My most recent foray into that literature did not disappoint, as I found an interesting article by Theresa Moyers and William Miller (2013) provocatively titled,
Is Low Therapist Empathy Toxic?
In it Moyers and Miller make the case for the need to consider empathic listening skills in the training and hiring of counselors.
They cite research in which differences between therapists in their empathy skills were more predictive of client outcome than the particular approach being taken to the treatment process
This indicates that basic relational skills, such as empathy, transcend treatment type and may actually serve as a necessary foundation upon which different treatment approaches can then be built.
Conversely, they also cite research indicating that a lack of therapist empathy is associated with poorer treatment outcomes, meaning clients of low empathy therapists got worse in treatment rather than better, hence the title of their paper.