We’ve submitted our response to the consultation on the National Institute for Health and Care Excellence (NICE) draft guideline for treatment of adults with depression.

We’ve welcomed the improved focus on client choice and the recommendation that all psychological therapies should be considered as first line treatments for depression.

But we’ve raised serious concerns about how the guideline was put together and how relevant research was not considered.

We’re also unhappy with how treatment options are ranked, the inconsistent use of the word counselling, and that longer-term psychological therapies are not recognised in the guideline.

Our comment

Our Head of Research Dr Clare Symons said: "We feel these failings in the development of the guideline have downplayed and downgraded the existing evidence on the positive impact that counselling and psychotherapy has on people’s lives.

"While we’ve been pleased to see some of changes to the guideline – particularly around patient choice – we still have major concerns about several aspects.

"This has been an incredibly important consultation to respond to because recommendations in the guideline have a direct impact on the treatments offered for depression and whether counselling and psychotherapy is made available.

"Thank you to all our members and academic researchers whose input has contributed to our consultation response."

Long campaign

We’ve long campaigned, alongside our members, other mental health organisations and MPs, for the guideline to be updated.

In putting together our response to the consultation, we’ve drawn on feedback from counselling and psychotherapy academic researchers and from members who contacted us during the consultation period.

Our submission was also informed by reviews we specifically commissioned to assess the research and analysis used in the guideline’s development.

Main concerns

We have a number of key concerns.

The guideline uses the term counselling inconsistently, which could affect how decisions about recommendations are made. We’ve said NICE needs to use clear and specific definitions about counselling that recognise it encompasses a range of treatments and modalities.

The ranking of treatment options in order of recommended use, based on interpretations of clinical and cost-effectiveness, undermines patient choice. We’ve recommended they’re listed in a neutral way – such as alphabetically.

We’re disappointed that longer-term psychological therapies is not included as a treatment option, as research evidence that supports this wasn’t considered. We feel peoples’ experiences, including those people who want and need longer-term treatments, haven’t been adequately considered.

The guideline hasn’t considered large datasets that provide real world statistics – such as the Improving Access to Psychological Therapies (IAPT) dataset of more than one million patients. Data from IAPT annual reports since 2014 show that patient recovery rates have been virtually equivalent between CBT and counselling. As this research wasn’t included, we don’t feel the guideline is a complete assessment of the comparative effectiveness of psychological therapies.

We’ve identified issues with the evaluation of some of the research used, which we believe has resulted in unreliable recommendations. We’ve called on the guideline committee to address this.

We also believe the seven-week consultation period should have been longer because of the large volume of consultation documents (around 2,500 pages) that needed detailed analysis.

The updated guideline is due to be published in May.

Our response

Full response to the NICE guideline consultation (pdf 0.3MB)

Response to the NICE guideline consultation - text only version (docx 38KB)