We have something to celebrate. I am pleased to inform you that we have been removed from the lists of pseudotherapies and subsequently from the list of “potentially evaluable techniques” in the “Plan for the Protection of Health against Pseudotherapies” (Ministry of Health, Consumption and Social Welfare & Ministry of Science, Innovation and Universities, 2018). Transactional Analysis was listed in both and was at risk of having its practice and teaching prohibited in both public and private teaching and assistance facilities.

The origins of the pseudotherapies list

The list of pseudotherapies was based on a list published in 2011 by the then Ministry of Health, Social Policy and Equality in the document entitled “Situation Analysis of Natural Therapies” (Ministry of Health, Social Policy and Equality, 2011). This document included 139 techniques considered pseudotherapies, among which was Transactional Analysis.

On Nov. 14, 2018, the ministers of science and health presented a “Plan for the Protection of Health against Pseudotherapies,” which consisted of 20 points. Among these measures, an assessment report on pseudotherapies would be conducted through the Spanish Network of Health Technology Assessment Agencies and Services of the National Health System. Royal Decree 1277/2003 (2003) would also be amended to eliminate pseudotherapies from healthcare centers and prohibit their practice and teaching in both the public and private sectors. The objective was to raise public awareness about the harmful effects of pseudotherapies and the inappropriate referrals to centers with purported healthcare purposes, as well as to eliminate the use of pseudotherapies lacking scientific evidence in public and private healthcare centers and services, to prevent the substitution of therapies with proven scientific evidence by pseudotherapies.

Advocating for appropriate evaluation

On Jan. 20, 2020, we began periodically sending lists of randomized controlled trials (RCTs) on the efficacy of Transactional Analysis that met the criteria requested by the government plan. However, reports submitted in 2020 already noted that RCTs can, at best, provide efficacy results, but not effectiveness in a naturalistic setting. They cautioned against overlooking the importance of quasi-experimental studies, as well as qualitative evaluative research on psychotherapies, since a favorable result in psychotherapy research without investigating the process leading to it is like researching the effects of a drug without laboratory research to understand its mechanism of action.

Furthermore, they requested that, in any case, it be taken into account that mixed methods and combined analyses are now essential in the evaluation of psychotherapies, since alternative methods to RCTs exist for establishing the efficacy of a psychotherapeutic treatment that lack their serious limitations. Among these are single-case controlled studies, which should be considered valid measures of the efficacy of psychotherapeutic treatments. It was requested that the evaluation of psychotherapies take into account measures of effectiveness, not just efficacy, since effectiveness is ultimately the dimension that allows for the study of a treatment under conditions more similar to care provided in a naturalistic setting. Therefore, studies conducted using quasi-experimental methodology should be included.

On Nov. 23, 2021, in response to these considerations and a list of RCTs that we sent to the administrative units responsible for the evaluation, we were removed from the list of pseudotherapies and moved to the list of potentially evaluable techniques.

From then on, we continued to send periodic reports requesting that it be taken into account that Transactional Analysis is not a “natural therapy” and that, therefore, if it were to be evaluated, it should be within a general context of evaluating psychoanalytic, humanistic and cognitive-behavioral schools of psychotherapy, and outside the “Plan for the Protection of Health against Pseudotherapies.” We insisted that for an evaluation of all the aforementioned schools, if one were to be undertaken, measures of effectiveness, not just efficacy, should be considered. Effectiveness is ultimately the dimension that allows a treatment to be studied under conditions more similar to care provided in a naturalistic setting. Therefore, studies conducted using quasi-experimental methodology should be included.

It was also argued that, for an evaluation of all the aforementioned schools, the existence in the specialized clinical literature of qualitative studies under different clinical conditions that allow for an understanding of the mechanisms of action of the proposed treatment should be considered as a criterion for evaluating the scientific nature of the different schools of psychotherapy.

It was also argued that the evaluation of the scientific nature of the schools of psychotherapy should take into account that a focus must be maintained not only on the symptomatic relief of psychiatric symptoms but also on the improvement of the different dimensions of mental health, the promotion of quality of life and adaptive functioning in work, school and relationships.

Removal from the evaluation plan

In response to these arguments, on May 10, 2023, we were informed that they were considering modifying the initial list of potentially evaluable techniques given that they had warned that, in fact, some are not “techniques,” but are part of philosophical and humanistic approaches and fall more into the field of humanistic and psychoanalytic psychotherapies, which would exceed the objective of the evaluation plan.

After continuing to send reports periodically accompanied by new efficacy and effectiveness data, finally, on Dec. 15, 2025, we were informed that Transactional Analysis is one of the techniques that exceeds the government plan and, therefore, does not have to be evaluated. On April 1, 2026, a statement from the Ministry of Health reached the secretariat of our association in response to a new accompanying report, which we sent on Sept. 29, 2025, and which contained new data on the efficacy, effectiveness and efficiency of Transactional Analysis.

In it, they notify us that they have realized that some of the techniques included in the ministry's plan as “potentially evaluable” exceeded the scope of the evaluation plan, having confirmed that Transactional Analysis is one of those that should not be evaluated.

One of the basic arguments that we had been using in our reports to the ministries of health and science and technology was that we did not refuse to be evaluated. We maintained that, if this were necessary, it would have to be done outside the “Plan for the Protection of Health against Pseudotherapies” and in the context of a “Global Plan for the Evaluation of Psychotherapies.”

This is indeed an evaluation that transcends the government plan, which is focused on protecting the general population from harm from natural pseudotherapies, not on evaluating psychotherapies. The evaluation of different psychotherapies is not an issue that can be addressed by evaluating the safety of a technique. Rather, it involves the evaluation of much more complex parameters, something which at this time, as we have informed the ministries repeatedly, requires a complex, mixed quantitative-qualitative methodology, given the growing criticism in the scientific world of RCTs as the gold standard of evaluation.

I believe that the key to success has lain in showing the technical teams in charge of evaluating the potentially evaluable techniques of the Carlos III Health Institute (ISCIII) and the Health Technology Assessment Agencies of Spain that we are not a technique, but a modality of psychotherapy. And psychotherapies, of course, must be evaluated, but in a scientific context and outside the security measures on which the protection plan against pseudotherapies focuses to protect the population from harmful effects. I think this has also been able to help other schools get off the list of potentially evaluable techniques.

We have convinced by the force of the facts and arguments, not by influences from lobbies or political influences, which ultimately reinforce the “suspicious” character attributed to us, since they do not focus on communicating objective data.

Gratitude for the research group

I want to show my deep gratitude for the work carried out over the last six years by the APPHAT Research Group, made up of Verónica Aguado, Sabina Mateo, Jorge Martínez and Blanca Fernández, and to which I also belong. Their commitment, their effectiveness, their tireless tenacity and their professionalism have produced more than 70 reports sent to different entities and administrative units. These include the Congress of Deputies and the ministries of health and science and technology, both to their managers and to the science and health commissions of the Congress of Deputies, the ISCIII, the Ombudsman, the group of Spanish members of the European Parliament (MEPs), the presidents and health departments of the 17 autonomous communities, etc.

During this time, the Research Group has produced a total of eight articles, two of them published in an external indexed journal unrelated to Transactional Analysis, with a recent study sent to the Transactional Analysis Journal pending publication. The objective of these articles was to inform the national and international scientific community of the empirical data that exists about our clinical practice.

Future commitments and clinical research

Now we have to continue showing that Transactional Analysis is efficacious, effective and efficient in different clinical conditions, something for which, as I have already mentioned, there is already empirical data from RCTs and single-case studies. We have to continue with a line of work aimed at finally being included in the clinical protocols and clinical guides prepared and updated by organizations such as the American Psychological Association (APA), the National Institute for Health and Care Excellence (NICE) or those commissioned by governments to groups of experts. These groups search the international scientific literature for efficacy and effectiveness data in different clinical conditions. This will eventually lead us to be taken into account in the protocols and clinical guides of the different national health systems, where we are now still not present.

There is something we must learn from this unfortunate episode of discredit in the official media. One of them is that we live in a world in which patients request efficacy data from providers of different psychotherapies and that many schools are in a position to offer them. This has already become an ethical requirement. We can no longer consider Transactional Analysis only as a “friendly technique,” but as an alternative psychotherapy modality that dialogues with others in this professional world in terms of efficacy, effectiveness and efficiency.

This implies a commitment not only to clinical practice but also to research. In this sense, it is important that we support and improve the construct parameters developed by Joel Vos and Biljana van Rijn (Vos & van Rijn, 2021) and that we use them in effectiveness and efficiency studies. Leaving this area implies being condemned to marginality.

For the moment, we have escaped being considered a form of pseudotherapy that can have harmful effects for the population, and whose practice and teaching must be prohibited.

I believe that we have helped the government administrative units in charge of evaluation to be aware that, first, we are a school of psychotherapy, and, second, that the evaluation of the efficacy, effectiveness and efficiency of psychotherapies does not correspond to governments, but to the international scientific community. With this, we have also achieved that the practice and teaching of Transactional Analysis in Spain is not prohibited, which was a threat in the making.

Transactional Analysis needs now to offer empirical data on efficacy, effectiveness and efficiency in certain specific clinical conditions (panic attacks, social phobia, specific phobias, depressive disorders, psychosis, etc.) so that it can be included by the health evaluation agencies as a first or second-line treatment in said conditions. In any case, its relationship with other psychotherapies and with psychopharmacological treatments must be determined.

This will be a new chapter.