The Department of Health Has Failed To Regulate Routine Mental Health Services

Improving Access to Psychological Therapies (IAPT) services are out of bounds to Care Quality Commission inspection.  In 2016 the National Audit Office (NAO) asked the Department of Health to address this issue and it has done nothing.  The Department sets the agenda and budget for NHS England, who in turn do the same with Clinical Commissioning Groups to determine local provision of services. But NHS England staff are lead players amongst service providers, these conflicts of interest exacerbate the parlous governance of IAPT. There is a need for Parliament to step in and take the Department of Health to task.  


Whilst no one doubts the importance of improving access to psychological therapies, it was remiss of the NAO in 2016 to take at face value IAPT’s claim that it had the appropriate monitoring measures in place.  Incredulously the NAO accepted at face value IAPT’s claim that it was achieving a 45% recovery. It is always tempting to look only as far as evidence that confirms your belief. But it is equally important to consider what type of evidence would disconfirm your belief. The NAO has failed to explain why it has not insisted on independent scrutiny of IAPT’s claims. 

The The Improving Access to Psychological Therapies (IAPT) programme has exercised a confirmatory bias in its’ audit by focussing only on self-report responses on  psychometric tests (the PHQ9 and GAD7). The service has never looked at a categorical end point, such as whether a person lost their diagnostic status as assessed by an independent evaluator using a standardised diagnostic interview.

Organisations, are inherently likely to be self-promoting and will have a particular penchant for operating, not necessarily wholly consciously, with a confirmatory bias. It is for other stakeholders, NHS England, Clinical Commissioning groups, MPs, the media, Charities and professional bodies (BABCP  and BPS) to hold IAPT to account. For the past decade they have all conspicuosly failed to do so. How have IAPT evaded critical scrutiny, despite the taxpayer having paid £4billion for its’ services? Friends in high places is the most likely answer. I have called for an independent public inquiry for years and will continue to do so  but there is likely to be an echo of a deafening silence as the only beneficiary would be the client with mental health problems.  

Dr Mike Scott

A Conflict of Interest Between NHS England and IAPT


the Improving Access to Psychological Therapies (IAPT) pantomine is likely to continue, with Dr Adrian Whittington, National Lead for Psychological Professions, NHS England  and IAPT National Clinical Adviser about to chair a Conference with the leading light of IAPT, Professor David Clark for IAPT staff.      IAPT afficionados seem inherently incapable of understanding what constitutes a conflict of interest, see forthcoming issue of the British Journal of Clinical Psychology, ‘Ensuring IAPT Does What It Says On The Tin’.

page1image32572160 page1image32571584 page1image32572352 page1image32572544 The Information Standard Guide

Finding the Evidence

A key step in the information production process

November 2013

Caroline De Brún

NHS England  should reflect on their own document published in 2013 ‘Finding the Evidence’ in which clinicians are asked to seek the ‘best research evidence’ by looking at how an intended treatment has fared compared to a credible alternative. Taking the IAPT service as the intended treatment there has never been a comparison with a credible alternative. IAPT cannot be considered  a repository of ‘best evidence’

The power holders, wish to believe their fairy tale ‘we are committed to mental health, we have shown this in supporting our world beating IAPT service, as far as possible we will fund expansion of the service, we have broken new ground’ and in small print ‘it is not politically correct to say other and we are too busy  with the pandemic/physical health to critically analyse IAPTs data’. But this is a dangerous story offering no protection for the mental health sufferer. It is time that sufferers are seen as ‘vulnerable’ people and offered societal protection.

IAPT therapists do not ask the client,  at the end of treatment, whether they are back to their old selves again. Outcome is determined by the Genie that arises out of the psychometric test lamp that IAPT polishes incessantly.

The Genie could be pressed ‘how does low intensity CBT work?’  A coughing and spluttering might ensue. It is known that CBT works for the depression and anxiety disorders, using the specific cognitive model for those disorders. But there is no evidence that simply describing the reciprocal interactions of cognition, emotion, behaviour and physiology, then targeting   one or more of them leads to an evidence supported treatment. It is a fundamentalist translation of the treatments conducted in the randomised controlled trials of depression and the anxiety disorders. It is a translation born of the exigencies of the situations, such as vast monies available for treatment, but it is akin to using a religious belief system for political purposes.

 The CBT protocol for panic disorder is entirely dependent on David Clark’s model (2020) of catastrophic misinterpretation of bodily sensations perpetuating the symptoms of panic None of the procedures in the protocol would make sense without reference to his model. 

A cognitive model of a disorder is the nucleus around which orbit all the procedures of a protocol. Beck enshrined this in his theory of cognitive content specificity, that disorders are distinguished by their  different cognitive content and connive profiles see Baranoff, J., & Oei, T. P. S. (2015). The cognitive content-specificity hypothesis: Contributions to diagnosis and assessment. In G. P. Brown & D. A. Clark (Eds.), Assessment in cognitive therapy (p. 172–196). The Guilford Press, and Eysenck and Fajkowska (2018)

But the procedures in low intensity CBT have no nucleus. For example the strategies in Williams et al (2018) doi: 10.1192/bjp.2017.18 Living Life to The Full classes ‘covering key CBT topics such as altered thinking, behavioural activation, problem-solving and relapse prevention’,  are not derived from any specific cognitive model of disorder – they are the equivalent of displaced electrons, the atoms have no credible name and the targets ill defined. For example in the Williams et al study (2018) the target is ‘low mood and stress’, the latter has no specific cognitive content or cognitive profile.   If it is not known how a psychological therapy achieves its goal then the therapy itself cannot be considered evidence supported. There has to be a plausible scientific explanation of the mechanism of change. The low intensity cbt protocols represent an ad hoc usage of cbt techniques, it is impossible to distil the mechanism of change, if any, in such a collage.  In this respect the low intensity interventions are found wanting, they are poor translations of the protocols in the ‘gold standard’ randomised controlled trials,  they are advocated in a fundamentalist way by IAPT, driven by perceived economy than any considered view of effectiveness.

Dr Mike Scott


‘Intensive Care PTSD’

this was the banner  headline on the BBC News today, January 13th 2021. It followed the announcement of a study by Prof Neil Greenberg, which revealed that staff had been ‘traumatised’ by the first wave of the pandemic. This in turn led for Paul Farmer Chief executive of MIND to call for ‘the right support at the right time’ on BBC radio 4 today. The Government has promised an extra £15 million so that extra support can be given.  But what sort of support?

In the press release accompanying publication of his study in the journal Occupational Medicine, Professor Greenberg notes ‘Further work is needed to better understand the real level of clinical need amongst ICU staff as self-report questionnaires can overestimate the rate of clinically relevant mental health symptoms’. His study was based on a web survey of ICU staff about half of whom responded, about half whom met the ‘threshold’ for PTSD, severe anxiety or problem drinking. There is a clear need to go beyond self-report measures.

I am currently writing a book ‘Personalising Trauma Treatment: reframing and reimagining’ to be published by Routledge. In this work I suggest that the initial conversation with trauma victims   should include ‘Gateway Diagnostic Interview Questions’ , with regard to Covid an appropriate subset would be:

Depression (evidence that at least one of the answers to the following questions is in the affirmative)

1. During the past month have you often been bothered by feeling, depressed or hopeless?

2. During the past month have you often been bothered by little interest or pleasure in doing things?


Panic Disorder

1. Do you have unexpected panic attacks, a sudden rush of intense fear or anxiety?

2. Do you avoid situations in which the panic attacks might occur?


Post-traumatic Stress Disorder

In your life, have you ever had any experience that was so frightening, horrible or upsetting that, in the past month, you

1. Have had nightmares about it or thought about it when you did not want to?

2. Tried hard not to think about it or went out of your way to avoid situations that reminded you of it?

3. Were constantly on guard, watchful, or easily startled?

4. Felt numb or detached from others, activities, or your surroundings?

5. Felt guilty or unable to stop blaming yourself or others for the event(s) or any problems the events may have caused?

Evidence that at least three of the answers to the symptom questions above are in the affirmative

Alcohol Dependence (evidence is that the response to the first three of the following questions is in the affirmative)

1. Have you felt you should cut down on your alcohol/drug?

2. Have people got annoyed with you about your drinking/drug taking?

3. Have you felt guilty about your drinking/drug use?

4. Do you drink/use drugs before midday?

Asking GDIQ questions encourages the person to furnish possible examples of the impact of the symptom on their life, so that they feel listened to. Reference can then be made to other  diagnostic symptoms for the particular disorder, to tease out whether there are sufficient impairing symptoms for that disorder, to merit that diagnostic label.  Use of GDIQ’s is part of a conversation, it is not a rapid fire interrogation or checklist. As a supplement to the GDIQ people can be asked whether this is something that they want help with, as they might not want to verbalise that they want to sort the problem out themselves, but are too polite to express this. 

The NICE recommended treatments are diagnosis specific, thus there is a recommendation of trauma focussed CBT for PTSD. But those traumatised by Covid are likely to find it toxic to be pushed to describe in graphic detail the horrors encountered. In my book I argue that this is unnecessary, rather that what is of key importance is to assess what the person takes their memory of being in ICU means about today. It is not the event that causes PTSD but the mental time travel to the worse period and the significance given to it  for today. This approach  is much less challenging for whoever is  accompanying the effected medical staff and family/friends who have seen horrors.


Dr Mike Scott

Unnecessary Treatment Is The Rule In IAPT – Due Diligence?


The UK Government, Improving Access to Psychological Therapies (IAP) only uses psychometric test screening measures  to assess clients, most commonly the  PHQ9 ( a measure of the severity of depression) and GAD7 (a measure of the severity of generalised anxiety disorder), but other measures are advised for other disorders, such as the PCL-5 for PTSD. A study by Zimmerman and Matia (2001) [The Psychiatric Diagnostic Screening Questionnaire: development, reliability and validity. Comprehensive psychiatry, 42(3), 175–189. ] showed that questionnaire measures that reflect DSM criteria have a roughly 90% sensitivity across major depressive disorder, PTSD, panic disorder, social phobia and GAD, i.e it correctly identifies 9 out of 10 of those who do have one of these disorders. But it identifies only about 60% (specificity) of those who do not have the disorder and for GAD only 50%.  However many more people do not have a particular disorder than have one, leading to unnecessary treatment for many. The National Audit Office should take note of this and re-instate its’ investigation, where is the due diligence with regards to IAPT? £4billion has been given to IAPT!


In the Zimmerman  and Mattia (2001) study 47.9% of the psychiatric outpatients had major depression. Assuming psychiatric outpatients are a reasonable approximation to the IAPT population, then in a sample of 100 patients approx. 50 would have depression and 50 would not. Of the 50 with depression, 45 would have been correctly identified and treated. However of the 50 who did not have depression only, 30 would have been correctly identified leaving 20 as false positives, candidates for inapropriate treatment. Thus roughly for every two depressed cases appropriately treated one would be inappropriately treated. For depression the appropriate/inappropriate ratio is 2/1 – pretty wasteful.

Generalised Anxiety Disorder

In the Zimmerman Mattia Study 17.5% pf the psychiatric outpatients  had GAD. Thus in a sample of 100 patients approx. 18 would have GAD, of whom 16 would have been correctly identified and treated. But 82 would not have GAD but 50% of them would have been regarded as having GAD meaning that 41 would have been inappropiately treated. Thus for GAD the appropriate/inappropriate ratio is 16/41, so that for every one GAD client treated appropriately 2-3 others are treated inappropriately.

Post-traumatic Stress Disorder

In the Zimmerman and Mattia study 10.5% of the psychiatric outpatients had PTSD. Thus in a sample of 100 clients approx. 11 would have PTSD with 9 being correctly classified and treated. However 89 would not have PTSD of these 62% (55) were correctly classified, meaning that 34 were false positives. Thus the ratio of appropriately treated/ inappropriately treated is approximately 1/4 , for every one treated appropriately 4 are treated inappropriately.

IAPT’s Preposterous Claim On Recovery

Given the ubiquity of unnecessary treatment in IAPT, its’ claim of a 50% recovery rate [IAPT Manual (2019)] is preposterous.  I found a 10% recovery rate Scott (2018), which is much more likely if a body relies simply on a screening instrument.

The Need To Translate Research Methodology Into Routine Practice

Ehlers et al. Trials (2020) 21:355 have used the PDSQ to screen for cases of PTSD in their study of therapist assisted treatment for the condition, but have followed the screen up by using a standardised semi-structured interview the SCID to then diagnose PTSD. In this study they have kept a screen in its place and not allowed it free rein as in IAPT.  The IAPT Manual p25 states ‘To ensure that all relevant problems are identified, it is recommended that assessments include systematic screening for each of the conditions that IAPT treats. Standardised commercial screening questionnaire that cover the full range of problems and that can be completed by people before they attend an assessment can be considered ‘ and cites the  PDSQ as an example. But sole use of any screening instrument is very wasteful.

Ehlers et al (2020) have sought to establish whether no more than 4 hours therapist time can make a real world difference to PTSD sufferers lives, a consummation devoutly to be wished, these authors could be well employed helping IAPT get its’ own house in order.


Dr Mike Scott