Executive summary:

BACP and NCPS refuse to allow a reasonable adjustment of online placement where a disabled student is unable to access an in-person placement. They cite SCoPEd as a reason. ACC and UKCP who are also signed up to SCoPEd do allow for online placements as a reasonable adjustment.

Disabled students are entering training courses and are then unable to do an in-person placement. As a result, some students are unable to qualify, even though they are academically and practically capable of doing the work (as demonstrated in their training environment) with reasonable adjustments.

Additionally (some) courses place their own additional demands on students that they must have individual counselling and it must be face to face despite no mandate from membership bodies.

We ask UKCP to speak with their colleges to clarify that their rules state that it is possible to qualify with an online route, and that this issue should be considered as part of accessibility.

We ask ACC to make the path clear on the website, to remove some of the cognitive load of a person who is already having to fight for reasonable adjustments.

We call upon the BACP and NCPS to enact a path to registered membership that allows a reasonable adjustment of online work for the students who are unable to access an in-person placement, and supervision.

We ask that the membership bodies consider the institution’s in-person skills practice as experience of working in person, whilst completing the entirety of their placement online.

We ask that membership bodies do not allow the enforcement of in-person personal counselling as a training requirement.

Citations are fully referenced at the end of the document only as I cannot link to them in an accessible way through this website.

At length:

Background:

During COVID lockdowns, the majority (if not all) institutions were closed to in-person interaction over an academic year or longer. During that time, NCPS, and BACP accepted thousands of applications for practitioner status from students with no in-person experience.

The Equality Act (EA) 2010 protects individuals from discrimination. Disability is one of the protected characteristics covered.

Institutions, who both have to (and who want to) follow the EA cannot discriminate around accepting disabled students on to their courses. Being a good counsellor has nothing to do with disabled status, and everything to do with the individual qualities of the person.

ACC’s, BACP’s and NCPS’ position

This author approached BACP, NCPS and ACC and suggested that as a result of placements often being in charities, and charities struggling with funding, some students would not be able to access a placement within a reasonable travelling distance. A request was made that BACP, NCPS and ACC allow for a reasonable adjustment of an online-only placement, with in-person experience on the course itself.

ACC’s response was

“Our membership criteria do not set out any requirements as to the placement being online or in person (please see here), so as long as the University allows reasonable adjustments as you have set out, I can confirm that those graduating […] can join ACC as long as they meet the other criteria.” (personal communication 3/2/26)

BACP’s response was

“For those students affected by the COVID lockdowns who weren’t able to gain any face-to-face placements hours, we developed the alternative face to face assessment strategy (where courses still had to sign student off a being competent to work F2F) as an emergency measure only. […]. You can still make reasonable adjustments for the affected students by allowing them longer to complete their placement hours, but we cannot make any exceptions otherwise” (2/6/2025 – personal communication)

NCPS’s response was

“Reasonable adjustments are there to enable trainees to meet required competencies, and we consider them to be essential to the provision of high-quality training. At the same time, adjustments are about adapting how a competency is met, rather than removing the competency. Where adjustments include online elements, training providers must still be able to evidence clearly that all of the core competencies have been met in full, and that standards of supervision, relational depth, risk management, and professional judgement have not been compromised.

In practical terms, this means that trainees would be expected to complete at least some supervised in-person placement hours. We cannot adjust the requirement in a way that removes in-person practice entirely, as this would mean a core element of training had not been demonstrated. The ability to work safely and competently with clients in shared physical space remains an important part of readiness for practice and public protection.” (personal communication 20/2/26)

The core competences are demonstrated within the training environment before an individual is considered ‘ready to practice’. Having said this, it seems that NCPS would accept fewer than the 51/100 hours required by BACP, but if a placement is inaccessible, it is inaccessible.

Unreasonable adjustments

It is not reasonable to suggest that a student who is disabled, should be forced to repeat modules in their year over and over again simply because they are disabled. When the decision to allow hundreds of students to join BACP and NCPS as members was financially beneficial, there was no ethical issue that prevented hundreds of students being allowed to become counsellors with no face to face experience (just a ‘test’ to be passed). Now that less than a handful of students in a year are impacted, despite having many weeks of in-person practice, it is considered unethical.

The disabled Students UK 2025 report states that 51% of over 1000 students across 100 institutions (on all kinds of courses) report that adjustments offered by their institution were insufficient to put disabled students on equal footing with non-disabled peers. 26% of respondents said that the adjustments offered were isolating, dangerous or humiliating. Suggesting a ‘reasonable adjustment’ of just making a student take longer to complete their hours is both isolating and ethically dangerous.

Unequal considerations for online/phone, and face to face work

Institutions may choose to qualify students to work online/via phone (OPT) but if they do, there is no requirement for the student to complete an online placement in order to have online competency as part of their qualification. The mirror image is considered unethical, but not this one. We work to the same levels of complexity online as in person, and arguably the risks are greater when working online than in person.

BACP’s dual standards

BACP states that supervision MUST be accessed in the same mode as client hours are delivered. However they also state:

“With regards to online supervision, Criterion B4.12 of the ‘Gold Book’ requires that the mode of supervision must be the same as the client work, therefore, a mix of in-person and online is required. However, we recognise the need for pragmatism and accessibility, so if individual supervisors are only working online, you could, for example, make up F2F supervision through group supervision” (personal communication 1/7/2025)

The ’group supervision’ referred to here is the supervision that happens as part of the teaching environment, delivered by lecturers. So we can be pragmatic about group supervision, and allow that in-person work to be class-room based, but not skills practice.

An institution’s responsibilities

As a result of Abrahart v University of Bristol, institutions have a responsibility to work proactively with students to arrange support, rather than relying on students requesting adjustments. In 2025 45% of students surveyed agreed that their institution did this.

SCoPed and the Partnership of counselling and psychotherapy bodies

NCPS helpfully linked to a document (referenced below) to entitled ‘in-person training and reasonable adjustments’ that states

“While online learning can have a role in CPD and certain skills development, current research does not yet provide evidence that online training alone can reliably deliver or assess many of these core competencies. For this reason, in-person training and practice remain essential to ensuring public safety, professional integrity and the effective development of counselling and psychotherapy professionals.”

Again – during COVID several thousand students were given membership despite this lack of evidence, and this paragraph conflates in-person training and in-person placements. Students who cannot access in-person placement will still have in-person skills practice. This statement is about online trainin* not about online placements. ‘Online placements’ have been tacked onto the statement, but the only paragraph about statements reads:

“Supervised in-person placements also provide trainees with essential opportunities to gain experience with real clients, receive immediate support and feedback and develop professional judgement in complex, real-world scenarios.”

You can absolutely take the words ‘in-person’ out of that statement, and add in ‘online’ and everything would still be true. Therefore there is no reasoning in this statement as to why a placement should only be face to face.

Course requirements

Some courses require an in-person counselling aspect. There is no BACP, NCPS or ACC requirement to have any counselling. There is an argument for counselling as part of training, but no requirement that it takes place, or the mode it takes place in. Organisations who require an in-person element are adding to the burden on students, who should be free to choose their counselling the way that works best for them. BACP (the most common student body) will not intervene in this, stating that it is up to the course. It should not be ok to discriminate against students in this way.

Final question

How, and why, should an institution discriminate against a student and refuse them entry simply because they are disabled, as a result of the membership bodies’ discriminatory procedures? And why are some bodies claiming that this is a SCoPEd requirement, when others do not?

This is not a PSA-related or a SCoPEd-related issue.

Please sign with any professional memberships you have that may be relevant.

References (all links are in full - not in accessible format as this website doesn't allow for HTML coding as far as I can see)

Abrahart v University of Bristol (WonkHE writeup): wonkhe.com/blogs/the-university-of-bristol-loses-i...

Abrahart v university of Bristol Judiciary findings: judiciary.uk/wp-content/uploads/2024/02/The-Univer...

Disabled students 2025 UK report: disabledstudents.co.uk/wp-content/uploads/2026/01/...

Equality Act 2010: legislation.gov.uk/ukpga/2010/15/contents...

PCPB In-person training and reasonable adjustments: pcpb.org.uk/wp-content/uploads/2025/11/PCPB-In-per...