Responding to public consultations: guidance for authors

What are these guidelines for?

These brief guidelines have been developed to ensure that responses submitted by BACP to public consultations are consistent, evidence based and of the highest quality.

BACP wants to consult widely with experts in counselling and psychotherapy, so that BACP’s responses to consultations are representative of the membership and the wider field. The views of BACP members are essential for BACP to influence and help shape policy initiatives. 

The responses to consultations are prepared by BACP staff and on a voluntary basis by members with specific expertise in the area of the consultation. 

BACP consultations procedure: overview 

Consultations are obtained in a variety of ways: organisations (such as the Health Professions Council and NICE) send us consultations, key websites are monitored, regular updates are received via e-bulletins and information is received from staff and members. Consultations normally last between four and 12 weeks.

BACP makes a decision as to whether a formal response will be made to the consultation based on its relevance and importance to the profession and/or discipline. The consultation is publicised on the website with the deadline for our final response. A formal response is drafted by the Research and Public Affairs Officer based on the comments received, which is then authorised and signed off by the Head of Research.

Criteria for comments:

Representative

Comments received for inclusion in the final response need to be representative of BACP membership. Authors of comments need to take into consideration that BACP has a diverse membership who practice using a range of modalities in different settings. Comments must not be specific to or biased towards one approach to the exclusion of others.

Responses should be written on behalf of BACP and should not be used as an opportunity to promote one area of counselling/psychotherapy above another.

Respondents should comment on behalf of BACP, rather than as an individual, e.g., BACP suggests, BACP would like to etc. Try not to write personally… but rather, on behalf of all practitioners.

Based on professional expertise/opinion or evidence

Responses should be a balance between professional judgement and expertise on the one hand and the use of valid, reliable and relevant research evidence on the other hand.

It is suggested that evidence is provided where appropriate/possible to support responses. If you quote from research or guidance this should be appropriately quoted and referenced.

Focused and relevant

Comments need to be focused and specific to the consultation document and/or questions posed. Comments need to be constructive and worded clearly, and any critical comments need to be constructive, courteous and well supported by evidence and/or experience.  

Consistent

Comments need to be consistent with BACP policies/positions, the Ethical Framework for Good Practice in Counselling and Psychotherapy, published guidelines and previous consultation responses.

Terminology and layout

Comments should be written in plain English and jargon and technical terms should be avoided unless necessary. 

When laying out your comments, breaking down your response into paragraphs or points can be useful. If the consultation paper has numbered paragraphs then your comments should refer to these numbers.

Submitting comments

Only one response will be submitted by BACP, so please do not send out a response on behalf of BACP.   Your comments need to be returned to the Research and Public Affairs Officer (suky.khele@bacp.co.uk) for collation, editing and formatting. If you wish to submit a separate response in your own or another organisation’s name, this is fine; however this must exclude any references to BACP.

Consultations tend to have different submission requirements for comments. NICE will expect comments to be sent in on a pre-developed comments form and they require us to indicate which section we are referring to when commenting. However, other organisations ask specific questions which they would like comments on or sometimes there in no pre-specified format and a letter with our comments will suffice. BACP needs to ensure that we respond in the correct format of the consultation. Therefore, comments will need to be received by BACP in the correct format; if questions are posed comments must address questions and be constructive. Before reading a consultation document, please check with us to find out what the submission criteria are.

If you only have something to say about one particular section of the consultation or on one of the questions posed, this is absolutely fine; any contributions, however specific can be very relevant and useful. 

Comments must reach BACP at least five working days before each deadline to ensure that there is enough time to collate responses and draft a formal response. 

Publication of responses

Consultations responded to will be flagged up in Therapy Today in the public consultations column. The full responses to consultations will be posted on the consultations page of the BACP website    (http://www.bacp.co.uk/consultation/previous_consultations.php). The consulting body may also put the comments we submit on their website. Please note that responses are therefore not confidential and any comments which you consider to be confidential should not be made.

If you wish to contribute to any of the consultations currently listed on the website or would like further information, please contact Suky Khele, Research and Public Affairs Officer (suky.khele@bacp.co.uk / 01455 883352).