Colorado unveils first rules for facilitation of psychedelic therapy

Colorado's legal psychedelic therapy industry is beginning to take shape as regulators recently unveiled the first rules regarding facilitator education, training and licensure.

In late February, the Department of Regulatory Agencies, or DORA, released a draft of these rules, which was informed by recommendations from the 15-member Natural Medicine Advisory Board, The board spent the better part of a year researching and discussing what they think are best practices for facilitators—the people who guide or advise people using psychedelics in a therapeutic context.

The rules outline several types of facilitator licenses that the state anticipates issuing, curriculum requirements for training programs it will approve, and a code of ethics for licensed facilitators in this newly recognized profession. The agency also made recommendations for growing, testing and labeling psilocybin mushrooms that will be used for therapeutic purposes.

DORA spokesperson Katie O'Donnell emphasized that the draft rules are just that—a first draft—and she expects they will change after the agency receives public input.

DORA will host a virtual meeting on March 8 at 2 p.m. when locals can offer feedback about the proposals. (Sign up to attend at dpo.colorado.gov/NaturalMedicine under the "Public Notice" section.) Those who can't attend may submit written comments to dora-dpo-rulemaking@state.co.us.

Anyone interested in joining the industry can read the proposed rules at dpo.colorado.gov/NaturalMedicine. Some notable aspects are highlighted below.

License types

Regulators proposed four different facilitator licenses that provide individuals with different avenues into psychedelic therapy based on their backgrounds and areas of expertise.

The first is a general facilitator license, and it's open to anyone who completes the necessary training requirements. That includes practitioners in massage, acupuncture or other holistic wellness occupations, as well as Indigenous or religious practitioners.

The rules carve out a couple of accelerated options for securing a general facilitator license. One is for already licensed facilitators who are practicing in other states; the other is for legacy healers who can show extensive experience and who complete the state's ethics training program.

The second license type is for clinical facilitators, meaning those who already maintain an active license in Colorado to diagnose and treat physical, behavioral and/or mental health conditions. That includes, for example, people working as psychologists, doctors, nurses, social workers and addiction counselors who also want to work with natural medicine.

The third is intended for educators who teach the state's facilitator curriculum in training programs, and the fourth is for trainees working toward their facilitator or clinical facilitator license.

All applicants must be at least 21 years old, must have never been convicted of a felony, and must complete the required training prescribed by the state.

Education and training requirements

Regulators outlined subjects they would like to see included in facilitator education and training. They include best practices related to recognizing bias, keeping up to date on the latest research in the field, and education on harm reduction and conflict de-escalation; training on the state's code of ethics; guidance on boundaries and the appropriate use of physical touch during facilitation; education and intervention strategies when responding to patients' physical or mental health concerns; education about possible drug interactions; an introduction to trauma-informed care and suicide risks; and information about culturally responsive care.

Training requirements also outline what should be covered during preparation, administration and integration sessions; and specific considerations for group therapy. Regulators also hope education will cover self-care for facilitators, including knowing when a professional "is not in a space to facilitate and what to do about it."

It's important to note that DORA's authority extends only to making regulations for occupational roles within psychedelic therapy. Another agency, the Colorado Department of Revenue, is tasked with writing rules concerning therapy centers, psilocybin mushroom cultivation and manufacturing, first responder training and public education strategies, among other topics.

The state revenue department begins its own rule-making process later this month, but individual municipalities may also enact additional local laws. Denver, for instance, is now accepting applications for those who want to participate in a working group to discuss "if the city should develop local regulations for natural medicine, such as psilocybin mushrooms, to protect public safety," according to a statement. The deadline to apply is March 13.

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