FAQs on Counsellors and Psychotherapists - Standards of Proficiency and Criteria for Education and Training Programmes
Do the Standards of Proficiency apply to all modalities through which counselling/psychotherapy is practised?
The Standards of Proficiency for both professions detail the threshold level of practice for anyone who wishes to practise as a counsellor or psychotherapist. There are no specific or particular standards that reflect the different modalities through which either profession can be practised. Education programmes can continue to have a particular focus on a modality of counselling or psychotherapy, as long as they can demonstrate how the programme delivers on the threshold standards of proficiency.
In drafting the standards for both professions, the Board has attempted to articulate standards that are high level and outcomes focused. This means that they can be applied across a range of different practice environments and demonstrated through differing practice modalities.
What is the relationship between the Standards of Proficiency and academic standards developed for counselling and psychotherapy programmes?
There is no relationship between the Standards of Proficiency, as set by the Registration Board, and academic standards developed for counselling and psychotherapy programmes. This reflects the distinct purpose of the Board as the profession regulator and its overriding concern for ensuring the protection of the public. The Registration Board’s statutory remit and function in setting its Standards of Proficiency is to ensure that all registrants meet a threshold level of professional knowledge and skill in order to practise safely.
The Registration Board does not have a role in the academic accreditation of education and training programmes. Profession regulation is distinct and different from academic accreditation and, as such, there are different requirements for both.
How did the Board determine the threshold qualification level for entry to the register for both professions?
The threshold level of qualification for entry to the register refers to the minimum level on the National Framework of Qualifications (NFQ) a programme must be designed in order to deliver on the Standards of Proficiency.
The standards provide the benchmark by which the Board determines the threshold qualification level. In setting the threshold qualification level, the Board initially reviewed the Standards of Proficiency it had drafted for each profession in the context of the NFQ Level Descriptors. The Level Descriptors identify the knowledge, skill and competence a graduate from a programme must be able to demonstrate at each level on the NFQ.
In assessing the standards against the NFQ Level Descriptors, the Board considered the language through which the standards were articulated and the requirements around the practice of the profession. The Board reviewed its standards against the requirements of Level 7 and concluded that NFQ Level 7 did not reflect the demands of practice or depth of engagement with service users required at threshold level for both professions. It also concluded that the requirements articulated at Level 9 went beyond the threshold level standards defined by the Board.
The descriptors at Level 8 reflected the demands of each profession and articulated the range and application of knowledge and skills required to practice at threshold level. Education providers can continue to deliver qualifications above the threshold level 8, that deliver on the threshold standards required. The Board also recognised that the counselling and psychotherapy professions should reflect Irish society and the people they serve. Therefore, the Board factored into its decision that there should be an opportunity for all members in society to access higher education and enter these professions.
Is there a requirement for personal therapy included in the Board’s draft Criteria for either profession?
Personal Therapy is not included as part of the requirements set by the Registration Board. In setting its Criteria for Education and Training Programmes, the Registration Board must ensure that the requirements it sets are directly linked to the achievement of the Standards of Proficiency. The function of the Criteria is to ensure that an education provider has the appropriate systems and mechanisms in place to demonstrate that students graduating from the programme have achieved the standards of proficiency and have been assessed and are proficient in the practice of the profession to enter onto the register and practise safely and autonomously.
Personal Therapy is not connected with the assessment of the student and does not contribute to an assessment of whether a student has achieved the standards of proficiency. Therefore, the Registration Board is not in a position to set any requirements around Personal Therapy. However, it is important to note that education providers, as part of their programme requirements, are able to stipulate whether a student on their programme is required to undertake a set number of Personal Therapy hours.
What is meant by ‘on-site’ placement supervision?
Practice Education is an essential component of pre-registration education and training, through which a student has the opportunity to experience and engage in the practice of the profession in a safe and managed environment.
The purpose of practice education is two-fold:
Firstly, it is a matter of public protection. In providing the opportunity for a student to experience and practice the profession – at the appropriate level of skill dependent on his or her experience on the programme – it facilitates the translation of theory into practice which thereby ensures the quality of the future workforce, positively impacting the standard of care provided to service users.
Secondly, engagement in practice education allows a student to demonstrate achievement of the standards of proficiency and, in so doing, gain proficiency in the practice of the profession he or she is training in. It is for both these reasons that it is essential that a student on placement has appropriate supervision when he or she is on-site in the placement setting.
A supervisory presence at each placement site does not mean that a student is observed for the entirety of the placement experience. Rather, it means that when on-site, the student has access to a practitioner of the profession the student is training in and has been trained by the education provider as a supervisor – to provide appropriate guidance, support and training to the student or a small number of students.
In short, on-site supervision, as defined and practised in regulated professions, is the process through which a practitioner is given responsibility for the support, training, learning and development of the student to ensure that the student progressively develops his or her proficiency, achieves the standards of proficiency and ensures the protection of service users a student comes into contact with. This is a responsibility that can only be undertaken by a professional situated on-site in the placement setting.
How does on-site placement supervision of a student differ from clinical supervision?
Clinical supervision is understood and practised in the counselling and psychotherapy professions as a formal process of professional facilitated reflection on clinical practice and experience that contributes to individual development. In the context of practice placement arrangements as they are currently delivered in education and training programmes for the professions of counselling and psychotherapy, clinical supervision is a relationship established by a student with a clinical supervisor outside of the practice environment the student is working in.
On-site placement supervision differs from clinical supervision in both its purpose and structure.
Purpose of On-Site Supervision
The purpose of on-site placement supervision is to ensure that the student has access to a practitioner of the profession the student is training in to provide appropriate guidance, support and training. This guidance, support and training is directly related to the student’s professional development of the threshold skills and knowledge required to practice the profession safely and the associated assessment of the student’s progressive achievement of the standards of proficiency.
Structure of On-Site Supervision
Each student at a placement site must be assigned an on-site supervisor. It is the responsibility of the placement site to identify supervisors on their site. The education provider is responsible for ensuring that the supervisors identified are trained and suitably proficient in the practice of the profession to undertake supervisory responsibilities.
An on-site supervisor must be:
- of the profession the student is training in;
- situated in the placement setting the student is undertaking his or her placement in; and
- trained by the education provider in how to assess students’ achievement of the standards of proficiency.
The responsibilities of an on-site supervisor will include, for example:
- working with the student in the development and implementation of a Placement Learning Plan
- observing the student in practice (where appropriate)
- providing feedback and guidance to the student in relation to his or her achievement of the Standards of Proficiency
- leading regular supervisory meetings with the student
- completion of administrative duties – e.g. signing off timesheets
- engaging with a member of the programme team (from the education provider) throughout the course of the placement to assist with the assessment of the student’s achievement of the standards.
On-site supervision is therefore a formal process between the student, the practice placement supervisor and the education provider. The Board’s Criteria details its requirements around on-site supervision. The Board does not stipulate any requirements around student engagement in clinical supervision.
What is the relationship between an education provider and a placement site?
The education provider is responsible for identifying suitable practice placement sites where each of its students will undertake practice education in.
As articulated in the Board’s Criteria, the education provider must have clear requirements in place for the suitability of placement sites and a clearly articulated process around how these requirements are applied in the selection of each placement site. In evaluating the appropriateness of the site, the education provider is ensuring that the environment is appropriate to provide a student to exposure and practice of the profession and the opportunity to develop and demonstrate achievement of the standards of proficiency.
For all placement sites where a student is undertaking a placement, the education provider should have a written agreement in place with the site that identifies the responsibilities of all parties involved in the practice placement (i.e. the placement site, the education provider and the student).
At each placement site, the placement provider is required to identify suitable on-site supervisors. The education provider is responsible for ensuring that the identified supervisors are appropriate and that each is trained in understanding the purpose of practice education, their role on-site, how to assess student achievement of the standards and how to provide feedback to students.
Throughout the course of the practice placement, there is on-going engagement and communication between the education provider and the placement site. Typically, the education provider assigns a designated person from the institution (sometimes referred to as an academic mentor or practice tutor) to engage with the student and the on-site supervisor in one-to-one meetings with each and, as well, in a group meeting with all three.
It is important to note that the education provider does not determine the service users a student will engage with during the placement experience. This is left to the professional assessment and judgement of the supervisors on-site. The education provider approves the placement site (on the basis of the selection criteria it has identified); it does not approve individual service user allocation to students.
Do Placement Supervisors need to be on-site?
Yes. Given the role and responsibilities placement supervisors have in respect of providing support and guidance to students, as well as assessing their achievement of the standards of proficiency, they are required to be on-site and accessible during the course of the student placement experience.
It is important to highlight that practice education is a developmental process whereby a student progresses towards independent practice. Different levels of on-site supervision will be required at different stages. A student, for example, on his or her first placement would require specific direction, support and guidance around all aspects of practice. Conversely, a student in his or her final placement, practising at a higher level of proficiency, would not require the same level of support and guidance.
Does the on-site supervisor need to be of the profession?
Yes. The responsibilities an on-site supervisor has in relation to practice education, which includes providing professional support and guidance to help a student develop proficiency in the practice of the profession and the assessment of whether a student has demonstrated achievement of the standards of proficiency, can only be appropriately undertaken by a member of the profession the student is training in.
It is the responsibility of the education provider to ensure that all supervisors are of the profession the student they are support is training in.
What qualifications or training does an on-site supervisor need to undertake the role?
The Board does not stipulate any specific qualifications that an on-site supervisor is required to hold to undertake on-site supervision of a student.
The Board’s Criteria requires that any individual involved in the teaching, supervising and/or assessing of students – which includes on-site supervisors – have the appropriate qualifications, expertise and knowledge to undertake this role.
In time, following the ending of the transition period (2 years following the opening of the register), the Board’s requirement under criterion 2.13 that all supervisors must be registered with the appropriate registration board, comes into effect.
In terms of training, it is the responsibility of the education provider to provide regular support and training for supervisors. This training must include guidance around the assessment tools and methodology the education provider uses on placement, how the supervisor is to complete the training, along with training on providing feedback to students during placement.
All supervisors must have completed the training provided by the education provider before they can undertake responsibility for a student on-site.
What type of student assessment is the on-site supervisor responsible for?
The on-site supervisor is responsible for the assessment of the student’s achievement of the standards of proficiency. This determination is made on the basis of whether, in the supervisor’s professional opinion, having observed the student in practice and through supervisory engagements during the course of the placement, the student has demonstrated that he or she has met the identified proficiencies for that placement. (Each placement experience will likely have a different combination of proficiencies a student is to achieve.) Given the supervisor is based on-site with the student and has observed the student in practice, he or she is best placed to determine whether the student has achieved the required level of proficiency.
A supervisor does not undertake this task in isolation. The supervisor is assisted in the assessment of the proficiencies by a member of the programme placement education team from the education provider. It is important to highlight that the supervisor is not involved in the academic assessment of a student and does not make the judgement as to whether the student has passed the practice placement module. These decisions are made by the education provider.
The sole assessment responsibility of the supervisor is to professionally evaluate – on the basis of the observed evidence on-site – whether a student has achieved the standards of proficiency.
Do all hours stipulated in Criterion 2.2 have to be undertaken on site in a placement setting?
Reflective of its role in pre-registration education and training programmes and that practice placement is an academic module integrated into the programme, practice placement education is constituted of two parts:
- Experience in the practice of the profession on-site in a placement setting; and
- Academic elements associated with the delivery of an academic module.
This division is reflected in the hours requirement articulated in the Board’s draft Criteria for both professions.
The total number of practice placement hours includes the hours that a student must be on-site and engaged in all elements of the practice of the profession – what is referred to as service user contact hours – and the hours that a student is engaged in other elements of practice education, such as:
- Research and reading time for academic work associated with practice education;
- Completion of academic placement task(s) – e.g. a placement portfolio;
- Periodic days attending placement workshop sessions provided by education provider;
- Attendance at supervision meetings with a supervisor.
Taking for example, the Board’s proposed hours for counsellors.
The Board has stipulated that students must complete 450 hours. A minimum of 300 hours out of this 450 hours are required to be on-site in the practice of the profession (i.e. engaging with service users, planning for therapeutic sessions, completion of reports and other administrative duties).
The other 150 hours may be related to student time engaged in the academic elements of practice education. The entirety of this time does not have to be spent on-site at the placement site – e.g. a student would not be expected to attend a placement site to complete an academic assignment associated with his or her placement experience.
Can time spent in clinical supervision contribute to total placement hours?
No. Supervision, as part of practice education, is concerned with ensuring that the student has access to an on-site practitioner of the profession the student is training in to provide appropriate guidance, support and training. This guidance, support and training is directly related to the student’s professional development of the threshold skills and knowledge required to practice the profession safely and the associated assessment of the student’s progressive achievement of the standards of proficiency.
This is distinct from clinical supervision. The Board does not stipulate in its Criteria any requirements around clinical supervision. More detail on the distinction between clinical supervision and on-site supervision can be found above.
Why was there a difference made between the total number of hours for counsellors and psychotherapists?
In setting its proposed placement hours, the Registration Board considered the distinct practice between the professions of counselling and psychotherapy.
In particular, the Board reflected on the differences in the length and type of engagement with services, concluding that psychotherapy relationships with a service user tend to take place over a longer period of time than counselling engagements.
Additionally, and connected with the length of service user engagement, the Board also reflected on the differing types of presenting issues that counsellors and psychotherapists encounter, noting that psychotherapists can work with a wide range of complex presenting issues that vary in severity and present a wide range of diagnoses.
The Board also considered the differences between the professions as articulated in its draft Standards of Proficiency and the necessity for sufficient practice placement hours in order for students to demonstrate achievement of the standards of proficiency. For example, the draft Standards of Proficiency for Psychotherapists requires:
5.11 – Be able to work therapeutically with a wide range of presenting issues of varying degrees of complexity and severity, and across a wide range of diagnoses in order to facilitate service user insight and long term change.
The comparative standard for counsellors requires:
5.9 – Be able to outline typical presentations from mild to severe presenting concerns and be able to treat presenting concerns, within the limits of their knowledge, skills and competence or refer to another professional.
It is for these reasons that the Board proposed a difference in the practice placement hours requirement between counsellors and psychotherapists.
What is meant by ‘supervised service user contact’?
Supervised service user contact refers to the period of time that a student is based on-site engaged in the practice of the profession, where there is appropriate supervision available on-site to provide guidance and support to the student.
This period of time of service user contact is intended to reflect the holistic experience of practice and, as such, includes all the elements that does into the delivery of either counselling or psychotherapy, including:
- Direct engagement with service users and the delivery of therapeutic care
- Planning time in advance of therapeutic sessions, including research
- Completion of reports and other administrative duties
Supervised service user contact does not mean that the student has to be observed for the entirety of this time. It means that the student spends the time in a placement setting, where there are appropriate on-site supervisory arrangements in place, engaging in all elements of the delivery of counselling or psychotherapy.
What is meant by ‘direct observation’?
Direct observation refers to the amount of time the assigned on-site supervisor directly observes a student in the practice of the profession. Practice Education is an integral and central means through which a student is able to develop his or her professional proficiency towards being able to practice as an independent, autonomous practitioner. This determination of proficiency is made on the basis of the student’s achievement of the standards of proficiency which are assessed during the course of a student’s practice education.
Observation of a student in practice is essential for the assessment of whether a student is proficient in the practice of the profession. It would not be possible to determine whether a student has achieved a significant number of standards without direct observation. Taking the draft Standards of Proficiency for Counsellors as an example:
5.22 – Be able to orient service users to the counsellor approach and explain the responsibilities of the counsellor in a therapeutic relationship.
It is important to note, however, that other standards may not require direct observation with a service user to assess whether the student has achieved and met the required standard. Taking the draft Standards of Proficiency for Counsellors as an example:
5.19 – Be able to articulate the necessity of engaging in clinical supervision to support, sustain and improve practice.
Finally, it is important to highlight that multiple standards of proficiency can be assessed during a single observed session between a student and a service user.
How can direct observation of a student be undertaken?
There are a range of potential methodologies which could be utilised by a supervisor undertaking direct observation of a student during a practice placement. These methodologies may include:
- Observation: this would involve a supervisor sitting in on a therapy session between a service user and a student in an observational capacity, but not interacting and engaging in the session itself
- Co-Therapy: this wouldinvolve a supervisor actively partaking in a session jointly with the student and a service user
- Two-Way Mirrors: this would allow for a supervisor to directly observe a student engaging with a service user without being a physical presence in the room
- Transcription: this would involve formal written record of a session being provided to the supervisor by the student which would include the verbatim discussion between the student and service user and any emotional or physical observations that would impact the understanding of verbatim account.
- Video/Audio Taping: this would involve the session between a student and a service user being recorded and available to the supervisor to review following the session.
It is recognised that there is particular sensitivity in undertaking this practice by the very nature of the therapeutic relationship dynamic developed between a counsellor or psychotherapist and a service user and that any method of direct observation will require the explicit informed consent of the service user.
Are there any requirements around how a programme should be structured?
No. The Registration Board does not stipulate how an education provider should design and structure an education and training programme. Taking the example of other professions CORU regulates, there are a range of programme designs which have been approved, including part-time and full-time programmes, programmes that are partly delivered online and programmes that run over 2 years (Level 9 Masters programmes), 3 or 4 years (Level 8 Bachelors programmes).
The education provider has flexibility around how it designs and delivers its programme. The Board’s requirements, as detailed in its Criteria, is that the programme has the systems and mechanisms in place to continually ensure that graduating students have met and achieved all the standards of proficiency and are able to practice safely as autonomous practitioners upon entry to the register.
The Board does not set academic requirements for programmes. This does not fall under the Board’s regulatory remit or responsibility.
Does the Criteria include minimum level entry requirements for entry onto a programme?
No. The Board does not stipulate admissions requirements for entry onto an education and training programme. All minimum entry level admission requirements are determined, set and applied by the education provider.
Under Criterion 3: Programme Admission of the Board’s Criteria, it requires that the education provider clearly articulates its admission requirements and that there are procedures in place for ensuring the stated entry criteria – that the education provider has determined – are consistently applied to all applicants.
Are there any arrangements for the Recognition of Prior Learning and Experience?
Yes. Criterion 3.3 of the Board’s Criteria articulates that education providers, if they wish, can allow for applications for Advanced Entry and the Recognition of Prior Learning and Experience (RPL).
If an education provider’s policy is to offer Recognition of Prior Learning and Experience to applicants, there must be a clear process in place that includes details of:
- The mechanism the education provider has for evaluating the impact of applying RPL on the applicant’s achievement of the standards of proficiency; and
How the education provider ensures that an applicant will meet all the standards of proficiency by the completion of the programme (i.e. how any deficits in achievement of the standards of proficiency will be addressed).
Will there be a period of pre-accreditation following successful completion of an approved programme before registration can be granted?
No. The Counsellors and Psychotherapists Registration Board operates, as required under the Health and Social Care Professionals Act 2005 (as amended), a qualifications-based register. This means that for new graduates within Ireland, the only means for entry onto the register, once it is opened, is through holding a qualification that has been approved by the Registration Board as meeting all its requirements under its Criteria and Standards of Proficiency.
The Registration Board has no legislative remit to require any post-qualifying training for registrants. In order then to ensure the protection of the public and the integrity of the professional register by guaranteeing that all registrants have met the threshold level of safe practice, it is essential that all approve programmes graduates have demonstrated achievement of all the Board’s Standards of Proficiency.
Is there a list of qualifications that can be used during the grandparenting/transition period?
During the grandparenting/transition period, there are a number of routes through which an existing practitioner can apply to join the register.
One of these routes, in addition to currently practising the profession and having been in the practice of the profession for 2 of last 5 years from the date the register opens, refers to an applicant holding one of what are called ‘Schedule 3 qualifications’. These are qualifications which have been recognised by the Minister for Health as appropriate to use for the assessment of applications by existing practitioners.
The Minister for Health is currently confirming the list of Schedule 3 qualifications to be used for opening the registers for Counsellors and Psychotherapists. When the Minister has listed the qualifications for grandparenting to the registers by regulation, it will be available on the CORU website. All other questions in this theme are addressed in the current FAQs.
Can one programme be aligned to both sets of standards of proficiency?
Any programme seeking approval by a Registration Board must demonstrate that it meets all the Board’s requirements as detailed in the Board’s Criteria and Standards for that profession.
The Board assesses each programme in terms of whether it has the appropriate mechanisms in place to ensure graduates have met the standards of proficiency and can enter the professional register. An education provider has flexibility around how it designs and delivers an education and training programme. Therefore, an education provider could decide to design a programme to meet both the Standards of Proficiency for Counsellors and the Standards of Proficiency for Psychotherapists. It would have to demonstrate how both the taught and practice placement curriculum provides opportunities to meet all the standards for both professions.
However, it is important to stress that the Registration Board approves an education programme as a pathway for entry onto a single register. If a programme was seeking approval for entry onto two separate registers, this would require two distinct approval processes (both of which could potentially run in tandem).
How long do education providers have to align programmes to the Board’s requirements before programme approval starts?
Following the public consultation, the Board will consider and review all the consultation responses and decide on any amendments it needs to make, on the basis of the feedback received, to its draft Criteria and Standards documents for both professions. Once agreed, the Board will publish its Criteria and Standards for both professions and issue these to education providers. At this point of the process, the Board will also make a determination as to how long education providers have to align their programmes to its requirements before the window for programme approval opens. When this decision is taken by the Board it will be communicated to all education providers.