Apologies have been received from Deputy Colm Burke.

I advise members of the constitutional requirement that they be physically present within the confines of the Leinster House complex to participate in public meetings. I will not permit members to participate if they are not adhering to this constitutional requirement. Therefore, a member who attempts to participate from outside the precincts will be asked to leave the meeting. In this regard, I ask any members participating via MS Teams, prior to contributing to the meeting, to confirm they are on the grounds of the Leinster House complex.

The minutes of the committee meeting of 18 November have been circulated. Are they agreed? Agreed.

Today, the committee will consider standards for the education and training of counsellors and psychotherapists. We welcome the opportunity to gain a better understanding of the different perspectives on this issue. While there is consensus on the need for regulation, there remains considerable disagreement on the proposed requirements for entry on the registers. The publication by CORU in July of the standards of proficiency and criteria for education and training programmes was an important development. However, the committee is aware of the concerns repeatedly raised by professional bodies with respect to the framework proposed by CORU.

We hope to gain a greater understanding at today's session of the different positions in this regard. I understand concerns have been raised by a variety of professional groups. We invited representatives of two of those groups to this meeting. Other groups interested in this issue are welcome to make written submissions to the committee and they will be included in our consideration.

The meeting will be broken into two sessions. In the first, we will hear from the Irish Council for Psychotherapy and the Irish Association for Counselling and Psychotherapy, IACP. In the second part of the meeting, we will hear from CORU. From the Irish Council for Psychotherapy, I welcome Mr. Rúaidhrí O'Connor, chief executive officer; and Dr. John O'Connor, board member. From the Irish Association for Counselling and Psychotherapy, I welcome Ms Lisa Molloy, CEO; and Ms Jade Lawless, chairperson.

Members and witnesses are reminded of the long-standing parliamentary practice that they should not criticise or make charges against any person or entity by name or in such a way as to make him, her or it identifiable, or otherwise engage in speech that might be regarded as damaging to the good name of the person or entity. Therefore, if speakers' statements are potentially defamatory in relation to an identifiable person or entity, they will be directed to discontinue their remarks. It is imperative that they comply with any such direction.

I invite Mr. O'Connor to take five minutes to make an opening statement on behalf of the Irish Council for Psychotherapy.

I am grateful for the opportunity to meet with the committee today. The Irish Council for Psychotherapy represents 2,100 accredited psychotherapists across ten professional bodies in Ireland. The ICP acts as the national accrediting organisation for the European Association for Psychotherapy. While we support and have long pushed for State regulation of the profession, we must express our urgent concern that the current framework proposed by CORU would undermine the very standards it purports to protect. Our concern is not with regulation itself but with the quality and integrity of the proposed criteria. The vast majority of psychotherapists in Ireland are in private practice and our demands will not put further pressure on public waiting lists for mental health services.

CORU has suggested that its standards are aligned with best international practice. However, we can see no evidence to support this position. The proposed criteria dilute the depth and breadth of training that has long defined psychotherapy in Ireland and the standards developed by psychotherapy associations with over 40 years of experience. Should CORU’s proposed standards be accepted, it will spell an end to the profession of psychotherapy in Ireland as we know it, damage Ireland’s standing internationally and, most important of all, place the public at great risk. Psychotherapy training is, of necessity, a substantial undertaking for trainees and for training programmes. Personal therapy for trainees is essential as it mitigates the risk of therapists carrying their own unexamined biases and unresolved issues into work with deeply vulnerable people. Indeed, CORU’s counsellors and psychotherapists registration board prepared a comprehensive submission to the CORU council strongly advocating for mandatory personal therapy to be included. One of the board’s reasons was the need “to work on oneself in the context of the service being provided to a service user and with their care and safety in mind”. This proposal from the board was declined by the council on grounds including the potential impact on other professions and possible emotional distress for students. We cannot accept these as valid grounds.

The standards as set out do not reflect the nature of the discipline of psychotherapy as it is practised in Ireland, in Europe and worldwide. We would like to highlight a number of points. The first is that there has been inadequate consultation. CORU has said on many occasions that it consulted widely and developed its regulations in light of those consultations. However, there is little evidence that the responses we gave during this process are reflected in CORU’s proposed standards of proficiency. For example, information released on foot of a recent freedom of information request demonstrates that substantial numbers of submissions advocated for personal therapy for trainees and for close clinical supervision in training. We had expected that CORU would closely engage with our profession prior to the wider public consultation.

The second point relates to misalignment with European standards. The European Association for Psychotherapy standards, which have developed over three decades, are currently the standard in Ireland and Europe and have been for many years. CORU’s proposed standards do not attend to these and are placed substantially below this level, leaving Ireland as the outlier. European countries that have statutory regulation that mandate for personal therapy include Germany, Switzerland, Austria, Finland, Sweden and Malta. If the proposed standards are implemented, Ireland will have the lowest standards in Europe and Irish psychotherapists will be unable to work in other European countries without significant additional training.

Our third point is that there is an inadequate understanding of psychotherapy as a profession. CORU’s framework conflates psychotherapy with time-limited forms of intervention, particularly those provided by clinical and counselling psychologists, despite the professions having distinct scopes of practice, training pathways and theoretical foundations.

Psychotherapy is founded on a model of training requiring intensive personal therapy and clinical supervision and involving a minimum of four years of training. In not specifying any of these details as necessary to training, the regulations entirely miss the point of what psychotherapy offers and what underpins it. It would mean that education providers could argue, with justification from CORU, that they could provide a programme without these vital and essential components. Most importantly, this would mean that public safety would not be considered and protected.

We call on the Minister for Health to pause and revisit these standards in order to address the risk of substandard training that will not prepare trainees for the complex work involved in this practice and will not provide the level of knowledge and skill required by members of the public. We call for a full revisiting of the regulation of the profession, involving a genuine, collaborative and open consultation with the profession, as it aligns to best practice standards in Europe and beyond. We propose the establishment of a joint working group comprising CORU, ICP, IACP, academic institutions and service users to co-develop standards that reflect both public protection and the unique nature of psychotherapy.

In closing, we reiterate our commitment to public safety, high standards and professional accountability. Regulation must be fit for purpose. It must be informed by those who know the work, who do the work and who have dedicated their lives to ensuring that psychotherapy in Ireland remains a rigorous, ethical and healing profession. The current proposed standards are a backwards step that lower our current safe standards of training. We welcome this opportunity to address the committee and we are happy to answer any questions members have for us.

I am the CEO of the IACP, which represents more than 6,500 counsellors and psychotherapists across Ireland. I am joined by our cathaoirleach, Jade Lawless, who is the academic director of PCI College, a practising psychotherapist and a member of our board of directors for the last six years. I thank the Chair for the invitation to appear before the committee. I acknowledge and welcome our colleagues from the ICP who are attending today.

Although today’s invitation refers specifically to psychotherapy, it is not possible to discuss these standards and criteria without including the profession of counselling. The two professions are inextricably linked and the IACP, founded in 1981, has been the self-regulating body for both professions in the absence of State regulation for more than 40 years. I cannot emphasise enough the devastating damage the new standards and criteria will have on the availability and quality of mental health services if they are left unchanged. The impact of these regulations will include a reduction in the number of practitioners entering the professions and a lowering of training standards. At a time when we are seeing a mental health crisis in Ireland, people will not have access to the services they need when they need them. I will bring three key points to the attention of the committee. The first is that the Minister for Health has not yet completed the mandatory regulatory impact assessment required under legislation. The second point relates to why this is so important and the consequences of it. The third point is the solution.

On the first point, the proportionality directive applies to new rules in EU countries that restrict access to or the pursuit of regulated professions. This includes the standards and criteria published by CORU. The central issue before us today is that a proportionality assessment, which is a mandatory requirement under EU law, has not yet been completed. The IACP has engaged with the Minister and CORU since August and has been calling for this proportionality assessment to be completed. Further to this, a legal opinion provided to the IACP by Eileen Barrington SC was sent to the Minister. This opinion confirmed that this obligation has not yet been fulfilled. CORU has acknowledged in correspondence to the IACP that no proportionality assessment or regulatory impact statement has been carried out. This is confirmed by documentation released by CORU to the IACP in response to a freedom of information request. There is no mention of a proportionality assessment or reference to the EU legislation in the minutes of CORU meetings or in any other documentation received. The Minister and CORU have replied that the standards and criteria are only one part of a broader regulatory framework and therefore do not, on their own, require a separate proportionality assessment. The IACP does not agree. The requirements of the EU directive are explicit; member states must assess any new regulatory provision before it is adopted.

Why is this so important? The standards and criteria were adopted without the required analysis to evaluate how these regulations are going to affect public safety and the future sustainability of the professions. This presents a number of serious concerns.

One such concern is the higher entry threshold for psychotherapy at NFQ level 9. The impact of CORU not maintaining the minimum threshold qualification for psychotherapy at NFQ level 8, as proposed by the CORU registration board in the draft standards and criteria, has not been assessed. There has been no consideration of the impact of the removal of personal therapy, which is a fundamental safeguard that ensures ethical formation, self-awareness and client safety. CORU FOI documents show that the CORU registration board supported the inclusion of mandatory personal therapy in the training standards but that the CORU council rejected it, citing implications for other registers. This justification is inadequate and fails to acknowledge the distinct nature of counselling and psychotherapy as professions. Personal therapy is essential in training competent and ethical practitioners.

On the restrictive and clinically inaccurate scopes of practice, there has been no assessment of the consequences of the misleading and clinically inaccurate division that portrays counsellors as treating only mild to moderate presentations and psychotherapists as addressing moderate to severe presentations. Clinical supervision is another issue. This is vital to the process of ongoing maintenance of the competency of counsellors and psychotherapists. Its removal compromises the quality and safety of client care, diminishes professional accountability and undermines public confidence in therapeutic services. The final concern relates to the requirement for placements in multidisciplinary settings. CORU requires placements with on-site supervision and multidisciplinary teamwork, but counselling and psychotherapy students lack access to HSE settings where these exist.

Most available placements cannot meet these standards, creating a mismatch between CORU's requirements and the realities of the sector. This threatens programme approval and will lead to a reduction in the number of qualified professionals.

The solution is that the proportionality assessment must be completed. The solution is straightforward and consistent with the Minister's obligations under EU and Irish law. The solution is to revoke the standards and criteria adopted in July 2025; conduct a proportionality assessment as required by EU and Irish law; reopen public consultation in line with Government consultation principles and EU regulations; and provide stakeholders with the evidence, rationale and regulatory impact assessment required.

That is my piece. I thank the committee. We call on it to support the completion of a proportionality assessment, ensuring that the regulation of these professions is legal, transparent, proportionate and fully protective of the public.

Thank you, Ms Molloy. We move to questions from members. We have a rota of members. Each member will be given four minutes in the first session and then four minutes for the second session with CORU. We will go through the rota and have questions back and forth. Our first slot is a Fianna Fáil one. I call Senator Costello.

What the witnesses are asking for is not too much. What jumped out at me was the personal therapy part of it. That is a hugely important aspect of training for people. My worry would be that if such training were removed and the focus were not on it, people would bring their stuff with them while trying to deal with deeply vulnerable people.

I have just a couple of questions, the first of which is to the ICP. Two of the major concerns it raised were the absence of close clinical supervision and the insufficient amount of mandatory clinical practice hours. How will these issues affect the quality and accessibility of patient care in the short term and the long term?

My next question is to the IACP. Ms Molloy mentioned that the new CORU draft drew a distinct divide between practitioners working with mild to moderate versus severe and complex presenting patients. How will this new distinction affect patients with overlapping needs and shifting presentations of behaviour?

Before the witnesses answer, I will say that what they are asking for is very important and that we need to really listen to what they are saying because the job is important.

I would also like to know if there are regulations around online therapeutic services because I have been disappointed at times with the quality of online services, especially from private providers. I feel that, for very high costs, a very poor service has been provided. I want to know what the witnesses' thoughts are on regulations around that.

I thank the Senator for that question. As the ICP, we represent the profession of psychotherapy alongside our colleagues. We see psychotherapy as standing on a number of pillars, one of which is personal therapy. Clinical supervision is another. The length of training, in terms of the developmental aspect of training, is very important for us, as is the overall coming together of these aspects. Personal therapy is extremely significant because it provides a really deep basis for a person to be able to do this kind of work. It has to do with a number of different factors, and some of those have to do with the person meeting their own pain and suffering in a way that means we have an awareness of our own internal worlds and our own lives. That is very difficult or maybe impossible to achieve outside of personal therapy, so the understanding of personal therapy is absolutely core for us in this.

To address the second part of this, we also see that the clinical supervision goes hand in hand with that. Clinical supervision is not management supervision; it is a close supervision of our practice. Generally, that is quite a detailed and long-term relationship that takes place between a supervisor and a trainee. Not only is there a development of skill and understanding but also something that couples up with the personal therapy, because as well as being a professional engagement, it is a personal engagement.

As regards the implications of pulling that in the short term and in the longer term, existing practitioners will continue as they are. Our concern would be for future practitioners, that the withdrawal of this will mean something that is lesser, and that psychotherapists of the future, were this to go ahead, would not really be in a position to respond to and meet the levels of suffering that people have. It is a great concern for us that it would mean a qualitative change in how psychotherapy is practised and delivered and, for people who are at the receiving end of it, a much reduced service.

May I say just one additional thing about this? It is important to distinguish between interventions that are pretty short term in nature and may deal with an individual problem, which have great value, and psychotherapy, which involves looking into deeper issues that have to do with trauma. Everybody experiences trauma and, therefore, everybody who is practising as a psychotherapist requires personal therapy.

Our next slot is for Sinn Féin. I call Deputy Cullinane.

We have a very brief amount of time because we have this meeting divided up into two sessions and we will hear from CORU later, so I will just try to get to the heart or the core of the issue, as I see it. Am I right in saying that both organisations are fully supportive of statutory regulations, that is, there is no quarrel about regulation but they are raising issues from their perspectives in relation to fairness, proportionality, what they feel is workable and practicable, and questions about the consultation process, which they are essentially saying was not fit for purpose? Is that a fair characterisation of how they see this?

And public safety.

And public safety. Fine.

In relation to some of the issues the witnesses raised, I will start with the IACP. It mentioned concerns about raising the entry level from National Framework of Qualifications, NFQ, level 8 to level 9. I think what was said here was that, in the consultation period and the frequently asked questions, there seemed to be a suggestion from CORU that entry level 8 would suffice and then there was a last-minute change. Is that the IACP's view, and was any rationale given to it as to why that change was made?

That is what happened, and the rationale presented, in our opinion, is not sufficient. In the consultation process, the registration board published draft standards in which it set the minimum threshold level for entry to both professions at level 8. It cited that level 7 was too low, with level 9 being excessive for minimum entry into the profession. The IACP supported that, representing 6,500 members. The board had four years to research and come up with that position and it was heavily supported. In the final publication of the standards and criteria, the level for minimum entry to psychotherapy was raised to level 9 and, from the IACP's perspective, there was not a sufficient rationale in the published reports. CORU stated that a small majority agreed with the setting of the level at level 8 and that qualitative support supported the setting of the levels at level 8, yet the board changed that to level 9 and we are not clear as to why that was the case.

Maybe we will ask CORU.

I have just one more question because we are very tight on time, unfortunately. It makes it difficult for us, but we obviously want to hear from CORU as well. I think both organisations raised concerns about the removal of the mandatory personal therapy and a removal or a dilution of the clinical supervision. Will the ICP explain to us why that is important from its perspective? Is that the safety issue? Does that go to the core of some of the safety issues the ICP has highlighted as well?

Yes, it goes to the core of the safety issues, plus clinical supervision. Mandatory personal therapy is a feature of psychotherapy practice throughout the world. The European Association for Psychotherapy is the professional organisation overseeing the profession in over 43 countries in Europe. If mandatory personal therapy is not included in the CORU standards of proficiency, Ireland will be the only country with state regulation in Europe that has not included it. I would ask why CORU would leave it to chance that it is one of several options that a training provider could use. It needs to be mandatory to ensure that the public are not at risk.

A Chathaoirligh, from listening to both groups - we have seen the CORU opening statement as well - I think there may be a need for mediation here or some sort of intervention.

There is a possibility of some meeting of minds. We want to get this right. I think we all accept that regulation is needed. It is difficult to balance public safety, on the one hand, with what is practical in regulating, on the other. I accept that is a difficult job but I would argue that maybe there is a level of mediation or much stronger consultation and we should get off on the right foot, if we can, rather than where we are at the moment.

The next slot belongs to Fine Gael and I call Deputy Roche.

I thank the witnesses and it is nice to meet Ms Molloy again as we had a conversation last week in this regard. One would have to be concerned with the issues that have been raised. Has CORU said none of the above or is it still part of the process where they may come back and reconsider? I hasten to add that it looks like CORU feels that it has got this model right and it seems to be ignoring the submissions that were made to it. Why is CORU not facilitating and not listening to your concerns?

The standards were published in July and we have met CORU twice - once online and once in person - and we were told firmly that standards are the standards and CORU is beginning to implement the standards by meeting the training providers and giving them four years to adjust. So there is no room for manoeuvre, absolutely no flexibility and no commitment to review. There was never any consultation with ICP in advance of the draft standards being published in 2023; no consultation with the profession at all. Our 28-page written submission was given to CORU but it never reached back to us to debate or to tease out the issues and the first thing we knew about how it was being considered was when the standards were published in July. So we just have not had the opportunity.

I find that astonishing. While we all want regulation but regulation must bring clarity, not confusion. Regulation must protect the public and not dilute standards. We look forward to hearing from CORU later and to hear what its take is but there is no point in having consultation if everything that is brought to the table is rejected. There is not any institution that feels that they can get it right themselves and not to consider others that provide critical intervention such as by the ICP's members. My questions are more designed for CORU but I wanted to get a feel for where the process is at and whether it is a closed door or if there is some meaningful space for dialogue and consideration, but obviously not.

In terms of that, to support our ICP colleagues, the horse may have bolted in one sense but there is not any reason the horse cannot be led gently back to the stable. That is why we are all here and why we are having this conversation. We are very open to making this work. Our colleagues have suggested a joint working group or coming together. The IACP has asked for a pause for a revocation of the current standards and an opportunity to revisit this. Our legal opinion is being considered by the Department of Health. We are due to meet officials in the Department and they asked for additional time to consider the legal opinion. I would certainly be hopeful that the door is not completely closed on this. I really do feel strongly about the uniqueness of our profession and the difficulties and challenges that the regulator has in applying a regulatory framework to a profession that does not fit neatly within all of those boxes. Counselling and psychotherapy are not as established as other health and social care professions within the HSE, for example, which is back to the placement issue that we have raised. So creating criteria that puts an onus on trainees to achieve placements within the HSE when they do not exist is one of the key issues, and this is back to the point that we have raised regarding the absolute essential need for a proportionality assessment. We are absolutely supportive of regulation but, as the Deputy has said, it needs to be fair, proportionate and legal.

I have a number of questions but first I will summarise what I have heard from the witnesses. The key concerns are the removal of the mandatory personal therapy, the no requirement for close clinical supervision, no minimum duration for training, a significant reduction in clinical practice hours, non-alignment with EU standards, and the difference between counsellors and psychotherapists in terms of qualifications, scope and practice, and the proportionality assessment. So we have a number of significant issues to tease out but for a couple of minutes I would like to talk about the proportionality assessment that the ICP has mentioned. My understanding of the proportionality directive is that it applies to new EU rules in countries that restrict access to a profession. Since this proportionality directive was transposed into Irish law in August 2022, are the witnesses aware of any other proportionality assessments that have been carried out on newly regulated health and social care professions?

No, I am not aware but the question is more likely one that can be answered by CORU. I am aware that the directive has been transposed and that it is a requirement since 2022. It is a relatively new requirement under the EU directive but it has been in place since 2022.

I can follow up this matter with CORU in the second half of this meeting.

Thank you.

We are bringing both together and will ask CORU some of our questions. What is the basis for CORU's decision to remove mandatory personal therapy?

We received information following a freedom of information request that outlined the position of the council. The registration board was in favour of including mandatory personal therapy. Some of the rationale expressed by the council concerned the impact that it might have on other professions, and the impact that it might have on student trainees in terms of causing distress, which we strongly argue against. The whole point of personal therapy is to ensure that trainees can work through their distress so it is not projected on to their clients and that they can work without bias and with their own trauma somewhat attended to. There was a point made about access for international students, in fairness to international students. Those are some of reasons given by the CORU's council. The CORU representatives might be able to expand on that further in its session.

Interestingly, in the UK art therapists are the one cohort of psychotherapists that is regulated. The Health and Care Professions Council in the UK, among the list of standards on its website, states: "The profession-specific standards for arts therapists included in this document were developed with the input of the relevant professional bodies", and they obviously include personal therapy and close clinical supervision. The stark contrast here is just so alarming that there was no meaningful consultation with us as professional bodies.

On what the Chairman alluded to earlier, CORU is not explicitly saying that personal therapy or, indeed, clinical supervision are excluded from the proficiencies.

Yes.

Within the proficiencies there is space for reflective practice, etc., which I am sure personal therapy would fall under as a practice method. However, not mandating it, as Mr. O'Connor said, leaves it to the colleges to decide and I have heard the term "race to the bottom" bandied around more in the past few months than I ever have before. Training in this arena predominantly occurs in the private sector and where there is no requirement for uniformity across the training colleges, we are looking at a race to the bottom in that regard.

Is the cost of personal therapy for trainees built into the training programme costs or is it an additional cost for trainees?

It is accepted as part of mandatory costs that go hand in hand with college fees but it is usually a cost that trainees would handle themselves. So trainees would negotiate fees and rates with an accredited personal therapist chosen by them. The cost is not part of the college fee package.

The next slot belongs to Fianna Fáil and I call Deputy Daly.

I thank the witnesses for coming in here and I do not want to re-hash anything because the committee has a very tight timetable.

First, I ask witnesses to please keep their answers short because I want to get through a number of important questions. Do the witnesses think there is a conflation between psychotherapy, psychology and counselling? Is there this general milieu understanding in the public's mind and it is not teased out what the individual professions are?

The witnesses have 30 seconds each. I am sorry, but we are tight on time.

This is an important point. There is a conflation between these. The proficiencies as set out are familiar as a psychologist - I am a psychologist as well as a psychotherapist - and these are familiar. There is a conflation. We need to divide them out and recognise that psychotherapy is a distinct profession.

The attempt of the registration board to differentiate between counselling and psychotherapy has given us these arbitrary definition that the Deputy's colleague has referred to there in terms of mild to moderate for counselling, moderate to severe for psychotherapy, including complex. That is just not how the professions work. That is not how clients present. That is a real risk to the public. How will clients determine whether they are seeking mild to moderate support versus moderate to severe? Counselling and psychotherapy happen predominantly in the private sector. It is not within our healthcare settings for the most part. The majority of clients are self-referring. How will they know how to categorise themselves? There are many more things I would like to say about that, but I know the Deputy is out of time.

I know that. Do the witnesses think they are caught in a political crossfire here, that there is pressure on CORU to allow an opening up, not just in psychotherapy but right across some of the other allied health professionals and so on because of the shortage in this country? Do the witnesses think we are talking about a lowering of standards here?

Absolutely. I think this would be a great lowering of standards-----

For expediency.

Yes. We are getting caught. There is a confusion between psychology and psychotherapy in this. There is currently, as we know, as shortfall in the number of psychologists in the health system, whereas psychotherapists operate generally in a different system in private work. It is getting confused.

Part of it also is the model that is being enforced here. Counselling and psychotherapy is unique. While there is lots of crossover between it and psychology, for instance, the model does not align. The medical model or regulatory model does not fit for counselling and psychotherapy.

One of the pressures has been trying to get psychologists into the field of education and healthcare and the insistence by some people that you have to have a PhD to become a clinical psychologist. That is a cause for concern. That is just a reflection of mine. Maybe you are getting caught up in that expedience. I am a doctor. I do not need a PhD to see a patient. As an intern, I might be supervised for a number of years in training and that, and that might be one of the elements. This leads to a question. I will try to get both Dr. O'Connor and Ms Lawless to answer. How many psychotherapists or psychologists are on the CORU council?

There is a lay majority on the registration board. I think there were six laypersons-----

On the council.

I think there are two. Is that right?

Two out of 32 members are on the council.

I apologise. I was talking about the registration board. I am not sure about the council.

On the council, there are no representatives or organisations. There is nobody who would recognise-----

That is important. That is like getting a group of people who are not part of the profession and have no real background there. I looked through the council members before I asked that question. It has everything from occupational therapy, podiatrists, dental business backgrounds, healthcare management backgrounds, which are all great professions, but almost no one from a psychotherapy or psychology background or that. Unfortunately, that lack of understanding is probably percolating into that decision. I thank the witnesses for their answers.

I think CORU will probably clarify that there is a representative from each of the registration boards on the overall council, as well as a lay majority. I will let CORU come in on that.

The board has made a recommendation not to lower standards. The council has said yes. There is conflict there. That is the point I am trying to make.

The witnesses are all welcome here today. For full transparency, I sit on the ACI board. I was an addiction counsellor prior to becoming a Senator. I personally wholeheartedly agree with the personal therapy aspect because I do not think I would be able to see the people that I see if I did not have personal therapy with the complexities of the issues that they come in to see me with. What Ms Lawless said around putting people into moderate, severe or complex is really difficult. In the profession that I am in, we would see people who have complex issues. To think that I would have to turn somebody away and tell them they have to go to a psychotherapist who has a massive waiting list, stay in limbo and see how they manage because I cannot actually see them is awful. Do the witnesses think that CORU is looking at this through the lens of healthcare profession as opposed to psychotherapy or therapeutic counselling? CORU initially would have regulated social care and healthcare, including occupational therapists, speech and language therapists and those kinds of things.

That comes back to the point I was making in terms of understanding CORU has to work within a regulatory framework that typically fits that more medicalised professional model. Ms Molloy made a point around access to placements. The majority of the proficiencies are outlined to work within a multidisciplinary setting. As the Senator knows, counselling and psychotherapy predominantly exist outside a multidisciplinary setting. The IACP is one of the largest accrediting course providers. We accredit 26 courses for counselling and psychotherapy, 23 of which, by the way, are at level 8 and they represent counselling and psychotherapy. That is the landscape we are talking about. One of the largest course providers has approximately 200 active placements currently, only ten of which receive public funding and none of which are in a HSE setting. That is what we are talking about here. There is no prospect currently for students and trainees to work, develop and become proficient under the proficiencies proscribed because they do not have access to placement settings.

In addition to that, there is also a danger that even if this were to happen, it would be difficult to create placements in the health service for trainee psychotherapists. Because psychotherapists generally work privately, this would mean that they would be trained to do one thing but would actually end up doing another. We would see and share the sense that a trainee needs to reflect the existing practice and reality. We need to sit down and find some way that the reality of psychotherapy as it is practised today, which is an evolving thing, matches the kinds of proficiencies. We are willing and interested in having such a conversation. We are used to conversing, to negotiating with one another and coming to some common understanding. That is almost the very nature of our work.

I will build on that. This all goes to our ask for a proportionality assessment. These are all of the aspects which should be assessed and analysed to ensure that the regulation is proportionate. Setting criteria and standards that are not possible to meet is dooming the profession into the future.

I agree. In terms of patient and client safety, it opens up a door to people and to courses that are not fully robust or accredited for people to start working with people who are vulnerable and putting them in danger, as opposed to having robust measures in place that people have to meet.

I will jump straight into questions because four minutes is not very long. In both organisations' interactions with CORU, how has it justified - I think Deputy Daly mentioned it - the exclusion of personal therapy? How has it justified that to the witnesses as bodies?

It would not frame it as an exclusion. It would say that the proficiencies allow for a course to decide to include personal therapy if they choose to do that. That may be the case. The issue that we have is that when it is not mandated, courses have the option to not include it. That is the issue.

The witnesses want clarity around it to make it a bit more transparent.

We want it to be mandatory.

We cannot leave something like critical public safety to chance.

I think Deputy Cullinane mentioned possible mediation or some other mechanism to resolve this issue. I am assuming the witnesses are open to that. Have they any suggestions as to how that could be facilitated?

We have proposed a joint working group to include both professional organisations here, CORU, the academic institutions and service users to look at this together.

Has it responded to that?

We only proposed it today.

We can put that to it afterward. I have a more general question. If Ireland was to adopt what CORU is proposing, the witnesses have spoken about the risks for regulatory standards and so on. How do they think that would impact us on a practical level if we were to adopt what it is proposing?

Internationally, it would mean that future graduates would be operating at lower standards than their counterparts in other EU countries. They would, in fact, be operating at standards lower than those that apply north of the Border, in the UK and in 43 European countries. For them to be able to work outside this jurisdiction would require significant additional training.

On the broader impact, we predict that this will have an extremely detrimental effect on the future of the professions and would act as a deterrent to entry into the professions. As of the past couple of days, one of the entities that offers our accredited courses stated that it will not continue to offer its training course in counselling and psychotherapy. There will be barriers to entry to the professions. That, in turn, will lead to a situation where we will not have enough counsellors and psychotherapists to meet the demand. We do not need to mention CAMHS waiting lists or waiting lists for private practitioners. We simply will not have enough counsellors and psychotherapists to meet the demand. This will have an extremely detrimental impact on the future of both professions.

To frame the conversation we will be having with CORU in the next session, I understand that this processing has been happening for some time. How long has it been going on? If the witnesses are to go back and re-engage with CORU, my concern revolves around how much longer that is likely to take. The whole aim of this is to ensure proper regulation and scrutiny-----

Absolutely. It needs to be done right. We would much prefer to wait. We have waited for many years. It has taken four years for the draft standards to be issued. Potentially, in view of the time it could take the education providers to align with the criteria, it could be up to seven years until the opening of the registers. In such circumstances, this is the time to take a breath, pause and revisit the matter. My colleagues and I are open to collaborating and working with the regulator and the Department to ensure that the regulation is fit for purpose. We would much rather delay this and get it right than push ahead with it at the moment.

We would have faith in our ability to communicate with one another. We have well-developed ideas and priorities. We would have one or two years, or a timeframe like that, with a pause of that duration to allow us to enter into communication. Maybe some might feel they are fraught at the beginning but they may develop over time, and we can find bridging points. In many respects, there are many of the proficiencies that we would thoroughly agree with,. There is a huge level of agreement. It is on the core issues of personal therapy, clinical supervision and duration of training that we disagree. However, both organisations share the sense that we could reach a real agreement which would lead to a stronger regulated profession rather than remaining in the situation that prevails.

Following on from Deputy O'Sullivan's line of questioning, which was on the ball, I have questions about mediation back channels. One would always hope that there is some sort of back channel whereby the lines of communication are open with CORU. As Senator Ryan said, the impact on vulnerable people here is quite worrying. What amazes me about this is that we are looking at a situation where, if this goes ahead, we will be dumbing down standards. Normally, when there is proposed regulation, it improves standards. That is hard to work out. I am surprised that the proposal for a working group is only emerging today in the context of he witnesses' appearance before us. Am I correct in that?

It is a proposal we put to the committee today. These standards were published in July and we sought a meeting with CORU, but the in-person one only happened on 5 November. Our appearance here follows that. It was a result of the intransigence of CORU when we met it and its unwillingness to review and revisit these standards that we decided to put this proposal together. I will summarise its position versus our position. There is very little actual difference between what we are saying and what it is saying, except that it is saying personal therapy may be provided and clinical supervision may be provided. We are saying they must be provided. It is one word.

I would very much agree with that. Was the meeting on 5 November essentially one-way traffic? Was it a case that CORU stated that that was it - end of story?

That was our take on it. I am sure CORU has a different-----

We will see what it has to say on that matter when it comes in. I have a final general question. Where is the gold-plated standard? I often ask people if there is a particular country or region where the standard is what we should be emulating. Does anywhere come to mind?

Eleven EU countries have developed state regulations in respect of psychotherapists. They all conform to the standards proposed by the European Association for Psychotherapy, EAP. Between 90% and 100% of what EAP recommends is present. I mentioned art therapists in the UK earlier. The HCPC, which is the equivalent state regulator in the UK, has regulated psychotherapists who are art therapists. They include mandatory personal therapy, mandatory close clinical supervision, a level 9 qualification and clinical practice hours. They were developed in consultation with the professional bodies in the UK, which is the opposite to what occurred here.

The standards issue is important. Mr. O'Connor is saying that in the UK, the regulated part of the profession is meeting all of the requirements that both bodies here have asked for.

In the case of art therapists who are psychotherapists.

The profession is not statutorily regulated in the UK. There is an umbrella system whereby all the self-regulating bodies have come together. There are different levels. It is slightly different.

The scope of practice issue is important. There are psychotherapists and counsellors. Unfortunately, honestly, as a GP, the term "counsellor" means different things to different people. Unfortunately, it can mean very different standards to people accessing the service on the ground around the country. It would seem to me that the word "counsellor" is abused at times. What do the organisations see as the difference between psychotherapy and counselling? We need to know that.

This is part of the issue that we have. The proficiencies for counselling and psychotherapy are attempting to differentiate between counsellor and psychotherapists. They have done so by imposing levels of education and training which ultimately restrict access to the profession. They also impose these arbitrary definitions of mild to moderate, where a counsellor might cover short-term work, mild to moderate, and psychotherapy moderate to severe, including complex work. That is just not the case. Counsellors being trained appropriately in that they have attended clinical supervision and worked within an accredited framework - because Ireland has been self-accrediting up to this point, including clinical supervision and placement in a suitable setting - is what makes a qualified counsellor or psychotherapist. That is the definition that we are working towards.

Does a counsellor's education start with a degree of any sort?

Yes, a level 8 degree.

I need to know this, because if I do not understand it, there are plenty of other people in the public who do not understand it. A counsellor starts with a basic degree in any discipline.

No. The minimum training standards in Ireland at the moment are a level 8 degree in counselling and psychotherapy.

That is important to know, because the term "counsellor" is bandied around.

Any qualified counsellor or psychotherapist needs to be trained to a minimum of level 8, and that training needs to include a set number of personal therapy hours, a set number of clinical supervision hours and a set number of on-site placement hours.

As registered psychotherapists, we would be particularly keen about having clarity for the public on who a psychotherapist is and what the minimum requirements are.

In general, it is important that we know the distinction between different kinds of work and provision. That is not the case at present.

It is important to understand that. On the placement issue, is a bar being set for psychotherapy that simply cannot be met? There are no placements for psychotherapists in settings under the HSE model.

Not in the model proposed.

There may be one or two people somewhere who are employed as psychotherapists-----

Not in a general setting the way we know the next bunch of medical interns, occupational therapists and physiotherapists will all have placements.

No.

I apologise for arriving late. I have huge sympathy with the arguments being put forward by both organisations. This is an unusual situation to find oneself in. On the face of it, the regulator appears to be demanding less than the organisations in terms of self-accreditation - if that is right way of phrasing it - and the system that has been in place for many years with regard to counselling and psychotherapy. In the context of mandated personal therapy, most of the education or training takes place in private colleges and institutions. Is the additional requirement of mandated personal therapy in response to the framework in which education has been delivered until now and the extent to which we need to ensure publicly funded education institutions provide training and courses for both counselling and psychotherapy? Perhaps that is not clear, but it seems that these add-ons or aspects that are integral to the training process have arisen because training takes place in private colleges rather than in the public system.

The reason being that the work a counsellor or psychotherapist does is process-based. You work the human condition. It is very different to other medicalised treatments. You do not need to have broken your leg to know how to repair a broken leg, but you do need to have journeyed through your own personal process to know what it is like to be a client and to guide a client in an unbiased, objective way. Even the most well put together with perfectly attached, healthy childhood relationships have trauma and issues which resurface - I will not go into all of that. It is an integral part. It has to happen in a particular type of setting. There has to be a private, trustful relationship with somebody who is not necessarily teaching you every day and is somewhat separate to that. There is lots of rationale, research and publications as to the nature and nuances of therapy. Whether it happens in the public or private sector, it is an absolutely essential component of the training.

Should it be part of the role of the regulator or the educational provider to stipulate that as part of the training?

Currently, it is the role of the courses to stipulate. It is held tightly by the accrediting bodies that they are the standards we have. We are hearing from CORU is that is not being taken away and courses can still do that. However, with the option to leave it out, courses may experiment with reflexive practice in other ways but that is not on a par with personal therapy. It only takes one course to do it differently and for that then to become the norm. That is the harm.

The Deputy mentioned the idea of an add-in. She may have meant that in a different way, but it is core to this work. It is almost like a starting point. It is the key element. It is work from the inside out. We are not implementing something or intervening; we are receptive. Our work is very much bearing pain and suffering and relating to somebody in that. One of the major things personal therapy does, as well as what the Deputy said, is help us to listen more fully and be more available. It is a central aspect of training alongside close clinical supervision. It is what sets us apart from other kinds of approaches that have personal therapy as optional. People may in psychology choose that or certain courses may mandate a certain level but generally for psychotherapy training programmes, a high level of psychotherapy is expected. It is also built into the way we go about training. We know it costs. It is an expense, but it is a central investment in our work. If we were to practise without it, we would feel its absence. We hear all the time from professionals who perhaps do not have personal therapy as part of their practices that they feel its absence and often have to backfill that later, particularly if they work with people who are highly traumatised.

My understanding is that CORU has claimed there is no consensus on how regulation should be delivered and that it is faced with different and sometimes conflicting views. Are the witnesses aware of other professional or representative bodies that support CORU's approach to these standards and criteria?

We are not.

We can follow up on that. Is there anything else that has not been raised and that members would like to be addressed before we conclude?

Most counsellors and psychotherapists operate in private practice. To what extent do they operate in the public health system? That needs to grow, particularly when one looks at the shortage of other disciplines like psychologists and, obviously, there is the whole issue of diagnosis, which relates to psychologists but in context of therapeutic support. Will the witnesses comment on how much there is in the public sector and what their vision is for where it needs to go in the future?

There is not enough is the short answer. The profile of our membership, similar to our colleagues in ICP, is the majority are in private practice. Some 7% of our members are employed by the HSE and there are various other employments whether in an EAP or not-for-profit organisation. There are not enough counsellors or psychotherapists in primary care provision. They need to be embedded within the HSE. It really makes the point stick around the placement requirements and having to complete them within a multidisciplinary setting such as the HSE when the posts are not available. We would absolutely welcome an increase in posts within the HSE.

There is no psychotherapist grade in the public health system. There is a counsellor-therapist grade. That is something we advocate for strongly.

I thank the ICP and the IACP for their engagement this morning, for their consideration of these issues, for the detailed briefing material and documents, for all of the ongoing work in considering these issues and for advocating in this space for the best standards they think need to be in place. As stated, I am aware that other bodies are interested as well. If any other bodies or key stakeholders would like to make written submissions to the committee, we will examine them as part of our consideration of this matter. We are happy to engage with others about it and hear their views through written submissions. We will now take a five-minute break to enable our witnesses to leave and our next witnesses to take their places. Is that agreed? Agreed.

To continue the committee's consideration of the standards for education and training of psychotherapists and counsellors, I welcome from CORU Ms Claire O'Cleary, the CEO, and Ms Mo Flynn, chairperson of the Health and Social Care Professionals Council. I thank them for their engagement. I invite Ms O'Cleary to make her opening remarks.

We are very pleased to be here. CORU is Ireland’s multi-profession health and social care regulator. Established under the Health and Social Care Professionals Act 2005, our mission is to protect the public by ensuring that only those who are properly qualified, competent and accountable can work under the protected titles we regulate. We set standards, keep public registers and act when those standards are not met. We have a long record of successfully introducing regulation across diverse professions. Since opening the social workers register in 2011, we have introduced regulation to 12 professions, from physiotherapists and dietitians and radiographers to optometrists. This is a milestone week in CORU as social care workers complete their transition to regulation. The public needs to know that the people providing their care in each of these professions are qualified and accountable. That is our role.

When CORU regulates a new profession, the work is led by a dedicated registration board. Each board is appointed by the Minister for Health and includes experts from the profession as well as specialists in areas like education and public protection. They set the standards of proficiency, outlining the knowledge and skills required to enter the register. Alongside this, the board develops the criteria for education and training programmes, which set the minimum level to which students must be trained so that graduates are safe to practise. While the board sets these standards, education providers decide how best to deliver their programmes. The board then conducts rigorous reviews of each course and approves qualifications that meet the required level. Today, there are over 80 CORU-approved courses across the 12 professions we regulate and they provide 2,000 graduates a year to join our health and social care services.

Once this work is complete, a register is established and each applicant is individually assessed before being registered with CORU. After a two-year transition period, the professional titles become legally protected, meaning only those registered with CORU can use them. This gives the public confidence that anyone using those titles is properly qualified and accountable.

A registration board for counsellors and psychotherapists was established in 2019 and tasked with introducing statutory regulation to what is currently an unregulated profession. Both professions provide vital care to people at vulnerable times in their lives and those clients deserve the same confidence in their care as they would expect from any other CORU-regulated profession.

The board has been working to build a safe and fair system of regulation. When complete, Ireland will become the first country in the world to regulate both these professions, ensuring that clients have confidence in the care they will receive. This has involved research, engagement with the professions and extensive stakeholder input. Our most recent consultation received almost 700 responses, including submissions the breadth of professional bodies. While there is strong support for regulation, there is no consensus on how it should be delivered. Faced with differing and sometimes conflicting views from the professions, we must act in the best interests of public protection.

In July, we published the standards of proficiency and the criteria for education and training programmes. The standards have been broadly supported and we acknowledge that some questions remain regarding the criteria. Transitioning to statutory regulation is a significant change and it is natural that concerns arise. However, CORU has introduced regulation to many professions and we bring that experience to this work.

One area considered carefully is personal therapy. We recognise its value within counselling and psychotherapy. All education programmes must ensure that students develop the self-awareness and reflective capacity essential for safe and ethical practice and it will be up to education providers whether this includes personal therapy or another means.

As I have said, CORU exists to protect vulnerable people and we will be doing this and eliminating a real risk when we regulate these two professions. However, we are also conscious that our role to protect people includes a responsibility to ensure the workforce continues to grow.

Right now in Ireland, there are too few counsellors and psychotherapists. Regulation can help address this by creating clearer routes into the profession through approved education. This is a balancing act. If we make entry too restrictive, this could constrain the growth of the workforce in this area and limit access to care. Furthermore, delaying the introduction of regulation would also leave those people, often vulnerable, who require the support of counsellors and psychotherapists unprotected for longer. That is a risk none of us can countenance.

CORU has made significant progress in strengthening public protection across health and social care. Today, over 32,000 people have committed to providing quality care through CORU and we look forward to adding both counsellors and psychotherapists in due course.

I thank Ms O'Cleary. We will now move to members for questions. Our first slot is Fianna Fáil.

I thank the witnesses for coming in. I want to cut to the chase. I get a sense from the statement that there is political pressure on CORU to shorten training times in order to get more people onto the playing pitch. Is that a good way to set a standard for a profession?

I respectfully disagree.

I am looking at the statement, which says CORU has "a responsibility to ensure the workforce continues to grow", but should that be at the expense of standards?

Just to clarify, there is no political pressure in any way to shorten educational programmes.

I am going from Ms O'Cleary's statement, which says "we are also conscious that our role to protect people includes a responsibility to ensure the workforce continues to grow." We know there are almost no psychotherapists in the public health service.

Yes.

We also know the psychotherapists have a dispute with CORU about the standards it is proposing to apply to them. I would have thought CORU would look at the standards and the quality of the professional service that is going to be provided and then apply those standards. This would not happen in a vacuum, but it should certainly be the primary aim of regulation. However, CORU says it is conscious of the responsibility to ensure the workforce continues to grow. No one wants a restrictive practice, but if a profession is telling Ms O'Cleary's organisation, as the psychotherapists told us here this morning, that it has very considerable concerns about standards, including international standards, then I am concerned. I have heard that we want to get more people on the pitch and I have seen it in other disciplines where people have talked about psychologists having to have a PhD to get into clinical practice, but if there is such a deep conflict here between the standards the profession has operated heretofore and how part of CORU's remit is to get people on the pitch, I am worried about that conflict.

There are a couple of things there. Colleagues were expressing their concerns about the standards in terms of the education requirements but it is really important to say about the standard of proficiency and the knowledge, skills and competence we are expecting counsellors and psychotherapists to have when they join the register that there is broad support for those standards. There are some concerns about the criteria for education programmes but there is a breadth of professional bodies-----

But broad------

If I could just-----

I have a very limited amount of time. Ms O'Cleary says there is broad support, but broad support from whom? Is it from the psychotherapists?

From across all 25 professional bodies. It is important to remember today's representatives represent some professional bodies but there are 25 professional bodies. We support the standards of proficiency-----

I just want to get this clear. When Ms O'Cleary refers to the people who came here today to represent psychotherapists - I think there are 6,500 psychotherapists and counsellors and 2,500 psychotherapists, and I would imagine there are not many more psychotherapists in the country-----

No.

-----than those represented by the two groups - would she say they are not reflecting the concerns within psychotherapy and counselling?

No. We definitely know there are other representative bodies, such as for family psychotherapy, which do not use personal therapy in their education and they are members of one of the representative bodies today. We also know that personal therapy is not used in the education of cognitive behavioural therapy, so it reflects some but it does not reflect all and I think-----

That is fine. They are two different disciplines. What I am asking-----

Well, they are within counselling and psychotherapy, so it is-----

Counselling, yes, but on the psychotherapy piece, Ms O'Cleary would accept the two groups that were here represent the vast majority of psychotherapists. Would that be true to say?

Yes, they definitely-----

So if they have concerns about lack of consultation on training standards, a lowering of training standards, the personal therapy requirement, the close clinical supervision, no minimum duration of training and the clinical practice hours, does Ms O'Cleary not think it is incumbent on CORU to engage with them to try to find a middle ground on this? It sounds like there are two poles here.

It is really important to remember the purpose of the public consultation. We had a very robust public consultation process. We launched that last year with a webinar. We created dedicated resources-----

Can I just interject again? I am sorry but I am on a really tight timeframe. Does Ms O'Cleary accept the two bodies here this morning represent the vast majority of psychotherapists in Ireland?

I acknowledge they represent counsellors and psychotherapists-----

No, but-----

-----but I do not agree with their-----

-----6,500 and 2,500 or 2,300-----

Yes, absolutely.

If they have concerns as a group of professionals about not meeting international standards, does Ms O'Cleary think it is incumbent on CORU to meet them and work this through?

It is really important to note that we did meet across all 25 professional bodies-----

Ms O'Cleary is not answering my question.

But I think-----

These people specifically represent psychotherapists and counsellors. They have significant reservations about the standards that are going to be applied. Is it not incumbent upon CORU to try to find some process to mediate and come to a common purpose?

I would like to get a brief answer because we are over time.

It is important to say we did a very comprehensive public consultation process over 12 weeks and when we are looking at the standards, we are looking through this lens of public protection and what is needed for the whole system. Absolutely, we value the input from professional bodies and they are one of many stakeholders, including the wider health system and education providers. We did engage and consult all of the professional bodies that were represented here as well as wider representative bodies.

Thanks very much. We can tease that out further later on. Next is Deputy Cullinane.

Go raibh maith agat. I welcome Ms O'Cleary and Ms Flynn. I commend CORU on the work it does. Regulation is really important.

I will get into the substance we are talking about but the area of psychology is also one CORU is working on. I am very concerned about rogue operators in that field diagnosing people with autism who do not have autism at all, so it is a profession that needs to be properly regulated. I accept that it is difficult to get the balance between public safety and a sustainable profession right in regulation, but we have to put to the test what CORU says here versus what we heard earlier from our witnesses. Ms O'Cleary said a number of times that there was a "very robust public consultation process". She was in the Public Gallery earlier and she heard the questions I put to the ICP and the IACP. There is a very big gulf between what Ms O'Cleary is saying and her understanding of what a robust consultation process is and what they were saying. If we take the ICP, it said it gave a very detailed written submission of over 20 pages, or whatever it was, but there was no response. That does not scream robust and genuine consultation to me. Will Ms O'Cleary address the concerns they have raised?

Absolutely. The public consultation process, as I mentioned, was a 12-week process. We launched a webinar for all stakeholders, we provided dedicated resources and FAQs and we had a series of meetings with representative bodies through that consultation process before they made their submissions. As I mentioned in my opening statement, we received almost 700 submissions and each was reviewed at-----

We are talking about the representative bodies. I know there was a public consultation.

Yes, absolutely.

Bear with me. There are others, obviously, who would have engaged.

Yes.

We are talking about the representative bodies Deputy Daly correctly said represent a huge number of the workforce we are talking about here. What they said to us - Ms O'Cleary could hear them - was that they were told the regulations were the regulations. The regulations were presented as a fait accompli. We have to judge that against what Ms O'Cleary is telling us, which is that there was a very fair, robust consultation process. The two obviously do not square.

Absolutely. I am very happy to provide the committee with our public consultation reports, which are published on our website, extend to over 800 pages and detail-----

I am only interested in the representative groups. I will accept all the other consultations that would have happened. We are trying to home in here. This is the difference between us. Ms O'Cleary will say everything else CORU might have done was very robust, but we are dealing specifically with the ICP and the IACP, which clearly do not agree. Ms O'Cleary heard them this morning and they do not agree.

They do not agree on some aspects of the criteria for education programmes.

No. They do not agree that the consultation process is robust. Does Ms O'Cleary accept that?

I accept that they do not agree the consultation process is robust but I do not agree with that assertion. It was a 12-week process. We had a series of meetings with 25 professional bodies and other stakeholders through that public consultation process-----

As I said, I am dealing with those two groups. If I can come back to what they said, it was that they were presented with regulations that were essentially a fait accompli and told the regulations were the regulations, despite whatever concerns they would have had because-----

That might be a slight-----

-----they have outlined so many.

Changes were made-----

Sorry, I am asking a direct question which is what they put to us. Ms O'Cleary heard them here this morning that their view is they were told the regulations are the regulations and that is it. Was that the case?

Following the public consultation, we have made changes to both the standards and the criteria for counsellors and psychotherapists, which shows the public consultation was a process where we took on board feedback. Changes were made and some members have raised concerns about the-----

So what Ms O'Cleary is saying is that, after the consultation process when the standards were put in place, at that point, the standards are the standards and that is it. Get on with it.

The standards are approved by the registration board.

Is that the position of CORU?

Our position at the moment is that our standards are approved by the Counsellors and Psychotherapists Registration Board. We are now actively engaging with education providers, among other stakeholders, to ensure they understand the requirements for aligning education programmes so we can produce graduates who meet the standards of-----

I will sum up from my perspective because we understand the position of CORU. It is not the right place to start where we have such a wide gap between the representative bodies and CORU. Looking at all of the issues they have raised, such as the removal of mandatory personal therapy, the removal or dilution of clinical supervision, reduced undefined training duration and clinical errors, the raising of psychotherapy entry level from level 8 to level 9, the redefined scope of practice and lots of different issues, the gap and the gulf is very big, and that worries me. I accept that CORU is a regulator and it has to make a call. I accept that but I also ask Ms O'Cleary to look at it from our perspective. There are representative bodies and people who are working in this area who are raising very genuine concerns with us. CORU's position is over here and the representative groups are over there. I do not think having such a wide gap between the two is a good start. If Ms O'Cleary is telling us today there is nothing anybody can do about it, CORU has accepted the standards and nothing will change, I do not think that is acceptable but that is the message that is being sent out to graduates and people who are training.

The standards have been approved by the board and they are set. We are actively engaging with stakeholders because concerns have been raised about the exact things the Deputy said, such as personal therapy. The IACP and ICP both acknowledge that. We have met them since the publication of the standards and we-----

Is there potential for movement on those issues?

There is potential for engagement for clarity and understanding about the requirements of the criteria. We are very clearly saying it is the decision of the education provider how they develop their programmes. It is important for the committee to note that we had a meeting with 30 representatives of over 20 education programmes only this month in CORU to talk about the programme approval process. They are not raising these concerns. They are very keen to begin the programme approval process.

On the issue of psychology, could a note be given to the committee on where that is and what might happen next year in that space?

Yes. We are absolutely happy to do that.

I thank the witnesses. Earlier on, we had the privilege of having the IACP and ICP give their testimonials. From what Ms O'Cleary read to us from her statement, there is a gulf of difference between what they believe to be best practice and what it is that Ms O'Cleary is standing for. I asked about whether the door was firmly closed on that dialogue or need for change, which is what both groups were really pleading for. I get the sense that Ms O'Cleary's organisation knows everything about it, this is the model and they can like it or lump it. That is the impression I get.

Without fully appreciating everything Ms O'Cleary believes to be the perfect model and what it is that the witnesses earlier were demanding, I have a question I want to put to Ms O'Cleary. How does she justify the removal of mandatory personal therapy and the reduction of supervised clinical hours, given that these elements are recognised internationally as essential for safe, reflective and emotionally competent practice?

As I mentioned earlier, in terms of the knowledge and skills graduates must have from education programmes, there is broad agreement. The knowledge, skills and ability for self-reflection and managing boundaries are all very clearly articulated in our standards. In terms of the criteria for the education programmes, it is our role to ensure there is a quality system in the education programmes that consistently produces graduates who meet the standards of proficiency. It is also very important to remember that all of the education providers have their academic quality assurance processes in place. It is not the role of the regulator to mandate to an education provider how it must educate a particular cohort. In fact, it is currently Government policy to ensure we have diversity in education and diversity to access of programmes. This is something that is well established in CORU.

At the moment, there are 82 approved education programmes across the majority of publicly funded education providers in the country. All of them have gone through an extremely robust programme approval process, where members of the profession assess the education programme to determine that the graduates will meet those standards of proficiency. As CEO and registrar of CORU, one thing I am extremely proud of is that, within our professions, there are apprenticeship pathways and tertiary pathways. There are a variety of pathways to improve access because diversity across all of our professions is essential. We need to make sure the students and graduates of our education programmes reflect the service users they will be engaging with.

In terms of personal therapy, if an education provider chooses to include personal therapy in their education programmes and it demonstrates that is what the students need to do to build, learn and develop those standards of proficiency, we of course accept that because the provider is the expert. It knows what should be included in the education programme. However, it is not appropriate for a regulator to mandate and be so rigid as to tell an education provider "there is only one way you can educate this student cohort". It is evidenced from our other professions that there are a variety of ways. It is also really important to note those comments about the level of education. A level 8 academic programme is a rigorous education programme. A level 9 academic programme is a rigorous academic programme. Education providers put a lot of work into developing their programmes so there is no race to the bottom in terms of the delivery of education.

The witnesses earlier focused on some key areas, such as a lack of a proportionality assessment, concerns over training standards and personal therapy requirements, workforce impact and the risk of restricting entry into the profession. They referenced a lack of meaningful consultation. Ms O'Cleary has mentioned the word "robust" twice, and in any robust conversation, dialogue or assessment, there is a clear deficiency in those four areas between what those entities want and what it is that CORU permits. That gap needs to be bridged because, if it is not, people will be discouraged from entering into that profession.

It is important to make clear from the outset that CORU has at no point indicated personal therapy cannot be a part of training. Ms O'Cleary has very clearly outlined that we are now moving into the phase with the education providers where they will actually determine the content of the training programme, which, given the long history of training that our colleagues from the professions outlined earlier, is likely to include personal therapy. However, we also have to be aware of our increased efforts to address the diversity issues and accessibility issues.

CORU has done a lot of work over the past couple of years to open up accessibility through education programmes so people from many communities who have previously been excluded from them can actually engage in these programmes.

What we want to see is that education providers are not proscribed from developing programmes that they open up to a variety of people through having flexibility in how they deliver that programme. That is a key component for us. By not mandating it, we allow for diversity, and we allow education providers to begin to think differently about how they might deliver it. However, it does not in any way say that personal therapy is not going to be part of training.

A reference was made that there would be no clinical supervision. That is absolutely incorrect. For many of our professions, clinical supervision is a critical component of their actual training.

The work that is going on over the next couple of years with education providers will really begin to address many of the concerns raised by our professional colleagues earlier. We will see programmes develop that begin to address those concerns.

I have a few questions. First, although I rarely do this, I would like to repeat a question put by Deputy Daly because I was not satisfied with the answer that was given. It was the question of what portion of the profession is represented by the bodies we heard from this morning. What percentage would the witnesses say is represented by those two bodies?

I cannot give that detail on the exact percentage of the profession.

Is it 80%, 90% or 95%?

I can find out that information as best I can. We know there are 25 professional bodies. We also know there are counsellors and psychotherapists out in practice who are not members of any professional body because there is no requirement to be a member of a professional body. I could try to adduce that, or I could ask my team to come back to the committee, but I would not be in a position to estimate.

Would Ms O’Cleary agree that these are the two largest bodies, representing the vast majority?

Yes, absolutely.

You would accept that.

I would. I also think it is important to note that there are many practitioners who may not be members of a representative body at all.

It was summed up well earlier when people said the difference here is the “may” versus the “must”. What the speakers this morning were saying is that this should be a requirement, that you “must” do this, whereas CORU is saying it “may” do this. The fear among professionals, from what I hear, is that if it is a “may” as opposed to a “must”, then it might not happen or will not happen, and standards will fall. There are fears for quality, fears for the service provided to people and fears of a kind of race to the bottom. It sounds like a very genuine concern for people working in the profession that they want to maintain a certain standard. There is a real feeling that CORU has got it wrong in terms of where it set the bar. I know it is a balance but, from what I hear, it sounds like the bar has been set too low and that the requirement seems to be off.

I would like to hear Ms O’Cleary's response to the proposal on taking a pause on this, establishing a working group, engaging with the professional bodies and education institutes, looking at this more deeply and in a collaborative way, and really mediating a response to this. What is Ms O’Cleary's response to that proposal?

I want to clarify one thing. I reiterate my point that not all counsellors and psychotherapists include personal therapy in their education programmes. Even within the representative groups today, some of their members do not mandate personal therapy in their education programmes. It is important to acknowledge that by mandating something, you are actually changing current education.

In terms of establishing a working group, we are very much led by the direction of the Minister.

That is one we can follow up with the Minister on. The committee can consider writing to the Minister about it.

The opening statement acknowledges the need to make sure that entry to these professions does not become overly restrictive, and that is also the reason for the proportionality assessment required under EU law. Was this proportionality assessment carried out?

We have completed a regulatory impact assessment. The introduction of the criteria and standards is not the entirety of the introduction to regulation of this profession because we have other measures to take, such as the development of the code of professional conduct and ethics, which are the standards that those registered must adhere to once they are registered. Closer to the date, when we are opening these registers, the complete regulatory impact assessment will be completed, taking in all of those different elements. Again, I am very happy to share that with the committee. There was a regulatory impact assessment completed on the standards and criteria, and that is available on our website.

My question was whether the proportionality assessment was in line with the EU directive. Was that completed?

No, because it looks at the regulation holistically. The introduction of the criteria and standards is one element of the introduction of regulation of this profession. It is not the entirety of it. That will be completed when we set-----

Is the majority a part of it?

It is one part of it. That is why we did the regulatory impact assessment. We have assessed the impact of the introduction of the criteria and standards. Once we establish the date for opening the registers, we will ensure that the regulatory impact assessment is completed in advance of that. We will be working with the Department on that.

Ms O’Cleary said the consultation report has been published.

Yes, I am very happy to share links to both of those. We have also published redacted versions of all submissions received.

The CORU opening statement also referred to there being a lack of consensus on the regulations and how they should be delivered, and stated that there are differing and sometimes conflicting views. Are there professional or educational bodies that expressed different views to the ICP and IACP on personal therapy, clinical supervision or minimum training?

Regarding our engagements with the education providers, as I mentioned, we met them earlier this month. They have not raised concerns about personal therapy. We were very clear to education providers that if that is how they choose to design and deliver their programme, and they think personal therapy should be included as part of their programme or concurrently with their programme, then they are absolutely free to do that. We have advised education providers of that.

In terms of clinical supervision, the criteria that we have set out are very clear about practice education. Clinical supervision is there throughout the programme of education. All students will be engaging with a practice education team. They will be reflecting on their progress through their academic studies, particularly when they are engaging with clients and service users. That is there. It is possibly because it is named and framed in a different way. It is very important to clarify that practice education during your programme of study and clinical supervision as part of your professional practice are two different things. Even within our standards of proficiency, we clarify that students must understand the value of clinical supervision. We are in no way suggesting to this profession that clinical supervision should not happen.

I thank CORU for being here today and for all the work it is doing. For the record, I have met with the IACP, the ICP and CORU. I am quite saddened by how all this has played out in relation to what should be a really good thing, which is the addition of counsellors and psychotherapists to the CORU register. In particular, the document CORU has produced is important in providing the data that we can see on who is across the various professions, their age, their nationality and all of that. I pay tribute to CORU's work on that.

I am bewildered, if I can use that word, about what seems to be the apparent diminution of the requirements for regulating counsellors and psychotherapists. I am also confused as to how a distinction can be made between counsellors and psychotherapists when there is no clear diagnostic pathway. It is very different if I go in and have an X-ray when I have broken a bone or something similar, and I am told that. However, while some people are referred by GPs, many are self-presenting. I am not clear in my head as to how that distinction is realistic. Sometimes it is only through the course of therapy that it becomes apparent who they really need to be seen by.

I am trying to understand why we have this gulf or gap. One of the reasons put forward was the concern about the lack of diversity in the sector. I certainly share the concern about the lack of diversity in any sector. Perhaps the witnesses could talk us through the barriers they currently see in accessing training to become a psychotherapist or counsellor, and then also specify who they think is excluded at this point in time.

Absolutely. I would also be happy to speak to that piece around the diagnostics and the differentiation of the professions. We have to be realistic about the potential barrier of mandatory personal therapy. As our colleagues said earlier, this is a separate concurrent cost to the cost of your programme of education. It could be anything from €80 to €150 per session, depending on the amount of therapy. It is important to note that even within the professional bodies, where there is consensus on the requirement for personal therapy, there is no clear consensus on the amount of personal therapy.

We have to be realistic. The majority of these programmes are provided through private education, which is a cost, and there is the additional cost of personal therapy alongside that.

It is a barrier to those who do not have the means. One of the really important things about professional regulation and our programme approval process is that we will be able to help support different entry pathways into the profession. As I mentioned earlier, we have an apprenticeship pathway into social work. At the moment, we are working with an education provider to develop an apprenticeship pathway for social care. In a similar way, we have tertiary pathways from further education into higher education for some of our professions. We are actively working with education providers to develop more. We know that is a strong Government policy. That is exactly what we want to see. We want to see more pathways opened up for those coming from different socioeconomic backgrounds or minority backgrounds who may not have the funds to support themselves through these programmes of education.

I have two questions. Is ongoing personal therapy a good thing or a bad thing in terms of ongoing professional development and how people conduct their practices? If that is CORU's concern, why is it not hardwiring it into the training requirements? Rather than being this thing on the side, as it is at the moment, why is it not being hardwired into the courses?

Two things are important in all education programmes for health and social care professionals: self-reflection and self-awareness, that is, an understanding of your knowledge and scope of practice. We require that for all of our professions and that is hardwired into our code of conduct on professional ethics. Once we open the registers for these professions, not only will we have standards for entry to practice, but we will have standards for continuing practice, which we do not now have. That is a really important public safety element because the code of conduct on professional ethics requires these professionals to self-manage and to be self-aware, which is relevant where health challenges, whether mental or physical, present. It is therefore hardwired into our code of professional conduct and ethics. When we open the registers to counsellors and psychotherapists, we will ensure that public protection.

I will have to reflect on what Ms O'Cleary has said because it appears to be inconsistent with delegating to education providers the decision as to how best to provide training. That last statement seems to be at odds with Ms O'Cleary's original statement about effectively allowing education providers to decide how best to provide training.

The education providers decide how best to deliver graduates who meet the threshold standards for entry into practice, that is, their competence on day one. When professionals are on our register, we are responsible for making sure they adhere to the code of professional conduct and ethics from day one until retirement. That includes those pieces around self-management, self-care and self-reflection. The essential part of regulation is that those who are not adhering to the standards will have to face our fitness to practice processes, through which we can hold those people to account. The real risk to the public is that we do not have that accountability at the moment.

I will start by making a statement as a human. The witnesses have mentioned the word "likely" with regard to personal therapy. I do not like the word "likely" because it is very wishy-washy. That does not sit well with me. As a person who would go to a therapist, I would not feel confident in attending therapy with a professional who has not had personal therapy and dealt with his or her own past trauma. It would also be quite concerning for the therapist because I am sure things come up that would be quite triggering for a therapist who had not availed of personal therapy. The answers around this issue have been a bit wishy-washy so far. I have some questions. I would appreciate straight answers that are to the point. Why is CORU willing to implement a regulatory plan that does not comply with EAP standards? How will it address concerns with regard to the inability of Irish psychotherapists to practise in other EU countries? Did the CORU registration board look for a derogation in respect of personal therapy?

I will speak to the first question. The EAP is a professional body. It is really important to note that, while there is statutory regulation of one or other of the professions elsewhere, Ireland is the first country that will be introducing statutory regulation for both. The EAP is a professional body and not a statutory regulatory agency. We are introducing regulation. We have to be really mindful of the context. Other jurisdictions have tried this and have faced challenges. It has not worked out. We do not want Ireland to be in that position. Everyone in this room agrees that the regulation of counsellors and psychotherapists is essential. We do not want to be like our near neighbours in the UK, where one of the professions is regulated. We want to regulate all so that all will be accountable and held to the standard.

On the Senator's second question, there is an EU directive on the movement of regulated professions. We work with that. As the Senator can see from our state of the register report, over 5,000 internationally qualified health and social care professionals working in Ireland are registered with CORU, so we are very familiar with the process. I have no concerns that the introduction of our regulations will prohibit the movement of Irish graduates into other jurisdictions. Most importantly, it will still be possible to welcome graduates and professionals from other jurisdictions to Ireland to support diversity and inclusion.

Did CORU's registration board-----

I will hand over to the chair of our council on that question.

I will refer to a question that was raised earlier about representation in the council. The council is made up of representatives of each profession's registration board. In respect of counsellors and psychotherapists, there is one counsellor and one psychotherapist on the council. There is also a psychologist and representatives of all of the other professions involved. They are balanced by an equal number of lay members. I just wanted to be clear on that.

The counsellors and psychotherapists registration board presented to the council and asked for the council's views on the mandating of personal therapy under the programmes for counsellors and psychotherapists. The council considered it and, while it was in no way of the view that personal therapy should be mandated, it did not seek to stop it from being included in training. The council had concerns about the ability to measure and assess such criteria. That is where we are looking at regulation across a consistent-----

A request by CORU's own counsellors and psychotherapists to include personal therapy was rejected.

It was, yes. That was done on the basis that we were-----

That is the answer to the question I put. It was rejected.

It was rejected by the council because we felt it was contrary-----

That is the answer. The answer is that it was rejected.

I thank the witnesses for being here. It sounds like CORU is really leaning on all the other professions it regulates and trying to make psychotherapy and counselling fit into that system. That is disheartening to hear because working with the human condition is not like working with a broken leg. In the case of a medical professional, somebody who was trying to be a surgeon, you would not say that there is a pathway to do things but that it can be changed and interpreted as wanted because we are trying to diversify. People need pathways into these things but let us call a spade a spade: if CORU is trying to bring more psychotherapists and counsellors into the public space, pay is the issue. That is why they go into private practice. That is the reality. The pay does not match the amount of time and effort people put into training up and getting accredited in these professions.

What is also really difficult is that CORU is not listening to the experts in the room. They have been regulating this area. I grant that it was on an ad hoc basis and that everybody wants regulation but nobody is listening to the experts. They are the ones who have been doing this the longest and yet CORU has decided this area must fit in with everything else that it regulates and that will be how it works. My first questions for the witnesses are on transference. Do they know what transference is? If they do, what is the definition of transference?

I am familiar with the concept of transference but I am not a counsellor or a psychotherapist. I am a pharmacist by background. That is my qualification. I do not feel it is appropriate for me to start speaking to the different terms used in counselling and psychotherapy.

It is important to note that we listen to the experts. The counsellors and psychotherapists-----

The question I asked was whether the witnesses, as representatives of the body regulating this space, know what transference is.

That is the important part. The members of the Counsellors and Psychotherapists Registration Board, which is appointed by the Minister, are the experts. We have representatives-----

CORU, the regulator, does not know what transference is. Transference happens when a patient's previous experience with other people is transferred onto the therapist. A counter transference works both ways because the therapist can also put their stuff onto the patient. When there is no mandate, it leaves each provider open to interpretation when there is nothing there. The witnesses are talking about balancing and protecting public workforce growth. How does CORU assess the workplace impact of raising psychotherapy entry to level 9, given the acknowledgement of a national shortage? It talks about pathways, accessibility for people and diversity. A level 9 course is not quite accessible to a lot of people. It is incredibly expensive. How did CORU come to that conclusion?

The rationale for changing the qualification to level 9 was as part of the public consultation process. That is what I am trying to make sure the committee is aware of. The public consultation process took on board views of stakeholders and following-----

Those were some views, though not all views.

Yes, but it is also important to note that consultation is about seeking views. That is what you do. It is not necessarily about reaching consensus. I go back to the Senator's original question. Through the public consultation process we made changes to the standards, proficiencies, knowledge and skills for psychotherapists. That was feedback received in terms of articulating that knowledge and those skills. When those standards were looked at in the context of the competence of graduates from that programme, the articulations of the standards and the knowledge and skills defined aligned with the level 9 NFQ framework. That is the rationale. It was not about just arbitrarily changing the level of the education programme. It was looking at the knowledge, skills and competence of that programme, and what academic requirement would be required to reach that. That was the rationale for level 9.

If that is the rationale, why would CORU not take that rationale into clinical therapy and personal therapy?

As I have said, we are not preventing personal therapy. For the absolute clarity of the committee, we are not preventing that happening in any away. In terms of the clinical supervision element, as I mentioned, the supervision is there through practice education and through the integration of theory into practice and feedback when engaging with clients and service users. Understanding what clinical supervision is as a graduate and the requirement for ongoing engagement is separate. It is when you are on the professional register.

That is not necessarily the case. There are courses where you have clinical supervision that coincides with learning at the same time. It is not just an add-on afterwards when you become a graduate. You engage in clinical supervision as you are learning and going through the course.

That is within our criteria, and we refer to that as the practice education.

That is clearly defined.

Yes, absolutely clearly defined, and I am happy-----

It is clearly defined in the document.

Yes.

Then why is everybody arguing if that is the case?

I think it is because of the change in terminology. There is a body of work for CORU to do in engaging with our education providers and professional bodies in the context of understanding the terminology we use. I am also happy to contact the Senator directly and clarify the criteria that refer to that ongoing practice education and the requirements for education providers to understand the suitability of students through their programme of education. We require education providers to have fitness to practice requirements within the programme of education. If something arises for the students through their programme of education and it impacts their ability to progress, there should be mechanisms to support that student.

Like personal therapy, probably.

Again, it is for the education provider to decide that.

It is important to say that for all our professions, there is a requirement for clinical training and practice through their education programmes. The concept of clinical supervision and clinical practice is within all of the professions and is what we would expect for any education provider in any of our programmes. As Ms O'Cleary rightly said, the language may be slightly different, but the core concept is the same and will be expected in this profession as in others.

I have four speakers remaining, Deputies O'Sullivan, Cahill, Quaide and Aird. We will conclude at approximately 12 noon.

The longer I sit here, the more confused I get. I will start with a proposal made by Deputy Cullinane about earlier mediation. It was followed up by the Irish Council for Psychotherapy which said it would propose a working group. Is that something CORU is open to or do the witnesses feel they have spent enough time on this, and it is full steam ahead? At this late hour, is there potential for further mediation?

We have had the public consultation process, as outlined in our public consultation reports. We have taken feedback on board and made changes subsequent to the public consultation reports. All of the views in the public consultation were considered by the registration board. That is important to say. The registration board includes members of the profession. It includes members who are experienced in healthcare management. It includes members who are involved in the education of these professions. Those were all of the perspectives in the room when the board was considering the feedback through the lens of public protection, and what that threshold is. It is not in any way the case that CORU is trying to shoehorn one regulatory framework for another profession. We are ensuring that we are an agile and proportionate regulator and the standards we set ensure students who graduate from the programmes meet the standards but allow education providers the flexibility to research and innovate. Again, as I mentioned, it is Government policy that we have pathways to education. It is absolutely not the case that we are trying to shoehorn in at all.

It was probably unfair of me to put it in those terms, but I want to be clear on the answer. Is that a "Yes", "No" or "Maybe" to the proposal for a working group?

For me, we have completed our public consultation. We have published our standards and are actively engaging with education providers.

I turn to the next step going forward. Can CORU make that decision independently or does the Minister have some input into this, in terms of letting things proceed? How does the process work?

If the Minister has a particular view and requests us to do something, we will respond to the Minister in that case.

I do not know if it is suitable for me to suggest, but maybe the committee would consider the suggestion made by the Irish Council for Psychotherapy that further mediation, if that is the right word, be considered. So much time was spent on this in the past few years. Four years was mentioned. One of the other witnesses mentioned that it might take another substantial amount of time to get education providers to align with the requirements. I am not generally for kicking things down the road but I think this is-----

We will consider writing to the Minister and requesting that. Perhaps we can consider it at our next private meeting.

My second question concerns personal therapy and clinical supervision. One of the witnesses said that it is just a one-word difference between "should require" and "must require." I was a schoolteacher, so I am probably not the best person to comment on medical stuff. As part of my training, we had 200 hours of placement. It was supervised. That was specified by the Teaching Council, which is the regulator of teachers. I still do not understand.

We specify a number of hours that must be engaged with clients. Some of that has to be supervised to observe the student demonstrating knowledge, skills and competencies. Any inclusion of personal therapy, as was outlined, is concurrent to that. It is not part of that requirement. The Deputy is right. The education provider needs to build a system where standards are taught, understood, demonstrated and assessed. We have the requirement for placement hours, some of which are directly observed, in our criteria. That is there, as it would be for the majority of professional academic programmes.

The difficulty I have is that we had Bernard Gloster before the committee three or four weeks ago. We were speaking to him specifically about the area of disability services and how many of our fourth-year speech and language therapists and occupational therapists have to go to England, Wales and other places abroad to fulfil their placements. It looks like he is more or less mandating that. He said here that before he leaves next March, he will mandate that this is a requirement. Here, it seems to be we are moving in the opposite direction.

These are slightly different pieces. If personal therapy were included in an education programme as a requirement of an education provider, it would be separate from the education programme. I think what Bernard Gloster was speaking about was ensuring that for CORU-approved programmes, we have more students and we broaden access to practice placement.

Personal therapy, if it were included, would be separate from the 200 hours we are requiring.

I thank the delegates from CORU for being here today.

Senator Ryan’s question on transference and counter-transference was very on point and got to the kernel of much of what we are contesting here today. My question is not a "gotcha" question; it is about the core of psychotherapy. As much as I do not want to personalise this issue, I believe the failure on the part of a representative of CORU to answer the question today on this subject really highlights the gulf that exists between CORU and the professions of counselling and psychotherapy that it is trying to regulate.

I was trying to reflect on the impasse that has occurred between CORU and the professions in recent weeks. Almost always when we encounter political resistance on an issue, there is some financial cost implication behind it. What is very difficult to understand in CORU’s regulatory proposals, which are causing so much concern, is the rationale. It is just not clear. Why has CORU set its face entirely against the disciplines of counselling and psychotherapy by insisting on the removal or dilution of core aspects of them, namely, the mandatory personal therapy element and the supervision requirement? There is almost unanimity within the disciplines on these core aspects of professional standards and professional identity.

I acknowledge the comment on transference. As I have said, my professional background is not in counselling and psychotherapy. I am the CEO and registrar of 12 professions. Two of us were invited here. Had I had the opportunity to have another colleague here, I absolutely would have had a member of the Counsellors and Psychotherapists Registration Board here to answer those profession-specific questions. Our model works as it does because we do have professional expertise, but it would be unrealistic for me to have expertise in every profession I regulate. I wanted to clarify that. The reason we do not have a counsellor and psychotherapist sitting here at the table with us is simply down to numbers.

On personal therapy, as I mentioned earlier we are very much creating agile criteria for education providers. We know that education providers have the knowledge and expertise to develop and deliver the education programme. Within our criteria there are specific elements whereby those involved in the development and delivery of the education programme must have the professional expertise to deliver it. There must be academics from the profession involved in the development of the education programme and there must be practitioners from the profession involved in its delivery. If the academics who design and deliver the programme feel personal therapy is the appropriate way for students to develop the skills around reflection, assessing boundaries and self-awareness, it should absolutely be included. As I said earlier, however, it is not for the regulator to mandate a particular profession or education provider to deliver its education programme only in a given way.

How did CORU engage with the ICP and IACP, which represent counsellors and psychotherapists, prior to the publication of the standards? How many meetings did it have with them? How did those meetings go from CORU’s point of view? Was there dialogue or a back-and-forth?

We have a very positive working relationship with the professional bodies, which met earlier today. At the start of the public consultation process, we had a webinar through which we engaged with all stakeholders. During the 12-week public consultation process, before the various professional bodies made their submissions, we met them to answer any questions on particular standards or criteria. Subsequent to the publication of the standards, we met the IACP twice. I met the CEO in person myself and we had an online meeting with education providers of the organisation. We met the ICP twice, once online and once in person.

Is CORU’s position fixed now? There has been such strength of feeling, and very compelling arguments have been made today by both the IACP and ICP. There has been a huge reaction online and in other media by people practising in the professions concerned. Is there any sense of CORU acknowledging this and taking on the concerns?

From our viewpoint, the Counsellors and Psychotherapists Registration Board has approved the standards and criteria. They are published and we are working with education providers. For me, it is about ongoing engagement with all the relevant stakeholders. We have 82 approved education programmes across the majority of publicly funded education providers in Ireland. Therefore, we have a very robust programme approval process. We have a requirement that academics and members of the profession be involved in the development and delivery of the education programme. Also, members of the profession are involved in the programme approval process. Academics and practitioners review the education programmes, meet the education providers, students on the programmes and those providing placements to students, and ask questions and interrogate what we have been told. That is an extremely robust process. That will provide the assurance-----

Why was it not possible to have somebody with a background in psychotherapy here today?

It was simply due to numbers. The chairperson of the council and I were nominated. If we had been allowed to bring more people, of course we would have invited members of the board.

May I answer? Our standard practice is to invite two witnesses. We had two witnesses from each of the organisations this morning. If an organisation wants to make an exceptional case for a third witness, we are open to it, but the standard practice is to have two. When several organisations are involved, it is easier to engage when there are just two from each. It is just the nature of it.

To be very clear for the committee, it is not that we did not want a member of the profession here.

Someone could have been nominated-----

Absolutely, but we were very mindful that the question around the council decision around personal therapy would come up. We thought it was very appropriate for the chair of the council to be here to answer that question for the committee.

It is a matter for each organisation to decide on its representatives and whom it believes is the best fit.

Absolutely.

A large number of stakeholders and individuals are interested in this. We are happy to receive written statements from other key stakeholders. Deputy Aird has the last slot.

I thank the Cathaoirleach for allowing me this opportunity. I have just three questions to ask. The first relates to the Irish council for physiotherapy and the Irish association for counselling and physiotherapy. How consistent are current education and training standards across physiotherapy disciplines? What gaps remain that could impact on patient safety or the quality of care? Second, what is the timeline for establishing statutory registration for physiotherapists, and what is the alignment with international best practice? Third, how does CORU propose to balance the need for excellent professional standards with accessibility for clients seeking mental health supports, particularly in rural areas, without compromising public safety?

Was the Deputy referring to psychotherapists as opposed to physiotherapists?