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Here are the (somewhat complex) pathways to get there.*
by Rachael Ardanuy and Alexander Hise
Prefer to read the PDF? Click here.
This summer has been very busy with rule making sessions to implement the Colorado Natural Medicine Health Act which provides for the therapeutic use of psilocybin mushrooms. The Department of Regulatory Agencies, Division of Professions and Occupations (DORA) finalized rules to regulate and license facilitators of natural medicine services. The initial rules to become a licensed facilitator, governing training programs for facilitators, and establishing required course content for training programs became effective June 30, 2024.
For a comprehensive review of the NMHA, check out the Colorado Lawyer Magazine article “Colorado’s Bold Move to Legalize Psychedelics” written by RZA Legal’s Rachael Ardanuy and co-author, friend and attorney Adam Foster.
Facilitator Licensing Requirements
Licensed Facilitators will conduct four main steps in providing natural medicine services:
Initial safety assessment to identify potential risks or concerns for participants;
Preparation session where participants are provided information, share their goals for the experience, and confirm the safety and support plan for the natural medicine administration session;
Natural medicine administration session where the facilitator supervises the participant for 4-6 hours, and
One or more post-administration integration sessions for participants and facilitators to integrate and process their experience with the natural medicine administration session.
In an attempt to standardize these necessary steps, protect public safety, and provide guardrails to practitioners and patients alike, training and educational requirements for facilitators and operational and safety requirements are enshrined in the two sets of regulations adopted this summer. It is important to note that these regulations will likely change significantly as this industry gets underway.
Under DORA’s initial regulations, which went into effect in June 2024, there are two main scopes of practice: Facilitators and Clinical Facilitators. Additionally, there are four pathways to licensure for those seeking to become licensed in natural medicine facilitation.
This article provides a high-level overview of the primary requirements for all Facilitators based on the initial rules and laws adopted so far. It’s important to note that this is a simplified summary, and the regulations themselves span over 40 pages. For a more detailed understanding or for any specific questions, it’s highly recommended to consult with an experienced regulatory attorney who can guide you through the nuances of the regulations and how they may apply to your situation.
First, some definitions:
Facilitator: An individual not in possession of a secondary license in a medical or behavioral health profession (such as a doctor, nurse practitioner, or mental health provider) who performs natural medicine services. Facilitators must complete specific training, meet safety guidelines and are not allowed to practice medicine or psychotherapy.
Clinical Facilitator: A licensed professional in the state of Colorado (such as a doctor, nurse practitioner, or mental health provider) who uses their existing medical or mental health credentials in conjunction with providing natural medicine services to participants for the purpose of treating physical, behavioral, or mental health conditions. Licensed professionals may qualify for an “Accelerated Licensure” pathway to obtain a natural medicine Facilitator license more quickly. They must still complete specialized training but can apply their prior education and experience toward meeting some of the training requirements.
Accelerated Legacy Facilitator: An individual with prior experience practicing as a traditional or legacy healer prior to formal regulation who can apply for a Facilitator license through an expedited process. To qualify, they must demonstrate substantial equivalent experience, including at least 200 hours of administering natural medicines over a period of two years to at least 40 participants. This pathway allows them to bypass some standard training requirements based on their previous work in natural medicine.
Accelerated Portable Facilitator: An individual already licensed or certified to practice as a natural medicine facilitator in another jurisdiction. They can apply for a Facilitator license in Colorado via the Occupational Credential Portability Program, which allows them to transfer their credentials if their scope of practice is substantially equivalent to Colorado’s requirements. This pathway speeds up the licensing process for experienced facilitators from Oregon, and other jurisdictions in the future as more states legalize psychedelics.
ALL applicants must:
Be 21+
Provide proof of Basic Life Support or equivalent certification
Submit complete application (Within one year of initial submission)
Pay non-refundable application fee
Pass Criminal Background Check at the discretion of the Director
Two Scopes of Practice:
Facilitator | Clinical Facilitator |
|---|---|
May independently provide natural medicine services to screened participants who do not identify risk factors suggesting a need for involvement of a medical or behavioral health provider | May provide natural medicine services to participants for the purpose of treating physical or behavioral or mental health conditions |
Applicants need not hold any secondary licensure | Must hold current and active Colorado license to practice, limited to the following:Psychologist (PSY) Licensed Social Worker (LSW) Licensed Clinical Social Worker (LCSW) Marriage and Family Therapist (MFT) Licensed Professional Counselor (LPC) Licensed Addiction Counselor (LAC) Medical Doctor (MD) Doctor of Osteopathic Medicine (DO) advanced practice nurse (APN) Nurse Practitioner (NP) Physician Assistant (PA) |
May not independently engage in the “practice of medicine” or “psychotherapy” in conjunction with natural medicine services | May only treat medical or behavioral health conditions that are appropriately treated within the scope of their secondary license |
May not provide natural medicine services to participants who take lithium or antipsychotic medications | May not provide natural medicine services to participants who take lithium or antipsychotic medications unless prescribing such medications is within the scope of their secondary license or they receive approval from a provider licensed to prescribe such medications. May not provide natural medicine services to participants with risk factors from the safety screen that are outside the scope of their secondary license unless approval has been granted by the participant’s treating provider |
Pathways to Obtain A Facilitator License:
Original application: Facilitator | Accelerated Portable Facilitator | Accelerated Legacy Facilitator |
Successful completion of a DORA-approved Facilitator Training Program including 150 hours of instruction | Licensed facilitator in good standing in Oregon, practicing for at least one year | Former legacy healers who do not hold a license or other credential to practice facilitation |
40 hours of supervised practicum training in the facilitation of natural medicine | Substantially equivalent education, experience, or credentials that are to those required for original licensure | Substantially equivalent education, experience, or credentials that are to those required for original licensure, including facilitation for 40 participants & 200 hours of administration sessions over at least two years. |
50 hours of consultation | Has not committed acts that would be ground for disciplinary action under CRS 12-170-101, et seq. | |
Successful completion of the Basic Life Support (BLS) certification or equivalent | ||
Successful completion of the 25-hour coursework on Ethics and Colorado Natural Medicine Rules and Regulations |
Pathways to Obtain A Clinical Facilitator License:
Original Licensure | Accelerated Licensure |
Must hold current and active Colorado license to practice, limited to the following:Psychologist (PSY) Licensed Social Worker (LSW) Licensed Clinical Social Worker (LCSW) Marriage and Family Therapist (MFT) Licensed Professional Counselor (LPC) Licensed Addiction Counselor (LAC) Medical Doctor (MD) Doctor of Osteopathic Medicine (DO) advanced practice nurse (APN) Nurse Practitioner (NP) Physician Assistant (PA) NOTE: Massage therapy is NOT a permitted license to qualify for a Clinical Facilitator License and is not a permitted practice in coordination with natural medicine services | |
Successful completion of a DORA-approved Facilitator Training Program including:
| Either successful completion of DORA-approved Facilitator Training Program or submission of successful completion of alternative coursework that is equivalent to:
|
Alternative educational programs or coursework may satisfy requirements for DORA Approved Facilitator Training Program (see Accelerated Licensure) |
Two more licenses with limited scopes:
Training License: A temporary license granted to individuals who are in the process of completing their training to become a Facilitator or Clinical Facilitator. This license allows the individual to practice facilitation under supervision while completing the required didactic education, practicum hours, and consultation. The training license is valid for a maximum of two years, during which time the trainee must complete their educational and practical requirements. The trainee may charge for services during the consultation phase but must work under the supervision of a licensed facilitator.
Distinguished Educator License: A license granted to individuals who have achieved significant professional attainment or recognition in the field of natural medicine facilitation. These individuals may be invited by a Colorado-approved natural medicine education program to serve as faculty. The license allows them to practice facilitation only in the context of their academic appointment, and they cannot receive payment for facilitation services outside of their educational role. The license is valid for one year and can be renewed annually. The Distinguished Educator License is intended for highly experienced practitioners who contribute uniquely to the education of facilitators.
Other Licenses Offered With Limited Scopes
Training License | Distinguished Educator |
Most facilitator applicants will need to get this on their path unless they can prove they have satisfied other training hours | Natural medicine services are limited to the role required by their academic position and must take place in physical locations affiliated with the education program |
License is valid for two years | License is valid for one year and can be renewed annually |
Successful completion of all education requirements of a DORA-approved Facilitation Training Program | For individuals from outside Colorado who want to train facilitators |
Successful completion of Basic Life Support or equivalent training | May only perform facilitation in training program setting and may not receive compensation from participants other than from the educational institution |
Not otherwise eligible for licenses as a Facilitator of Clinical Facilitator | The Director may consider the following in evaluating the applicant’s qualifications:
|
Must complete 40 hours of supervised practicum (after completing didactic training) | Application Requirements: Submit a description of experience in their facilitation practice (CV). Provide a letter from a Director of a DORA-approved Facilitation Training Program on which the applicant will serve, identifying:
|
Must operate under the supervision of a licensed facilitator in the state where the training takes place. The supervisor must be affiliated with a DORA-approved Training Program and willing to oversee the licensee's work during their training. | License is valid for one year and can be renewed annually |
Must participate in and document regular meetings (virtual or in person) with their supervising facilitator | |
Must participate in at least 50 hours of consultation with an experienced natural medicine provider over a six-month period (after completing educational training) |
Navigating new regulations can feel overwhelming, especially with the launch of a novel regulatory program like this one. There are still many unanswered questions surrounding the rollout of these services over the coming months. But rest assured, the team at RZA Legal has the experience and expertise to guide you through every step. We handle the red tape and paperwork so you can focus on what matters most—helping individuals on their path to inner healing with your unique offerings.
If you're wondering whether you qualify for one of the accelerated pathways for a natural medicine Facilitator licensure, or just need clarity on the process, we’re here to help. Schedule a consultation with us to get personalized guidance and make sure you’re fully prepared to take advantage of this opportunity to become one of Colorado’s first natural medicine Facilitators.
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