I thin there are some people who won't be helped by therapy but I don't know that they have a common trait. Attachment disorders are very difficult to treat, I believe. And I have heard that personality disorders are hard to treat, but I have found a t who is helping me with that.
I definitely believe that treatment should be individualized. I think for some, somatic type of treatments are the best. There are studies that show that EMDR is especially helpful for trauma. In my experience CBT is helpful for addicts. I also believe that out of session contact is sometimes helpful, but that seems to vary for different people. Internal Family Systems works for some people, but H hated it and sees a t who is more of a coach and he likes that.
I wouldn't see a t that thought there was only one way to treat.
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