2006 Consultation:

The Bowen Forum's response

Name: The Bowen Forum

Job title:


Address: 14 Grandpont Place , Longford Close, Oxford , OX1 4NH

Contact telephone: 01865 728 920 Email: info@bowenforum.org.uk

If you are responding as an individual, which of the following categories best describes you? (Delete as appropriate)


Health Professional (please state profession/therapy)

Member of the public

Other (please give details)

If you are responding as a representative of an organisation, which of the following categories best describes your organisation? (Delete as appropriate)

Professional association - No

Public educational institution - No

Private education provider - No

Emerging voluntary regulatory body - No

Statutory regulatory body - No

Public/patient/representative body - No

Other (please give details) Therapy Forum working towards VSR with PFIH

Please note that your response will be used for analysis and may be made public. If you would prefer your response to remain private, please indicate this by ticking here:

Q1 Do you agree with the criteria for professions to be regulated by the federal council and what other criteria would you suggest (Section 4.2)

Yes. There should maybe be criteria that the professions are distinct from other therapy professions, and that they are professionally run.

Q2a Do you think there is a minimum number of professions for the establishment of the council? (Section 4.2)

No, but we believe that there will be a minimum number of registrants for a regulatory body to be financially viable. A body with too few registrants would not be able to set the fees at an affordable level. Another view was that the professionalism of the participating therapy bodies was more important that their number (same for Q2b).

Q2b Do you think there is a maximum number of professions that a federal structure could accommodate? (Section 4.2)

Possibly, but it is in excess of 10. As size increases, it will be necessary to alter the composition of committees, to avoid them becoming unwieldy. This would result in not all of the therapies being represented on all of the committees all of the time.

Q3 Do you agree with the proposed fundamental functions and duties of the council? (Section 4.3)


Q4 Have you any comments on the continuing role of the professional associations? (Section 4.4)

We believe that the professional associations have an important role going forwards, but it is up to them to prepare for a new regulatory environment. If therapists are to pay for membership of an association as well as a fee to the regulatory body, the associations will have to provide their members with a valuable and cost effective service. Another view expressed was that there should be fewer professional associations, since joining more than one is very expensive, and not worth the money.

Q5 Do you agree the structure outlined in section 4.5 would be appropriate for membership of the council? (Section 4.5)

The structure seems fine initially, but it may have to modified as more professions join the federal structure, to prevent the council becoming unwieldy. One comment received was that, while it might be good to have all four countries in the UK represented, it is more important that the Council members have the necessary qualities to represent therapists.

Q6 Who would you suggest carry out the appointment process for lay members? (Section 4.5)

Three suggestions were received:

1. PFIH would be in a good position to appoint the first batch of lay members, and that subsequent members could be appointed by the Council itself.

2. Delegates chosen by each of the therapies should appoint the lay members.

3. An initial e-mail vote by therapists could provide a short list, which could be voted on by Committee members.

Q7 How should the chair be appointed? (Section 4.5)

Again, three suggestions were received:

1. The chair should be elected by the Council.

2. Delegates chosen by each of the therapies should appoint the chair.

3. An initial e-mail vote by therapists could provide a short list, which could be voted on by Committee members.

Q8 Do you agree with the proposed council committee structure? (Section 4.6)

Yes (as long as not too bureaucratic and expensive).

Q9 Do you have any comments on the registration of practitioners? (Section 4.7)

There should be an additional criterion that the practitioner has undertaken a minimum level of CPD. There was a concern that not all qualifications for a particular therapy are the same, and that some have done longer training than others, while some practitioners are specialists in a particular area. If this is not sorted out by standardising the courses, it was felt that this should be recognized on registration. It was commonly felt that multi-disciplinary practitioners should not have to pay separate registration fees for each therapy that they offer. Many therapists only work part time, and do not earn a great deal. Standards of proficiency should include therapists being made aware of the circumstances in which referral should be made to a GP. This should be a component of all approved courses. It was also suggested that standards of proficiency should include therapists being made aware of and understanding other complementary therapies. This would be so referrals could be made if appropriate. Many therapists have little or no understanding of other therapies, or indeed their limitations.

Q10 Do you agree with the approach as outlined to the accreditation of courses and qualifications? (Section 4.8)

In general, but there should also be a requirement that all courses and qualifications should meet a minimum standard.

Q11 Do you agree with the role of the visitor and that the professional associations could provide guidance of their appointment? (Section 4.9)


Q12 Do you agree with the proposal for conjoint validation? (Section 4.9)

It seems reasonable. One respondent said that conjoint awards should only be at the higher educational level, and not at the further educational level.

Q13 Do you agree there should be a transitional period to enable the setting up of a new council and register? (Section 4.10)

Yes, this will be necessary for many of the practitioners who are not currently members of professional associations to be able to demonstrate that they meet the required standards.

Q14 Do you agree that this should be for a term of not less than two years from the opening of the register? (Section 4.10)

It was generally felt that two to three years is probably appropriate, but no longer.

Q15 Have you any comments or suggestions for grandparenting during that transition period? (Section 4.10)

We should use the experience of other professions within the HPC. Although the experience of the HPC is not necessarily the model that we would need to adopt, this is an opportunity to develop a scheme that is most appropriate to individual therapy needs.

Q16 Have you any comments on the registration of practitioners who have qualified overseas?

The proposal seems sensible, and it is important that standards are maintained. Why is the English test only proposed for candidates outside the EU?

Q17 Do you have any comments on continuing professional development? (Section 4.12)

Therapists should undertake a minimum amount of CPD specifically relating to each therapy for which they are on the register. This may seem hard for multi-disciplinary practitioners, but it is necessary for the protection of the public. The minimum amount should be set by each therapy body, since it may be different for different therapies. CPD should also include courses that are applicable across all disciplines, e.g. research courses, teaching modules, business management, advanced first aid. This may assist therapists who practise more than one therapy.

Q18 Do you agree that the new council should consider advanced or specialist-level practice? (Section 4.13)

Yes, but the priority must be to establish a basic minimum training for anyone practising on the general public. Advanced and specialist levels of practice should be developed when VSR has been evaluated and there is a high enough level of engagement with the process.

Q19 Do you agree with the proposed composition and functions of the education and training committee? (Section 4.14)


Q20 Do you agree that provision should be made within the register to accommodate professionals who are using their professional skills in some capacity, but are not involved in patient contact? (Section 4.15)

Yes, provided that there are clear provisions to enable them to rejoin the full register later, if they wish to do so (and not at a punitive cost).

Q21 Do you have any comments about fitness to practise procedures? (Section 4.16)


Q22 Do you believe that a federal council will be more likely to be recognised by statutory healthcare regulators, government agencies and other organisations than a number of individual voluntary regulators? (Section 4.17)

The common view was that it is definitely more likely that a federal council would be recognised. It would be better if all therapies were within the federal body, since this would give it a higher profile. Another view received was that a federal council is only more likely to be recognised up to a point. It was felt that it suits the existing medical system for complementary medicine to remain fragmented, and that they will never fully accept those not trained within their system. To be recognised, the federal body will need to inspire confidence that it can protect the public. However, we must not build up an unnecessary bureaucracy in order to keep the fees affordable.

Q23 Have you any comments relating to the cost to practitioners of registration? (Section 4.18)

Regulation will not succeed if it is too expensive. Complementary therapists are different from many other regulated professionals, because many work from home, many work part time, and few are well off. Registration fees need to be in the £50-£150 range, and there need to be tangible benefits from registration, or people will not sign up. Many people would find it hard to afford heavy membership fees even though they may be well trained, experienced and good therapists. We received several comments about the need to avoid setting up a bureaucratic organisation, that only the wealthy could afford to join. If less than a critical number of therapists join, the regulatory body will not be seen to represent the whole profession, the fees will be higher, and it will be harder to persuade other therapists to join. It may be that the regulatory body has to operate in a slimmed down form for the first couple of years, in order to keep costs down. Then as membership builds up, it can begin to offer a fuller service, while still avoiding unnecessary complexity and cost. Some therapists are concerned that within their own sphere they are already undertaking a form of VSR and the federal system will cost them a lot more for very little benefit. It is vital to show in clear, easy to understand terms, what benefits the membership of the Federal body would bring.

Q24 Do you agree with the principle of establishing a voluntary federal regulatory body for complementary healthcare professions? (Section 5.2)

Yes. We do not believe that a relatively small therapy such as Bowen could support a regulatory body of its own. Not only would the costs be very high, the body would carry much less weight with the medical and insurance professions than would a federal body. We believe that the benefits of a federal body are such that all therapy groups would benefit from joining it. We have noted that there is still confusion among some therapists about the roles of the membership associations and the role of a federal body.

Q25 Have you any comments on the proposed timescale (Section 5.2)

The timescale seems very tight, given the relatively little progress that has been made in the past year. It is important that the Regulatory Body is fully prepared for its role, because therapists will not sign up if it cannot perform properly. We would not like the preparations to be rushed through on an unrealistically tight timescale. Even if 3 or 4 therapies are fast tracked in to the therapy body, it is important that the other 6 or 7 are fully consulted on the form of the body which they will later join.

Any other comments?

Twelve written responses were received by the Bowen Forum (all but one from practising therapists), together with a number of verbal comments. Other Bowen therapists and Bowen organisations responded directly to the consultation. We believe that VSR is an important step for the protection of the public, and that it will improve the professional standing of therapists, and the reputation of complementary therapies. Bowen should be a very safe and effective therapy, when properly administered, because the moves are so light, and we perform the minimum number of moves to address the problem presenting. However, it is sadly still possible for hurt or harm to be caused by a therapist who is badly trained, one who is medically unfit to practice, or one who practices in an unprofessional manner. This can then damage the reputation of the whole therapy. It is important that we can set up a system of self-regulation which will protect the public and also promote high standards of training and practice. We received one response from a member of the public who was put into considerable pain by a therapist not practising in a responsible manner, and who is still suffering five months later. They were keen to see a proper system of regulation in place, in order to protect others.

Summary comments from written responses received are:

  • On the face of it the document is encouraging.
  • I agree that the federal system of voluntary regulation would be the best option.
  • A federal-type structure is the most appropriate for the voluntary regulation of complementary healthcare practitioners.
  • I'm happy to see regulation take place. As a professional nurse, anything that shows a professional approach to client care is a plus in gaining credibility for complementary therapies.
  • I agree with the general principle of establishing a voluntary federal regulatory body.
  • I am fully aware that [regulation] has to come to complementary therapies. As I offer two other therapies and have two other professional membership my view is to support the 'Forum’s' views in that our best option as a smaller set up is the federal structure for VSR.
  • I understand that regulation should offer protection to our clients and ourselves, establishing a list of qualified and ethical practitioners. It definitely sounds like a positive step forward.

One respondent was against regulation in all its forms, believed that the risks from Bowen are minimal, that regulation would be expensive, and that the benefits, if any, would be outweighed by the administrative hassle.

Comments were also passed to the Forum from practitioners who had not responded to the document. These were generally that it was difficult and long to download, very time consuming to complete, or that it assumed a level of background knowledge which many therapists do not have. Many therapists did not have a clear understanding of the process, found the structure and future development of VSR too abstract for them to be able to imagine how it would affect them, and found the document too difficult to understand. Others felt uncomfortable about not being able to answer all the questions, and therefore did not answer at all.