The Malta Chamber of Psychologists is currently in talks with stakeholders, which include government officials, on its position regarding the proposed Psychotherapy Profession Bill.

The main concern relayed by the Chamber, as well as the Dean of the Faculty of Social Wellbeing within the University of Malta, Professor Andrew Azzopardi, is how no distinction has been made between the practice of psychotherapy and the profession, which could have very real implications on trained psychologists.

Presented for its first reading in Parliament on 13 November 2017, the proposed Psychotherapy Profession Bill is aimed at regulating the profession of psychotherapy. At first reading, the title of the Bill is presented in Parliament and will then proceed to the debate stage when it is presented for its second reading.

The Bill seeks to create an authorised registry of psychotherapists, sets out criteria for how a psychotherapist can be warranted and explicitly precludes anybody from receiving remuneration for the services of psychotherapy without being listed on the registry. In addition, it the Bill would set up a Board to regulate the registry, the issuing of warrants and also investigate any allegations of misconduct by psychotherapists.

Criteria surrounding the issuing of a warrant include that a person is authorised to work in Malta, is of good conduct and good moral character, has "full legal capacity", has obtained a bachelor's degree in a human or social science issued by a higher education institution and has obtained, "to the satisfaction of the Board", training in a specific psychotherapeutic modality for a period of now less than 3,000 hours or its equivalent of 120 ECTS (likened with a Master's degree).

In November 2017, the Chamber called for a meeting with the Prime Minister on the issue, and should its concerns continue to be ignored industrial action would have to be contemplated.

A press release issued by the Chamber said:

"The MCP has ascertained that whilst being in favour of the regularisation of any profession, this Bill not only attempts to regularise the title of the psychotherapist, but is also attempting to regularise the practice of psychotherapy, undeniably threatening to encroach and impede psychologists from practicing psychotherapy freely and without impediment.

"The MCP argues that psychologists are also trained practitioners of psychotherapy, as well as other psychological interventions, and should in no way be conditioned on how, when or with whom they practice their specialisation."

Due to the Bill precluding anybody from offering psychotherapeutic services without having a warrant or being placed on the registry, those licensed psychologists who have psychotherapy training are unable to offer services in relation to that training. In order to do so, they will no longer be able to present themselves as psychologists, but rather psychotherapists. Due to psychotherapy being part of some psychologists wider training, and that those psychologists did not exclusively study psychotherapy, the bill in its proposed form would impinge on their ability to perform psychotherapy services despite being trained to do so.

Many experts in the field have flagged a situation where a psychologist who is trained in psychotherapy would be unable to provide the latter service as part of a wider treatment under the proposed bill, therefore regulating both the practice of psychotherapy as well as the profession.

In a statement issued by Professor Azzopardi on 1 December, he wrote:

"In actual fact, the recently proposed bill intended to regularise Psychotherapists is implying that only Psychotherapists can legally practise this therapy. It is important that I flag a situation that creates a conflict with the Psychology Profession Act, (2004) which stipulates that warranted Psychologists can implement what section 9 of the Act refers to as "a set of therapeutic interventions" because Psychotherapy, is in fact, one of the main features of many psychologists' practice. 

"In countries such as the USA, UK and Malta, Psychotherapy is a core competency of the training of many psychologists. These psychologists are trained in a wide range of mental and physical health problems and are able to conduct clinical assessments. Psychological assessment may lead to psychological intervention, which may consist of various forms of psychotherapy.

"Psychologists generally draw on one or more theories of psychotherapy, which act as a guide to understanding and intervening with clients and their problems. If the proposed bill were to pass as is, it would have not only serious consequences on the Psychology profession but risks short-changing vulnerable people."

In comments from those in the industry, it was stressed that not all psychologists are trained in psychotherapy, but certain branches of psychology rely on psychotherapeutic principles more than others, such as clinical and counselling psychologists.

The European Federation of Psychologists' Association has also written to the Prime Minister to say that it welcomes legislative regulation of psychotherapy but also "hopes" that regulations adopted "will contribute to the development of mental health care in general and psychotherapy in particular for the benefits of patients and clients."

It also attached a statement of the entity's vision on psychotherapy as a professional activity of psychologists, where it states that, "Psychotherapy is an area of applied psychology that is practised by the profession of psychologists."

What exactly distinguishes psychology, psychiatry and psychotherapy? 

Psychiatry, perhaps the most straightforward to explain, forms part of the medical profession. A person must go to medical school, receive their warrant to practice medicine and subsequently specialise in the field of psychiatry. In general, psychiatrists are able to prescribe medication due to their medical training, and psychologists on the whole are not empowered to do so (some countries allow psychologists to attend a psychopharmacology courses which empowers them to prescribe certain types of medications).

A psychologist, or more specifically those specialising in clinical psychology, will have gained a degree in psychology at university. After gaining further experience working in relevant healthcare settings, clinical psychologists then do 3 years Doctorate clinical training in an approved training scheme at university. During this time they work with patients under supervision from experienced psychologists and study for an academic doctorate as well as their first degree. They complete training placements with adults, children, older adults and people with learning difficulties.

Psychotherapy refers to the treatment of mental disorder through psychological means rather than medical ones. It is accepted that psychotherapists may come from both psychological and medical backgrounds.