Colorado Natural Medicine Program

1. Introduction

Version followed: Colorado Natural Medicine Licensure Rules, 4 CCR 755-1 (DORA, Office of Natural Medicine Licensure), as published current through Colorado Register Vol. 48 No. 11 (10 June 2025), read with the Natural Medicine Health Act as rewritten by SB23-290. Status is updated to HB26-1325 (passed 12 May 2026). Rule numbers below (e.g. 6.15) refer to 4 CCR 755-1 unless another source is named.

Sources include the 150-hour training curriculum and 40-hour practicum (4 CCR 755-1 §4); the DPO list of licence pathways and the Clinical Facilitator and endorsement requirements (DPO FAQ); the titles of the state's template participant forms, including the Screening Assessment (Health History) and the Adverse Reaction Reporting Form (DPO Forms Library); and the passage of Proposition 122 in November 2022 (Axios, 15 Nov 2022). The detail of each licence pathway and the consultation rules rests on DPO pages and secondary sources rather than the text of 4 CCR 755-1 §§2–3 [uncertain]. None of the sources cited shows DMT or mescaline added to the regulated programme [uncertain].

This is a state regulated-access programme, not a psychotherapy. It sets no therapeutic model and no theory of change. What it regulates is the frame: who may facilitate, how participants are screened and consented, and how preparation, supervised administration and integration are run. Voters passed Proposition 122 (Natural Medicine Health Act of 2022) at the November 2022 general election, with about 53% support in early counts [source: Axios Denver, 15 Nov 2022]. It did two things. It decriminalised personal use of psilocybin, psilocin, DMT, ibogaine and mescaline (excluding peyote) by adults aged 21 and over, and it created a regulated access programme [source: Axios Denver, 15 Nov 2022]. SB23-290 was signed on 23 May 2023, took effect on 1 July 2023, and replaced the ballot framework [source: Vicente LLP guide to SB23-290]. (One Vicente press release gives the vote as 2023; that is an error. The election-week report confirms November 2022.)

The programme's implicit model of change runs as a sequence: careful screening, informed consent, preparation, a protected setting with a trained licensed facilitator present, and integration afterwards. Within that, the substance experience is treated as potentially beneficial and the facilitator's job is safety and support. The rules do not prescribe a mechanism [source: 4 CCR 755-1 §6; synthesis].

Legal and regulatory status (as of the sources' dates):

• Colorado:
  • Who regulates. DORA's Division of Professions and Occupations licenses facilitators and sets practice standards. The Department of Revenue's Natural Medicine Division licenses the supply chain: healing centres, cultivation, manufacturing, testing, owners and handlers. A 15-member Natural Medicine Advisory Board, appointed by the Governor, advises both agencies [source: Vicente SB23-290 guide].
  • Launch. Facilitator licensing launched on 1 January 2025 [source: Vicente SB23-290 guide]. The statute required facilitator rules and approved training programmes by 31 December 2024 [source: DPO Implementation page].
  • First healing centres. The first healing centre licence (The Center Origin, Denver) was issued in March 2025, and its first session took place in June 2025. By 3 February 2026 the state listed 9 standard and 25 micro-licensed healing centres, with 18 applications pending [source: Axios Denver, 3 Feb 2026].
• Substances. Until 1 June 2026, "natural medicine" in the regulated programme means only psilocybin and psilocin. After that date, DMT, ibogaine and mescaline (not peyote) may be added on the Board's recommendation [source: DPO Implementation page]. From the start, the Board was due to recommend by mid-2026 whether healing centres could add mescaline, ibogaine and DMT [source: Axios Denver, 15 Nov 2022].
  • Ibogaine. The Board recommended therapeutic access to ibogaine in September 2025 [source: Westword]. HB26-1325, passed on 12 May 2026 and expected to take effect on 12 August 2026, creates an ibogaine research pilot of up to five sites within the Behavioral Health Administration. The pilot works through FDA Investigational New Drug pathways, includes cardiac screening and monitoring requirements, and depends on outside funding. It does not itself create ibogaine treatment at healing centres [source: Vicente press release May 2026; Westword].
  • DMT and mescaline. In February 2026 DMT and mescaline (not from peyote) were reported as under consideration for an Advisory Board recommendation, which the Board had not yet begun discussing; only psilocybin was available in healing centres [source: Axios Denver, 3 Feb 2026]. None of the sources cited (to October 2026) shows either added. Treat the regulated programme as psilocybin and psilocin only, and check the DPO and Natural Medicine Division pages before advising a client [uncertain].
• HB26-1325 also:
  • bans advertising of natural medicine products and online sales;
  • bans sales disguised as "harm reduction" or "support services";
  • exempts bona fide harm-reduction services that do not exchange or share natural medicine [source: Westword].
• What stays illegal. Selling or dispensing natural medicine for payment remains a crime outside the licensed system. Sharing ibogaine is not protected [source: Vicente SB23-290 guide].
• US federal law. Psilocybin, DMT, ibogaine and mescaline remain Schedule I federally. Colorado licensure gives no federal protection [source: Vicente press release, for ibogaine; general Schedule I status of the others is synthesis] [uncertain for the others].
• Oregon. Oregon runs a separate licensed psilocybin services programme. Colorado rules accept licensed Oregon service centres as practicum sites [source: 4 CCR 755-1 §4].

2. Framework

The rules impose a fixed sequence for each participant [source: 4 CCR 755-1 §§6.15–6.20]. Session counts: the rules set minimums, not a course length. At least one preparation session is required (individual even for group participants), then one or more administration sessions, then at least one integration session. The first integration session may not be charged separately. Further preparation and integration sessions are allowed if their fees are disclosed in advance.

Who may provide [source: DPO Individual Applications page; DPO FAQ; 4 CCR 755-1 §§4–5; CPA poster]:

• Licence types:
  • Facilitator in Training (NMIT): the training licence used for practicum. Per a 2024 rules review, it is open to people who have completed the 150 didactic hours, and it lets them charge for services during a supervised consultation period [source: Vicente LLP Bulletin 11.5, June 2024; DPO Individual Applications];
  • Facilitator (NMF);
  • Clinical Facilitator (NMCF);
  • Distinguished Educator (NMDE).
• Pathways. DPO publishes separate licensing booklets for these pathways: Clinical Facilitator Pathway, Post Education (the standard route after an approved programme), Distinguished Educators, Facilitator and Clinical Facilitator Traditional Path, Legacy Healer Accelerated Path, Consultants, and Facilitator Endorsement [source: DPO Individual Applications]. Endorsement for a Clinical Facilitator requires a valid Colorado licence in a qualifying secondary profession plus an Oregon facilitator licence held in good standing for one year [source: DPO FAQ]. The 2024 rules review describes accelerated licensure by petition for unlicensed applicants with prior natural-medicine experience, who can be exempted from parts of the education requirements. It also describes the Distinguished Educator as an ancillary licence for very experienced practitioners, valid only within a training programme [source: Vicente Bulletin 11.5]. The eligibility and experience thresholds for the Traditional and Legacy Healer paths are set in the booklets and in 4 CCR 755-1 §§2–3 and are not given here; check them with DPO [uncertain].
• Clinical Facilitator secondary licences: the applicant must hold a current Colorado licence as one of the following:
  • psychologist;
  • licensed social worker or LCSW;
  • marriage and family therapist;
  • licensed professional counsellor;
  • licensed addiction counsellor;
  • MD or DO;
  • advanced practice nurse or nurse practitioner;
  • physician assistant.
  They must also be over 21, hold Basic Life Support (BLS) certification, and complete approved training, practicum and consultation [source: DPO FAQ].
• Approved training: at least 150 course hours across 14 mandated topic areas:
  • ethics and Colorado rules (25 h);
  • physical and mental health and safety (25 h);
  • relational boundaries and touch (10 h);
  • trauma-informed care (10 h);
  • suicide risk (5 h);
  • drug effects, contraindications and interactions (5 h);
  • Indigenous, social and cultural considerations (10 h);
  • screening (5 h);
  • preparation, administration, integration and group facilitation (10 h each);
  • facilitator best practices (5 h);
  • facilitator self-care (10 h).
• Supervised practicum: at least 40 hours, held at a licensed healing centre (or a licensed Oregon service centre):
  • at least 30 h in person in administration sessions, of which at most 10 h may be the student's own experience as a participant;
  • up to 10 h of preparation, consultation or integration, which may be done remotely by live video [source: 4 CCR 755-1 §4].
• Consultation: 50 hours of consultation is part of the baseline for both Facilitators and Clinical Facilitators, alongside the 150 didactic and 40 practicum hours [source: Vicente Bulletin 11.5, June 2024; CPA poster]. The DPO FAQ confirms that consultation is a requirement for Clinical Facilitator licensure. It adds that training programmes offering consultation to newly licensed facilitators must set out their consultation plan when they apply for approval [source: DPO FAQ; 4 CCR 755-1 §4]. The timeframe, who may act as consultant (DPO publishes a separate Consultants booklet) and any exemptions are set in 4 CCR 755-1 §3 and are not confirmed here [uncertain].
• Ongoing requirements: active BLS certification; 20 h of continuing education a year, including 5 h of ethics; participant records kept for 3 years [source: 4 CCR 755-1 §5].
• Healing centres: a healing centre may not operate unless it employs or contracts with at least one Facilitator who holds a Handler or Owner licence. Group facilitation needs enough facilitators under DORA ratios [source: 1 CCR 213-1-8-8020].

Participant eligibility [source: Vicente guide; CPA poster; 4 CCR 755-1 §6]:

• Adults aged 21 and over.
• Participants pass the facilitator's screening and risk review, with medical or behavioural-health clearance where risk factors call for it.
• None of the sources cited states that a diagnosis or a clinician's referral is required. The rules do describe referral-based pathways (6.16F) [uncertain whether self-referral is the norm; inferred].
• Out-of-state participants must be told the risks of travelling to Colorado (6.5).

3. Guiding principles

Each principle is followed by its practical meaning. Sources are 4 CCR 755-1 §6 unless stated otherwise.

• Practise within competence (6.14). Take on only the populations and situations you are trained for. Refer whoever falls outside them.
• Clinical needs go to clinical licensees (6.16F). If the screen flags a condition needing medical or behavioural-health management, a non-clinical facilitator must refer to a Clinical Facilitator or obtain written provider clearance.
• Safety screening is the facilitator's own act (6.3). Staff may collect forms, but only the facilitator completes the consent document, the touch contract and the safety screen.
• Consent is per session and revocable (6.5). Re-consent before every administration session. Document any withdrawal and honour it immediately.
• Explain how the substance affects decision-making (6.5). Settle important choices (touch, who is present, recording, the safety plan) before the session, in plain language.
• Touch is optional, minimal and contractual (6.6). Touch is limited to hands, feet and shoulders, only with written contract and training. Agree stop words or gestures. Never touch for anyone's pleasure. Examine your own motives.
• Not impaired (6.11). Do not use natural medicine or other intoxicants while facilitating. Do not start a session if your own state could impair you, and have a contingency plan.
• Prevent physical and psychological harm (6.17). Monitor vital signs, hydration and psychological wellbeing. Keep the participant in the session space, and restrict movement that is dangerous.
• Tell side effects from emergencies (6.7). Know the expected effects. If something is beyond them, call emergency services or medical professionals at once.
• Transparency (6.15C, 6.15F). Give written credentials and disciplinary history, all fees, termination and transfer procedures, product information, alternate facilitators, regulator contacts and participant rights.
• Confidentiality with stated limits (6.4). Explain in writing the mandatory-reporting and duty-to-warn exceptions, and the limits of confidentiality in groups. Share only the minimum necessary.
• No exploitation or dual relationships (6.8–6.10, 6.12).
  • No romantic or sexual contact with participants, their partners or family during services and for two years after.
  • Do not serve people you supervise or evaluate.
  • No financial dealings that breach loyalty.
  • No services offered to build a personal relationship.
• Dual licensees follow the stricter code (6.7B, 6.10D). If you are also a psychotherapist, the stricter of the two ethics codes and relationship rules governs.
• No referral fees; clean referrals (6.21, 6.20). Do not accept or pay referral fees. Refer without reciprocity, brokering or deception.
• End services that are not helping (6.20). Terminate and refer when the participant is not benefiting, is unlikely to benefit, or is being harmed.
• Report serious harm fast (6.23). Report any life-threatening or serious adverse health event to the Director within 24 hours.
• Cultural humility toward Indigenous traditions. Training carries a mandatory Indigenous, social and cultural component. DORA must convene a Tribal and Indigenous Working Group on commercialisation and exploitation [source: 4 CCR 755-1 §4; Vicente guide]. Practically: do not present programme sessions as Indigenous ceremony.
• Advertising limits. Advertising is restricted, including testimonials [source: CPA poster] [uncertain on detail: the limits are set in 4 CCR 755-1 §7].
• Professional protection is not permission (statute). Licensed professionals cannot be disciplined solely for providing or advising on natural medicine. Conduct outside their scope or standards is still discipline-able [source: Vicente guide]. Practically: as a psychotherapist you may advise and do integration within your own licence. You may not facilitate administration without a natural-medicine licence.

4. Intervention inventory

The programme prescribes procedures, not psychotherapeutic techniques. Below are all the participant-facing procedures that 4 CCR 755-1 §6 requires, in order, plus (4.18–4.20) the roles open to a psychotherapist outside the programme. The rules do not prescribe how to accompany a participant psychologically during the session. Any guidance on that is marked [synthesis]. No doses, dose tiers or administration details are given here: the rules make dosing the facilitator's decision "following accepted standards" (6.17) and a referral order's dosing must be followed (6.16F). That remains outside this guide.

State template forms. DPO's Natural Medicine Program Forms Library publishes template participant forms that map onto the procedures below. They are: Documentation and Consent Checklist; Guide and Disclaimers on the Forms Library; Facilitator Required Disclosures; Screening Assessment (Health History); Informed Consent; Safety Plan (Environmental Risks); Supportive Touch Contract; Transportation Plan; Disclosures on Privacy and Confidentiality; De-Identified Data and Opt Out; Fees, Termination, and Alternate Location; Demographic Data Collection and Outcome Reporting 2025; Medication and Medical-Assistive Devices; Consent for Video and Audio Recording of Administration Session(s); and Adverse Reaction Reporting Form [source: DPO Natural Medicine Program Forms]. Only the titles are cited here; the contents are not summarised. The library includes a guide and disclaimers, so it is not certain whether each template is mandatory or only a model [uncertain].

4.1 Initial consultation (6.15A)

• Purpose: decide whether the person is a candidate and whether they want you. Check whether your competence matches their needs.
• Steps:
  1. Explain what the programme is and isn't (supervised psilocybin services, not a treatment for a named diagnosis unless you are a Clinical Facilitator acting under your secondary licence) [synthesis on framing].
  2. Ask what is bringing them and what they hope for.
  3. Ask about broad medical, psychiatric and medication history, enough to judge fit.
  4. Decide: proceed to screening, refer to a Clinical Facilitator, or refer elsewhere.
  5. Note the outcome in the participant record.
• Example language (illustrative): "Before anything else, I want us both to see whether this is a good fit, and whether I'm the right facilitator for what you're carrying. If not, I'll help you find who is."
• Watch for: expectations of cure; pressure from a partner or employer; signs that the request belongs in clinical care first. It is working when the person can state their reasons and understands that the next step is a formal screen.

4.2 Safety screening and risk review (6.15B, 6.16F, 6.3)

• Purpose: identify medical, psychiatric and medication risks before any administration.
• Steps:
  1. Give the written screening tool. The rules require each prospective participant to receive the facilitator's written screening tool, and the facilitator must carry out a safety assessment "using a safety screening tool that reflects generally accepted standards of practice", including medical history and a thorough evaluation of risk factors from the participant's medical information; the rule names no particular instrument and does not require a state form. [source: 4 CCR 755-1 6.15(B), 6.16(F)] DPO's Forms Library offers a template "Screening Assessment (Health History)" and a "Medication and Medical-Assistive Devices" form [source: DPO Forms]; their items are not reproduced here [uncertain].
  2. Personally review every answer. Only the facilitator completes the safety screen.
  3. Discuss with the person when they may or may not be a suitable candidate.
  4. For each flagged risk factor, proceed only after a direct referral from, medical clearance by, or documented consultation with a qualified provider.
  5. If you are not a Clinical Facilitator and the condition needs management, refer to a Clinical Facilitator or get written clearance from a provider.
  6. Have the participant attest to a complete medical history.
• Risk areas named in sources:
  • significant mental-health risk;
  • suicide risk;
  • lithium or antipsychotic medication, which a Clinical Facilitator handles only after consulting the participant's prescriber;
  • drug contraindications and interactions [source: CPA poster, secondary].
  Where risk factors are found, the facilitator must make sure the participant understands the risks, and the rules specify when a third-party (provider) opinion is required [source: Vicente Bulletin 11.5]. The state template's specific exclusion items are not reproduced here [uncertain]. Commonly screened areas in trial programmes are personal or family history of psychosis or bipolar disorder, cardiovascular disease and pregnancy [synthesis; not from Colorado sources].
• Example language (illustrative): "Some of these questions are about medications and family history. A 'yes' doesn't automatically rule you out; it means we bring in your prescriber or a clinical facilitator before deciding."
• Watch for: under-reporting by people who very much want to proceed; medication changes made without the prescriber; denial of suicidality. It is working when every flagged item has a documented resolution.

4.3 Required written disclosures (6.15C, 6.15D, 6.15F)

• Purpose: informed choice and transparency.
• Steps: provide in writing, with signatures where required:
  • all your licences and certificates, any disciplinary history, and your professional domains;
  • signed cost disclosures: every fee type, add-ons, refund and cancellation policy, collection practices, and the confidentiality risk of third-party collection;
  • termination and transfer procedures;
  • for private-residence sessions, the availability of healing centres and the associated risks;
  • signed statements on your medical knowledge and on possible interactions with medical conditions or medications;
  • product information and manufacturer labels;
  • information about alternate facilitators;
  • a signed discharge plan with safe transport home;
  • for group sessions, the number of other participants;
  • for Clinical Facilitators, written documentation of the scope of your secondary licence and when you may practise psychotherapy or medicine during any phase.
  Before each session, give your contact details, the applicable regulations, your training credentials, regulator contacts, and the participant's rights to information, to end services and to withdraw touch consent.
• Example language (illustrative): "This sheet tells you exactly what I charge, what happens if you cancel, and how to complain to the state if you need to."
• Watch for: participants skimming documents. Check understanding verbally [synthesis].

4.4 Informed consent (6.5, 6.16D)

• Purpose: valid, documented consent before every administration session.
• Steps:
  1. Explain scope of services, the natural medicine, risks, benefits, alternatives and the termination process.
  2. Describe in plain language how the substance affects consciousness and decision-making.
  3. Explain the written limits of confidentiality: mandatory reporting and duty to warn.
  4. Disclose fees and payment before any billable service.
  5. Name any assistants, observers or staff in advance.
  6. Tell the participant of their right to request an additional non-participant (who may be a licensed facilitator) and a video recording. Allow both if requested. Any extra person must meet the participant beforehand.
  7. If recording, explain purpose, storage and use, and get consent from everyone present. Release recordings only with explicit permission specifying use, recipients and terms.
  8. For travellers from another state, explain the risks of travelling to Colorado.
  9. Document consent and any later withdrawal.
• Example language (illustrative): "While the medicine is active your judgement may shift, so we're making the important decisions now, while you're clear. You can still say stop to anything at any time."
• Watch for: consent given under time pressure. It is working when the participant can repeat back the key risks and their rights [synthesis].

4.5 Physical touch contract (6.6)

• Purpose: prevent boundary violations; make any supportive touch explicit and revocable.
• Steps:
  1. Offer supportive touch as optional, never as part of the method.
  2. If chosen, limit it to hands, feet and shoulders, and only if you are trained in it.
  3. Agree words or gestures that stop touch, and stop at once when they are used.
  4. Explain the safety exceptions in advance: preventing imminent harm, life-saving procedures, vital-sign checks, help to the restroom, preventing falls.
  5. Everyone who may be present signs.
  6. In groups, touch between participants needs specific consent naming the individuals. You may forbid all participant-to-participant touch, recorded in the contract.
• Example language (illustrative): "Some people like a hand on the shoulder, some don't want any touch. Both are fine. If you want touch to stop, say 'stop' or raise your hand, and it stops immediately."
• Watch for: your own motives (the rules require you to examine them); requests for touch beyond the contract during the session, which you decline kindly; participants who agree to touch in order to please you.

4.6 Pre-administration attestations, safety and support plans (6.15E, 6.3)

• Purpose: a shared written record of health history, identified risks, goals and touch parameters, plus safety and support plans.
• Steps:
  1. Both parties sign attestations covering complete health history, identified risks, the participant's goals and agreed touch parameters.
  2. Write a safety plan: what happens if distress escalates, who the emergency contacts are, and the medical escalation route.
  3. Write a support plan for the days after the session [content of plans synthesis; the rules name the plans without specifying their contents].
  4. Confirm the transportation plan.
• Example language (illustrative): "Let's write down who you'll be with tonight and tomorrow, and who you'd call if things feel heavy afterwards."
• Watch for: isolated participants with no support person. Consider extra integration contact [synthesis].

4.7 Preparation session(s) (6.16)

• Purpose: complete missing screening and disclosures, finalise consent, and prepare the participant psychologically.
• Steps:
  1. Hold at least one individual preparation session, including for group participants.
  2. Finish any outstanding screening, risk review and disclosures.
  3. Complete full consent, including the right to additional people and recording.
  4. Have the touch contract signed by all who may be present.
  5. Meet the timing rule between preparation and the first administration session where it applies to the dose tier.
  6. If the session will take place at a non-healing-centre location and preparation was not held there, inspect the location and get the participant's consent to the arrangement.
  7. Psychological preparation (illustrative content, [synthesis]): intentions; what the experience can be like, including frightening material; how to move toward rather than away from difficult content; agreed ways to ask for help; the rules for staying in the space.
• Example language (illustrative): "If something frightening comes up, you don't have to fight it or solve it. You can tell me, and I'll stay right here."
• Watch for: high anxiety, rigid expectations, or new disclosures that change the risk picture. Re-screen if needed. Additional paid preparation sessions are permitted.

4.8 Conduct and monitoring during the administration session (6.17, 6.11, 6.14)

• Purpose: physical and psychological safety while the participant is under the substance's effects.
• Steps:
  1. Be present in person, in Colorado, unimpaired.
  2. If you cannot attend, reschedule as soon as possible, use the backup facilitator named in consent, or cancel and refer.
  3. Re-confirm consent, touch terms and who is present.
  4. Take reasonable steps to prevent harm: monitor vital signs, hydration and psychological wellbeing. Interpretation of medical findings belongs to medical professionals [synthesis on the division of roles].
  5. Keep the participant in the administration space and restrict movement that endangers anyone.
  6. Continue the session until no obvious adverse effects remain. The rules also set a minimum length by dose tier (not reproduced).
  7. Psychological stance, which the rules do not specify [synthesis]: quiet, non-directive presence; minimal talk; reassurance when asked; no interpretation or therapeutic agenda imposed during the peak.
• Example language (illustrative): "You're safe. I'm right here. Your body is doing what it needs to; just keep breathing."
• Watch for: escalating panic, agitation, attempts to leave, signs of medical distress. Distinguish expected effects from emergencies (4.12).

4.9 Additional persons, co-facilitation and video recording (6.5, 6.18G)

• Purpose: an independent safeguard against misconduct and harm.
• Steps:
  1. Offer the participant the right to request a second non-participant and a video recording, and grant either if requested.
  2. Make sure any additional person meets the participant before the session and signs the touch contract.
  3. Outside healing centres, either have at least one more facilitator present throughout or provide a video recording.
  4. Handle recordings under the consent terms in 4.4.
• Example language (illustrative): "You're entitled to have a second facilitator in the room, or a recording, as an extra safeguard. Many people choose one; it's completely your call."
• Watch for: a participant who declines and seems uneasy about it. Revisit before the session. At alternative locations, you cannot proceed if the participant refuses both a second person and recording (6.18).

4.10 Group administration sessions (6.17G, 6.15D, 6.6)

• Purpose: shared sessions with adequate staffing.
• Steps:
  1. Run a group only at your discretion and with each participant's individual consent.
  2. Make sure everyone attending is known to the participants beforehand.
  3. Keep within the ratio: generally no more than 4 participants per facilitator, with an overall cap of 64 per session. A looser ratio applies only when every participant is in a low-dose tier (amounts not reproduced).
  4. Make the group touch rules explicit.
  5. Explain the limits of confidentiality in groups.
  6. Hold an individual preparation session for each member.
• Example language (illustrative): "In this room, what others share stays here, but I can't guarantee what other participants do with it outside, so share what feels right."
• Watch for: contagion of distress between participants. Have a plan to give one person individual attention without leaving the group under-staffed [synthesis].

4.11 Sessions at authorised locations outside healing centres (6.18)

• Purpose: access for people who cannot attend a healing centre.
• Who is eligible: people receiving or eligible for palliative care, people in hospice, people with disabilities as defined by the ADA, and homebound people meeting the stated criteria.
• Which locations: the participant's private residence (where they have a legal right to occupy it for at least three months), licensed medical or rehabilitation facilities, and licensed mental-health treatment facilities, with some exclusions.
• Facilitator requirements: affiliation with a healing centre or a Business Owner licence; a Handler licence; and either 50 hours of healing-centre administration experience or a palliative or hospice specialty certification.
• Steps:
  1. Review and inspect the location beforehand.
  2. Give the private-residence risk disclosures.
  3. Hold individual sessions only, with no one under 21 present.
  4. Have a second facilitator present or a video recording; you cannot proceed if both are declined.
  5. Comply with the law on product transport and storage, and return or secure unused product as the law requires (the procedure is a facilitator-licensing matter and is not detailed here).
• Watch for: frailty, interactions with palliative medications. Coordinate with the treating medical team [synthesis].

4.12 Emergency response (6.7, 6.17)

• Purpose: timely medical help.
• Steps:
  1. Know which effects are typical and which signal an emergency.
  2. In an emergency, contact emergency responders or appropriate medical professionals at once.
  3. Use the safety plan and the agreed emergency contacts.
  4. Document what happened.
  5. Report to the Director if the event is serious (4.15).
• Example language (illustrative): "I'm going to get a medical check for you now. That's part of keeping you safe, not a sign that anything is wrong with you."
• Watch for: delaying a call to avoid disrupting the experience. The rules put safety first.

4.13 Discharge and safe transport (6.15C, 6.3)

• Purpose: the participant leaves safely.
• Steps:
  1. Confirm that no obvious adverse effects remain.
  2. Activate the signed discharge plan, with transport home by someone other than the participant driving [the no-driving element is synthesis; the rules require "safe transportation"].
  3. Confirm the support person and the integration appointment.
• Example language (illustrative): "Your ride is here. Tonight, keep things simple. We'll meet for integration on the day we set."
• Watch for: residual disorientation. Extend the session rather than discharge.

4.14 Integration session(s) (6.19)

• Purpose: review the session, evaluate the participant's reaction, recommend follow-up care and refer as needed.
• Steps:
  1. Offer the first integration session without a separate fee.
  2. Review the whole administration session with the participant.
  3. Assess their current state, including mood, sleep, safety and any persisting perceptual or emotional effects [the specific checks are synthesis].
  4. Help them translate insights into concrete, small changes [synthesis].
  5. Recommend follow-up care: psychotherapy, medical review, peer support.
  6. Refer where indicated.
  7. Offer further sessions if their fees were disclosed.
  8. Hold group integration only with each person's consent.
• Example language (illustrative): "Let's go through it from the start. What stands out now, a few days later? What, if anything, do you want to do differently because of it?"
• Watch for: destabilisation, new suicidal thoughts, grandiosity, or a sense of being 'stuck' in difficult material. These call for referral to a mental-health clinician. It is working when the participant can describe the experience coherently and relate it to their life with balanced appraisal [synthesis].

4.15 Adverse-event reporting (6.23, 6.3, 6.22)

• Purpose: regulatory oversight of serious harms.
• Steps:
  1. Report every life-threatening or serious adverse health event to the Director within 24 hours.
  2. Record all adverse events in the participant record.
  3. Submit de-identified data, including adverse events and outcomes, when the Director requests it.
  Form: the rule requires the report to the Director within 24 hours but does not name a form or method [source: 4 CCR 755-1 6.23(B)]. DPO's Forms Library includes an "Adverse Reaction Reporting Form" template [source: DPO Forms]; confirm the current submission channel with the Office of Natural Medicine Licensure [uncertain]. On the supply-chain side, healing centres must also report medical and emergency incidents on their premises, and deaths within 30 days of a person receiving services [source: Vicente Bulletin 11.5, summarising the Department of Revenue rules].
• Watch for: under-reporting of psychological adverse events that emerge after the session day. Ask about them at integration [synthesis].

4.16 Termination and referral (6.20)

• Purpose: stop services that are not helping or are harmful.
• Steps:
  1. Keep a written termination protocol.
  2. Terminate when the participant is not benefiting, is unlikely to benefit, is being harmed, or when you cannot give adequate care. You may also terminate if you are threatened.
  3. Refer to another facilitator, healing centre or provider, without reciprocity or brokering.
  4. Respect the participant's right to end services at any time.
• Example language (illustrative): "I don't think further sessions with me are the right thing for you now. Here are people who can help with what's come up."
• Watch for: participants seeking repeated sessions as a substitute for other care [synthesis].

4.17 Records, confidentiality and data (6.3, 6.4, 6.22, 5.3)

• Purpose: an accountable, private record.
• What the record must hold:
  • demographics, consent, communication preferences, transport plan and fee agreement;
  • the touch contract, safety and support plans, and the safety screen;
  • session dates and times, and product details;
  • adverse events and outcomes;
  • recording and additional-person disclosures, and the 6.15 disclosures.
• Steps:
  1. Keep records searchable by name for at least three years, store them securely and destroy them securely.
  2. Give participants copies on request, with other participants redacted.
  3. Clinical Facilitators follow any stricter record rules of their secondary licence.
• Watch for: a psychotherapy record and a facilitation record that are mixed together. Keep them distinct and clearly labelled [synthesis].

4.18 For psychotherapists outside the programme: referral to licensed services [synthesis grounded in programme rules]

• Purpose: connect an interested client to lawful, supervised services.
• Steps:
  1. Explore the client's reasons and expectations.
  2. Explain the programme: adults aged 21 and over, licensed facilitators, healing centres, mandatory screening, preparation and integration.
  3. Help the client verify a facilitator's licence on DORA's licence lookup and check any discipline.
  4. Note that clients with psychiatric conditions or medications such as lithium or antipsychotics are likely to need a Clinical Facilitator and prescriber involvement [source: CPA poster; 6.16F].
  5. With the client's written consent, share relevant history with the facilitator.
  6. Do not accept referral fees (6.21 applies to licensees; it is also standard ethics) [synthesis].
• Example language (illustrative): "If you decide to explore this, I'd want it to be through a licensed facilitator, and I'm glad to talk with them, with your permission, so your care stays joined up."
• Watch for: clients choosing unlicensed paid providers. See 5.

4.19 Coordinated pre- and post-session psychotherapy [synthesis]

• Purpose: support preparation and integration from within your own licence. Professional protections cover advising on natural medicine, not administering it (Vicente guide).
• Steps:
  1. Assess readiness and stability before the client's programme screening.
  2. Work on coping skills for strong emotions.
  3. After the session, run integration within your usual modality.
  4. Monitor for adverse psychological effects and liaise with the facilitator if consented.
  5. Document as ordinary psychotherapy.
• Watch for: role confusion. If you also hold a facilitator licence, apply the stricter code and consider whether facilitating for your own psychotherapy client creates a conflict that "materially limits" care (6.21, 6.10D).

4.20 Harm reduction for clients using under decriminalisation [synthesis]

• Purpose: reduce risk for adults who use outside the regulated programme, which is lawful personal use in Colorado for adults aged 21 and over but not federally.
• Steps:
  1. Assess the context of use.
  2. Ask about medications and health conditions, and give general education that interactions and psychiatric vulnerabilities exist, without dosing.
  3. Encourage a sober, trusted person to be present and a safe setting.
  4. Make an emergency plan.
  5. Screen for warning signs: psychosis history, active suicidality, heart problems.
  6. Refer to medical care or the licensed programme.
  7. Offer integration afterwards.
  8. Never help the client obtain substances, and do not run or attend use sessions.
• Example language (illustrative): "I'm not going to help you get or use anything, but I do care about you being safe. Can we talk through what could go wrong and who'd be there?"
• Watch for: paid "support services" that include supplying natural medicine. HB26-1325 restricts these (Westword).

5. Handling problems

The rules give a procedural response to some of these problems; each item names its source. Psychological guidance is [synthesis] unless a source is named.

• Screen flags a risk; participant insists on proceeding.
  • Rules: you may proceed only after referral, clearance or documented consultation. A non-clinical facilitator refers to a Clinical Facilitator (6.16F). You may decline and refer (6.15A, 6.20).
  • [synthesis] Name the specific risk and the next step, not a verdict: "Not now, and here's how we find out whether later is possible."
• Under-disclosure suspected (e.g. medication not mentioned).
  • Rules: the participant attests to a complete history (6.16F, 6.15E).
  • [synthesis] With consent, ask permission to contact the prescriber, and pause until the gap is resolved.
• Participant withdraws consent or wants to stop mid-session.
  • Rules: honour the withdrawal and document it (6.5). Touch stops on the agreed signal (6.6).
  • The participant still stays in the space until no obvious adverse effects remain, and movement that endangers them may be restricted (6.17). Explain this tension in preparation [synthesis].
• Overwhelm or a frightening experience during the session.
  • [synthesis] Lower stimulation; steady, brief reassurance; orient to breath and to your presence. Touch only as contracted.
  • Escalate to medical help if the signs go beyond expected effects (6.7).
  • Record the event and assess it at integration. Report it if serious (6.23).
• Participant tries to leave or behaves dangerously.
  • Rules: restrict movement that endangers anyone (6.17). Physical intervention is permitted only under the touch-contract exceptions for imminent harm or preventing falls (6.6).
  • Call emergency responders if safety cannot be kept (6.7).
• Persisting distress after the session (anxiety, low mood, sleep loss, derealisation, intrusive memories, suicidal thinking).
  • [synthesis] Do a structured risk assessment at integration using standard suicide-risk practice. Make a safety plan, including lethal-means counselling (storage and removal). Refer to psychotherapy or psychiatry.
  • Report as an adverse event if serious (6.23). Recommend follow-up care (6.19).
• Stuck in integration: the client repeats the narrative and nothing changes.
  • [synthesis] Shift from meaning-making to small behavioural commitments. Link the material to ongoing psychotherapy. Avoid booking further administration sessions as the solution (6.20).
• Non-adherence (missed preparation, unsafe transport plan, skipped integration).
  • Rules: the required preparation must be completed before administration (6.16), and a signed discharge plan with safe transport is mandatory (6.15C).
  • [synthesis] Postpone rather than proceed. Follow up skipped integration actively.
• Rupture or boundary concerns (touch felt intrusive, participant feels exploited, fee dispute).
  • Rules: stop touch, revisit the contract and document (6.6). Give the regulator's contact details and the complaint route (6.15F; DPO complaints).
  • [synthesis] Acknowledge the participant's experience without defensiveness. Offer an alternate facilitator (6.15C) or another provider.
  • Sexual or romantic contact is prohibited during services and for two years afterward (6.10).
• Facilitator unwell or impaired on the day.
  • Rules: do not start (6.11). Reschedule, use the named backup, or cancel and refer (6.17A).
• Group problems (one member's distress unsettles others; boundary breaches between participants).
  • Rules: keep the ratios (6.17G) and enforce the group touch rules (6.6).
  • [synthesis] Assign one facilitator to the distressed person while the others hold the room. Address breaches in group integration with each person's consent.
• Client (of an outside psychotherapist) is using an unlicensed paid "guide", retreat or "support service".
  • DORA has issued cease-and-desist orders alleging unlicensed facilitation [source: Westword]. HB26-1325 restricts sales disguised as support services.
  • [synthesis] Discuss the safety and legal risks without judgement, encourage licensed services, and offer integration. Consider whether a complaint to DPO or DOR is warranted; respect confidentiality and report only where the law requires.
• Client asks about ibogaine, DMT or mescaline.
  • These are decriminalised for personal use by adults but not available through the regulated programme as of the sources cited. Ibogaine is only at the research-pilot stage under HB26-1325, which includes cardiac screening [source: Vicente press release; Westword; DPO Implementation].
  • [synthesis] Explain in general terms that ibogaine carries serious cardiac risk. Strongly encourage medical evaluation and research settings. Do not give use information.
• Out-of-state client planning travel to Colorado.
  • Rules: travel risks must be disclosed (6.5).
  • [synthesis] Plan aftercare in the client's home state. Remind the client that bringing natural medicine across state lines is outside Colorado's protections.
• Indigenous and cultural concerns (client feels the programme appropriates ceremony; Indigenous client seeks traditional use).
  • Some Indigenous voices have objected publicly to the programme [uncertain: secondary, unverified].
  • [synthesis] Respect the client's views. Refer to community-held authority for ceremonial matters and do not run or describe ceremony.
• Dual role: your psychotherapy client asks you to be their facilitator.
  • Rules: avoid conflicts that materially limit care (6.21). Apply the stricter code (6.7B, 6.10D). Clinical Facilitators must document when they practise psychotherapy within facilitation (6.15C).
  • [synthesis] Generally prefer referral to a different facilitator, with coordination, unless your board's guidance clearly supports combining the roles.

Sources

Web sources:

• 4 CCR 755-1 Section 6, Standards of Practice (Justia, current through Colo. Reg. Vol. 48 No. 11, June 2025)
• 4 CCR 755-1 Section 4, Approved Facilitator Training Programs
• 4 CCR 755-1 Section 5, Requirements for All Licensees
• 4 CCR 755-1, table of sections
• 1 CCR 213-1-8-8020, Facilitator Required (Department of Revenue Natural Medicine rules)
• DPO Natural Medicine FAQ (training programmes, Clinical Facilitator)
• DPO Natural Medicine, Individual Applications and Forms
• DPO Natural Medicine, Implementation (key dates)
• Vicente LLP, The Ultimate Guide to Colorado's Natural Medicine Health Act (SB23-290)
• Vicente LLP press release, Colorado legislature passes ibogaine research bill (May 2026)
• Axios Denver, Colorado psychedelic therapy program considers expanding options (3 Feb 2026)
• Westword, Colorado ibogaine law and psilocybin mushroom sales (2026)
• Nicholson B., Navigating the Psychedelic Frontier (Colorado Psychological Association student poster; secondary)
• DPO, Natural Medicine Program – Forms (Forms Library titles)
• Vicente LLP, Natural Medicine Advisory Bulletin 11.5: Rule Review & Roadmap (13 June 2024)
• Axios Denver, Psychedelic mushrooms legalized in Colorado (15 Nov 2022)
• DPO, Natural Medicine Health Act FAQs

Not confirmed from primary text [uncertain]:

• 4 CCR 755-1 §2 (Licensure) and §3 (Experience and education): pathway thresholds and consultation rules are taken from DPO pages and secondary sources.
• §7 (Advertising).
• The DPO Natural Medicine home page.
• The content of the DPO Screening Assessment (Health History) template (title only cited).
• The content and submission route of the DPO Adverse Reaction Reporting Form (title only cited).

Statutes referred to:

• Natural Medicine Health Act of 2022 (Proposition 122).
• SB23-290 (2023).
• C.R.S. title 12, article 170.
• HB26-1325 (2026).