MBs don’t collect that data.

Page 20 of the EDI assessment suggests that without the ability to move between columns with further training (rather than only ‘core training’, which would require a qualified counsellor to start again as if untrained), that this will compound the difficulties those therapists with ‘protected characteristics’ hold, and make higher columns inaccessible.

Despite the information given above, this consultation sees no reason why SCoPEd can’t go ahead as it stands and we can iron out the details later. A profession based on expertise especially in one’s own process should never be mediated by privilege. It is an impoverishment of the profession as well as injustice to practitioners with marginalised identities.

There is an interesting point in the data, which is that single women are less likely to support SCoPEd than partnered women, and we cannot help but wonder if this is part of the reason that SCoPEd votes are going through – that if you think it doesn’t affect YOU, PERSONALLY, you don’t necessarily consider the impact on other people. Those who are in a relationship will generally (we know, not always) have a second income coming into the family. Those who only have one income coming in have to be much more aware of SCoPEd and how this might impact. This ‘awareness of how all counsellors might be impacted is, in our opinion, what an EDI assessment would do.

This EDI assessment says: as SCoPEd stands, you can’t move across columns without investing in more training; those who are more marginalised can’t afford more training; some organisations have already said they will start to stratify therapists according to columns, thus ensuring that column A therapists can only do ‘lesser’ qualified roles (which presumably one then gets paid less for, or the thing that we CURRENTLY see, which is that someone is ‘good enough’ to volunteer, but not good enough to be paid), thus meaning that they earn less money and therefore have less income to be able to afford more training that might push them across columns. But please, feel free to get started and iron out these ‘small’ details later.

Trans folk, queer folk, disabled folk, folk with racialised identities, folk who are working class, will all find it difficult to move into the top two categories and are at risk of being pushed into lower paid jobs as a result, and kept there. For those people who are multiply marginalised this will be even more more likely and this ‘EDI impact assessment’ does not recognise intersecting axes of oppression in its report whatsoever.

A book review: The Queer Mental Health Workbook

We asked some of our members if they would care to read various books around working with LGBTQ+ topics, and write book reviews. Here is a review from one of our members, who has approached the reading of this book from the point of view of being a therapist who might want to explore this book as a way to work with clients.

The Queer Mental Health Workbook
A creative self help guide using CBT, CFT and DBT
Dr. Brendan J. Dunlop

Dr. Dunlop’s book definitely fits the criteria of self-help, and shares some of the positive and negative features of this genre. On the positive side, it does offer practical (rather than creative, if I’m being picky) exercises that are easy to complete and buying the book gives you access to downloadable versions of resources too including some colouring sheets which, while not being exactly creative, does encourage the reader to get their felt tip pens out.


Dr. Dunlop puts his ideas in a broader context which helps get perspective and adds meaning to what we are reading or being encouraged to try. He often writes as if he is speaking directly to the reader which gives it a pleasant immediacy and directness and moments of honesty and familiarity would definitely, in my opinion, make a reader feel less alone (for example the list, in the chapter on identity, of very recognisable comments that queer people might find themselves exposed to).


Other useful aspects included in the chapter on self-acceptance and self-compassion, a table on what might be behind things such as self-harm, substance misuse, disordered eating and self-neglect, and Dr Dunlop offers a deep dive in side boxes in the test (for example, giving some background to Section 28 [the prohibition on teaching about ‘homosexuality’ in high schools that was in place 1988-2000/2003 depending on whether you lived in Scotland or England and Wales] and how it could have impacted queer people’s mental health).


The book is very broad, so there’s bound to be something in there for almost everyone and readers are encouraged to go directly to the chapters that will be most relevant to them. However, in this breadth comes some of the aspects of the book that I found less helpful. The exercises, because they are designed to be accessible and applicable to a wide range of people, can come across as quite simple and for me, did not have enough depth and the text was similarly general. 

Some concepts or ideas about concepts were presented as facts without acknowledging that they might not be true for all and a several concepts felt over-explained and overly simplified. I felt frustrated at what felt like ‘talking down to’ the reader.


As a therapist, I would recommend using exercises from this book in a personalised way in sessions with clients, tweaking them to suit the needs of your clients and guiding clients through them rather than just handing it over to a client. I felt, in its current form, it would be best suited to teenagers but for them, the patronising (in my opinion) feel of much of the voice could alienate and annoy them, making them feel that things are being overexplained. Having said that, when the author does go deeper (for example the activity on ‘identity in context’ in chapter 4), it seemed to me to be a lot more useful and beneficial.


In summary, do selectively read this book and choose the exercises you would share carefully, personalising them to your clients and putting them in the context of your clients’ lives and experiences. To be fair to Dr. Dunlop, this is hard to do in a very generalised book, and he does make it clear that a reader should choose the parts that work for them. There are some useful parts here, and it is worth making the effort to find them by zooming in directly to the chapters that seem relevant to your clients and personalising what you offer so it is meaningful to them and presented with respect, with free choice and with acknowledgement that one size certainly doesn’t fit all and ‘facts’ are to be handled with caution.

Final response to UKCP

On 2nd November 2023, UKCP published “guidance regarding gender critical views” for their members. We were very concerned by this guidance and wrote an open letter detailing our concerns which has been signed by over 1,000 therapists, trainees and other professionals. There followed an exchange of statements with UKCP, which you can read on our blog and as updates to the open letter. We are now publishing this as our final update, inviting UKCP into dialogue in the hope that the Council may yet find understanding, compassion and empathy for trans life, and that we can work together to protect and support trans clients. At the end, we also address all psychotherapists and counsellors; trans and gender-expansive therapists and trainees; and our current and future trans and gender-expansive clients.

Dear UKCP,

Thank you for your response, published on 15th December 2023, to our open letter about your guidance regarding so-called ‘gender-critical’ views. This will be our final written response in this series of communications, although we otherwise remain open to dialogue with UKCP on this matter. We are using this written response to expand upon points made in our holding statement published in early December, as they were not adequately addressed in your response to us.

We do not wish to volley written statements back-and-forth with UKCP; our concern is making  therapy safe for our trans and gender-expansive clients. We would welcome an opportunity to meet with UKCP and discuss how the Council too can support this work.

At this stage, we would  like to highlight our continuing concerns with the statements published by UKCP, both in your original statement and in your response to our open letter, before addressing other therapists and any clients who may be reading:

  1. Once again, this latest response from UKCP entirely fails to explain how it will protect trans and queer therapists, trainees and clients. Indeed, any mention of what trans clients might want from therapy is entirely absent. UKCP is speaking over the people who are most impacted by their statements and creating an atmosphere of fear and confusion. There appears to have been no consultation with trans and queer therapists or clients. This is regrettable given UKCP has shown some effort in the past to include and listen to marginalised groups.
  1. TACTT is concerned that this statement either doesn’t understand or misrepresents what affirmative therapy actually is. Affirmative therapy means the therapist supports the client’s right to define themselves. The splitting of ‘exploratory therapy’ from affirmative therapy is now being used to justify a form of therapy based on so-called ‘gender-critical’ beliefs. We cannot stress enough that all good therapy should be exploratory in nature, but weaponising affirmative therapy to make way for so-called ‘gender-critical’ praxis is blatantly unethical and, we believe, amounts to discriminatory practice. The play on language does not hide the unethical attempt at trans-erasure.

We note UKCP’s imperative to remind us that so-called ‘gender-critical’ beliefs are protected under the Equality Act 2010; we remind UKCP that trans people are also protected under the same legislation. We are not seeking to discriminate against people who hold so-called ‘gender-critical’ beliefs. However, if a practising member of UKCP does not believe in the legitimacy of trans life then, according to UKCP’s own Code of Ethics and Professional Practice and the MOU on conversion therapy in the UK, said practitioner would be ethically bound to refer on to competent colleagues.

As practitioners committed to trans-affirmative therapy, we now find ourselves in an uncertain and increasingly unsafe professional environment, where anti-trans activism is emboldened. Those of us who are trans and queer professionals and trainees find ourselves isolated and left to advocate for ourselves against institutions with far more power. The available pool of truly competent and safe therapists for trans and non-binary clients is already small. UKCP’s guidance does nothing to help this.

  1. We are dismayed that much of our effort to communicate with UKCP has involved having to remind the Council of its own core values, pointing to the Code of Ethics and Professional Practice and its position as a signatory of the MOU on conversion therapy. UKCP still has not acknowledged that its position on so-called ‘gender-critical’ beliefs, which may cause harm to transgender clients, contravenes its position as a signatory to MOU. We fear that, at best, this will cause significant confusion for members and, at worst, harm to clients.

As stated, we do not want to get into an interminable correspondence with UKCP.  Rather, we would like to invite UKCP to a roundtable discussion with members of TACTT to address our concerns. We seek dialogue, not to call out our colleagues, but to invite you to join us in finding understanding, compassion and empathy for an extremely vulnerable client group.

Alongside this, we will continue to work to improve therapy for trans and gender-expansive people through advocacy, education and campaigning. We ended our open letter by stating that those of us who are UKCP members or training in UKCP-accredited organisations are starting to question our place within the Council. If UKCP is unwilling to engage on these questions, you are likely to continue losing the trust of your members who work in a trans-affirmative way, as well as the trust of clients.

Yours sincerely,

TACTT 

We now turn our attention to the different audiences reading this letter.

To all psychotherapists and counsellors: 

We urge you to expand your knowledge and learning on trans-affirmative therapy, and specifically, seek training and education from trans and non-binary practitioners.

We encourage self-reflection on your own process around gender, transness and affirmative therapy. We further encourage you to seek out appropriate supervisory guidance if you are unsure about any aspect of your work. If you do not feel comfortable or equipped to work supportively and openly with trans and non-binary clients, it is ethical to refer them on to competent colleagues. We suggest a search on the Pink Therapy and Gendered Intelligence therapist directories for such practitioners.

We encourage you to examine your culturally inculcated reactions and responses to this topic and invite you to begin to challenge and work on them, in just the same way you may work on unconscious bias across all the other axes of oppression. 

We also remind you that trans and gender-expansive clients seek therapy for all the reasons anyone of any gender might come to therapy. By engaging in these processes of reflection, you will be better placed to support these clients with matters such as depression, anxiety, bereavement, relationship issues etc. without bringing an unwanted and unnecessary pathologising focus to their gender.

For those who are allies and who have already spoken out on behalf of trans clients, thank you. Any therapist who would like to use their voice for change is welcome to join TACTT.

To trans, non-binary and gender expansive therapists and trainees:

We see you. We know that the continued attacks on trans rights – both within and outside the therapy profession – create an emotional burden which you are shouldering while helping your clients to navigate the same environment. We oppose transphobia across the therapy profession and will continue to work to ensure the voices of trans, non-binary and gender expansive therapists and trainees are heard. 

To our current and future trans and gender-expansive clients:

We want you to know that you are welcome in the therapeutic space, that you belong here. We want you to feel safe accessing therapy, no matter what you come to therapy for – whether that is support through transition, gender questioning or indeed any other issue not related to your gender. We want you to have competent, supportive, knowledgeable and, above all, safe therapists to work with. 

We want you to feel empowered to question a prospective therapist about their stance on trans life to ascertain if they are safe for you to work with. 

Guidance such as the Pink Therapy guidance on how to choose a therapist is likely to be helpful. We also suggest asking a therapist if they have experience in working with trans and non-binary people and whether they have either lived experience or extra training in the subject. You can state you are looking for an explicitly trans-affirmative therapist and ask if they consider themselves to be so. 

Remember, exploration is an important part of any therapy. But the term ‘exploratory therapy’ is being increasingly weaponised by those who hold anti-trans beliefs, so ask your therapist what they mean by any terms they use.

Ask for word-of-mouth referrals from trans and non-binary communities. We also suggest searches on directories that are explicitly trans-inclusive, such as Pink Therapy and Gendered Intelligence, and to use trans-affirmative or inclusive search terms when seeking a therapist. 

When words matter

We start this with a caveat: the language and definitions of terms are correct as of Dec 2023. This may change in future.

As therapists we work with people from all types of backgrounds and may encounter those of a different race or ethnicity to us, those with a different class, sexuality, gender, those who are (differently) disabled, as well as those who are trans.

Although most UK counselling membership bodies (including BACP, NCPS, UKCP and ACC) have signed up to the memorandum of understanding on conversion therapy (that is – conversion therapy is bad and the evidence overwhelmingly suggests that it has a risk of suicide, there is a current discussion around language and semantics that feels important to unpick.

In light of the UKCP’s statement around exploratory therapy and their response to TACTT’s open letter, this blog sets out a brief overview of key terms as used by gender critical (GC) therapists (which are often in direct opposition to the definitions used by non-GC therapists).

Gender critical: To be ‘gender critical’ (or ‘GC’) exclusively refers to those people who don’t believe that trans is a valid identity. A GC person believes that there are only two sexes, that people can’t change sex and that sex is the axis that matters. Gender critical people do not believe that “trans women are women” and “trans men are men” (and non-binary people exist), but that trans people are at best delusional, and at worst, predatory (‘men aiming to access women’s spaces’ for example). It is of note that the term ‘gender critical’ originally meant almost the opposite of what ‘gender critical’ now means, and therefore it is easy to understand why someone who is critical of gender norms and stereotypes, but who is accepting and welcoming of trans identities, might call themselves ‘gender critical’, not realising they are aligning themselves with a very different way of being.

Conversion therapy: Conversion therapy attempts to explain gender and sexuality divergence as a failure to be cisgender, heterosexual etc., and sees “success” as a client’s embracing of the preferred norms. Conversion therapy is “an umbrella term for a therapeutic approach, or any model or individual viewpoint that demonstrates an assumption that any sexual orientation or gender identity is inherently preferable to any other, and which attempts to bring about a change of sexual orientation or gender identity, or seeks to suppress an individual’s expression of sexual orientation or gender identity on that basis.” (MOU) It can include an attempt to ‘change’ a person’s gender identity by suggesting they were abused, or are actually autistic or gay (etc.), and are therefore this means they are not trans, and that other gender identities outside of the white binary don’t exist. Conversion therapy is at best, ineffective and at worst, actively dangerous.

Affirmative therapy: GC therapists will state that affirmative therapy is actually conversion therapy ( that affirming is ‘telling’ someone they are trans) and that exploratory therapy is the only way forward. A non GC-therapist would usually use the word affirmative to affirm the client in their right to explore and to use words that are right for their identity (with the therapist having no preference for the client to hold any particular identity). In the same way that we do with clients who discuss childhood abuse for example– we don’t presume to speak over a client and tell them they were or were not abused; we provide space to allow them to come to what labels (or none) and understandings of their experiences work for them. We affirm their right to do this exploration of self in a non-judgemental space. We do not seek to convert, or to act in accordance with our personal beliefs. The GC-therapists’ claim is that ‘affirmative therapy’ is “telling a client they are trans” and affirmative therapists are pushing those clients towards that identity. This would be tantamount to conversion therapy, were it happening. However, allowing an affirmative space for a client to explore all aspects of their identity, is not the same as trying to convince them of one aspect. Affirmative simply means that we do not think it is a worse outcome if a client decides, for themself, that they are not cisgender.

Exploratory therapy: Exploratory therapy is being cited in the UK as being contra to the (GC) definition of affirmative therapy. Florence Ashley writes a brilliant paper on a GC definition of exploratory therapy and why it is a terrible idea, and is essentially equivalent to conversion therapy. Proponents of exploratory therapy are reluctant to accept trans identities (particularly in young people) and instead look to find the reasons a person may be saying they are trans (such as childhood trauma etc.) to resolve these and ensure a person moves to a cisgender identity. This approach situates transness as pathology, meaning that it is in direct contravention of the MoU, which states that neither being trans nor being cis are inherently better than the other. Of course, if our clients have a trauma history they are looking to explore then we would look to do this. This is not the same as looking at trauma as ‘the reason’ someone is saying that they are trans.

A gender-critical therapist who believes that sex is immutable and more important than ‘gender identity’, will practise exploratory therapy in order to try to find (and fix) the reasons someone says they are trans – there is no therapeutic neutrality here as pathology is assumed. A therapist who believes that trans identities are valid may seek to practise in an affirmative way that does not aim to tell a client what their identity is, but provides space for the client to find their own language. Exploratory therapy (in the way the term is increasingly used) begins from a place of pathology, but although trans people are more likely to have suffered abuse/trauma, this is not the cause of our transness. To attempt to search this out and resolve something where no cause exists, is conversion therapy.