Not Able: What Happened After I Filed Complaints Against the PACT Institute
I finally have had time to write the follow up to my post about the PACT Institute's photo and video release. It ended with me having filed complaints with the organizations that accredit PACT for continuing education. Here is what happened after that, in order.
Late April: Three Letters
I wrote the complaint on Sunday, April 26, and sent it to CAMFT, the APA and NBCC the same afternoon. I took some care with it, tying every objection to the standards for CE providers that the APA, NBCC and the State of California publish, so that the letter did not lean on my own sense of what a training should be. The comparison at its center is one every supervisee learns: when you record a session with a client, the consent is bounded in scope and purpose, for the supervisee and supervisor, period. PACT's release had no bounds at all. The letter closed with the grievance point, because that was the part I thought an accreditor could act on most easily: PACT's published grievance policy promises a prompt, good-faith response and a review, and then, if the issue cannot be resolved, a fee credit or a refund. What I had received was the refund, in six days, with no review I could see. PACT treated a colleague as a customer and an ethical objection as a dissatisfied purchase.
A few days later I sent all three organizations the consent form I thought PACT should be using instead. I also forwarded the complaint to Stan Tatkin, PACT's developer, and Beverly Baker, PACT's Executive Director, told them I would be writing about it, and said I hoped their accreditors would require the self-reflection my own feedback had not.
CAMFT answered first, within a day. PACT is not a CAMFT-approved CE provider, so CAMFT was "not able to take any action," and they pointed me to the APA and NBCC.
Early May: The NBCC Package
NBCC asked me to fill in their Complaint Statement form. The time-consuming part was the addendum: an evening with the NBCC Continuing Education Provider Policy and the NBCC Code of Ethics, finding the provisions PACT's release actually violated and quoting each one before arguing it. Four held up, and the one with teeth was a reporting rule: a provider must report every complaint touching the Policy to NBCC within sixty days. My complaint to PACT was dated January 6. Nothing suggested PACT had ever reported it.
Then the package, twelve attachments assembled over a weekend, including a copy of PACT's public terms page with my annotations in the margin. The annotations were there because something had already changed. When I registered in January, the release was not on the public terms page at all; it sat inside the portal, after payment, which is where I found it, and which Beverly's March email called inadvertent.
In that same email Beverly told me they were "not able" to materially change the policy. By May the release was on the public page and the list of permitted uses had been trimmed: conference presentations and website presentations were gone, and everything else, the unlimited editing, the waiver of review, no time limit, no geographic limit, "position yourself out of range of recording devices," was still there. The policy that could not be changed had been changed, quietly, in the one way that cost them nothing. I noted that for NBCC so the reviewer would know which version they were looking at. By the time the file reached NBCC's Director of Continuing Education on May 12, I had put more hours into this complaint than I want to count, none of them paid.
May 15: PACT's Answer
I published the post on May 8. A week later, Beverly Baker wrote to me, the one letter I received from PACT that engaged anything. They had "confirmed with the relevant accrediting boards and organizations that the PACT Institute's policies and procedures are in compliance with current CE requirements and standards." My feedback had "been reviewed internally," and the concerns I raised "were appropriately addressed through our existing processes."
On May 15, all NBCC had told me was that my file had reached their Director; it would be another ten weeks before they closed it. The APA had not replied to me at all. Whatever confirmation she had, it did not come from a finished review.
The letter also drew a distinction: "PACT Level 1 is a professional training program for therapists, not a therapy process or psychotherapy treatment environment. While the training is experiential in nature, participants are engaging as professionals in an educational setting." The implication was that I was confused about this. I said it was experiential, which is PACT's word, in PACT's video, as the reason to register. The ethics codes don't stop at the consulting room door; APA 3.08 names students and supervisees alongside clients precisely because the person who controls your training controls something you want, and that asymmetry is enough to compromise consent whether or not anyone is in treatment. On May 26 I wrote back with the link to the post, said that nobody at PACT had engaged the substance of my objections clinically and that I had never spoken with a clinician, and told them they would not hear from me again.
Summer: "Deficiencies Addressed"
In June NBCC told me it could not discuss a pending complaint but would update me when the review concluded, and the APA wrote that it was examining the matter with PACT. On July 30 NBCC wrote that the review was complete. "Any identified deficiencies were addressed by the ACEP, consistent with Policy. Accordingly, the complaint matter concerning The PACT Institute is closed." I wrote back within the hour: what deficiencies were identified, and what changed? On August 3 the answer came. They were "not able to disclose the exact details concerning the deficiencies and corrective actions." As the complainant, I could ask PACT.
I sat with that for a few days and wrote back on August 7. Part of it:
NBCC approves and generates revenue from providers like PACT. When a clinician files a complaint, NBCC conducts an internal review with results disclosed only to the provider. The complainant, who contributed the unpaid labor of documenting the violation, is then directed to contact the provider directly for more information. That provider's refusal to engage with an ethics complaint is the reason I came to NBCC in the first place. From where I'm standing, this looks less like a professional standards process and more like a structure that protects the providers who pay you from the licensed professionals who don't.
Someone read it. On August 19 NBCC sent a longer and more careful reply than any before it. The review had "identified limited areas requiring attention," NBCC had "followed up with the ACEP regarding those matters," and "the ACEP addressed the concerns identified." The confidentiality rules, they wrote, "should not be understood to mean that the concerns raised were disregarded." I thanked them and said I appreciated this extra context, but I was pretty discouraged at this point.
October and November
The APA is still examining. I wrote to them again at the end of October, and on November 2 they replied that they were "currently awaiting additional information from the organization regarding this matter" and would follow up "once we have completed correspondence to resolve this matter."
Vindication
With this newsletter to write, I went back to PACT's Level 1 terms page to see whether anything had changed. It had. The page now ends with a line it didn't have before: "Updated August 4, 2026 By Beverly Baker, Executive Director, The PACT Institute." Above it is a different policy. Participant recordings are now "intended solely for the benefit of the individual cohort and will not be used outside that educational context without additional permission." They "will not be publicly distributed, used for marketing, or used for commercial purposes without separate written permission." They are kept for three years and then disposed of by the training manager. The lifetime, worldwide, waive-all-review release that I refused to sign in January is still on the page, but it now applies to "Faculty, Instructors, Coaches, and Paid Representatives," the people PACT pays, rather than the people who pay PACT.
It's much of what I asked for in January and most of what I sent them in April: recordings that stay with the people who made them, nothing used to sell the training without a separate yes, a date after which it is gone. I felt vindicated, but so disappointed. Ten months of letters, to get a page I could have been told about in a phone call, from an organization that had answered every one of those letters by saying nothing would change.
NBCC closed the complaint on July 30 and told me on August 3 that it could not say what had been found. The next day, according to PACT's own page, the policy was rewritten.
The thing I asked for in January happened. Nobody told me, and if I hadn't felt I owed you, dear reader, a follow up, I would never have known.
The Level 2 and Certification terms pages still carry the January release, word for word, with no update line. Whether that is an oversight or a decision I can't say. If you are considering Level 2, read its terms page, not Level 1's.
"Not Able"
Nicci at PACT, January 12: "we are not able to provide an alternate consent structure." Beverly Baker, March 6: "we are not able to materially change the policy." CAMFT, April 27: "not able to take any action." NBCC, August 3: "not able to disclose." Four institutions, one phrase, and in three of the four cases what it described was a choice. The policy that could not be materially changed in March was changed in August, by the person who said it couldn't be. The day after NBCC told me it could not disclose what had changed, a change appeared on the provider's own website.
I don't think anyone was lying to me. I think "not able" is what people and institutions say when the thing you are asking for would cost them something and the policy lets them not pay it.
It is worth turning that on ourselves. We hold frames too. We enforce cancellation policies, and when a client pushes, a lot of us reach for the same phrase: I'm "not able" to waive that. In private practice the policy is yours, and the honest sentence is "I won't," with the reason. In an agency the policy is someone else's, and there are still only two honest positions: you agree with it, in which case you won't, or you don't agree with it and you are enforcing it anyway, in which case say that. Owning the power you actually have and stating it plainly is what I wanted from every one of these institutions, and it is not a bad test for how we speak to our own clients.
NBCC's complaint process has a remedy, and it apparently works, but it is delivered to the provider, and the complainant is told the matter is closed. The clinician who raises the concern stands outside the relationship where money changes hands, which is why the answer to them is always the same.
If You Can't Sign It
When I thanked NBCC in August I told them I was not sure I would take the time to file another complaint, and that having ethical and professional standards in this period of hyper commodification and corporatization of the field is exhausting. I still feel that. I also have to admit that the thing worked, in the only way these things seem to work: slowly, invisibly, with no acknowledgment, and only because I kept asking. Every colleague I told this story to was shocked by the release and not surprised by the response, and I have come to think that second reaction is the real problem, because it means we have stopped expecting our institutions to engage with us as clinicians at all.
So: read a release before you pay, and read it again when they update it. If you can't sign it, say so in writing and say why. If the provider won't engage, find the accreditor's own policy and write the complaint in its language; it is tedious, it will not tell you what it found, and it may still produce the change you asked for. Go back a few months later and look.
This is the last I'll write about PACT. Whatever the APA decides, you won't read about it here.
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Writing and updates from Robin Levick on psychotherapy, embodiment, the metacrisis, and the practice of Embodied Relational Psychotherapy.