Atlas›Domain VII · Transpersonal, psychedelic & altered states›Guide 077
Guide VII-077

Utah psilocybin pilot

2024Utah, USA
A 31 · L 58 · M 1116 interventions in the Trinity explorer
Client cardCompare
[source: …] where a claim comes from[uncertain] not confirmed in a primary source[synthesis] the writer's reconstruction

1. Introduction

Version followed: Utah Code 58-37-3.5 as enacted by 1st Substitute S.B. 266 (2024 General Session, "Medical Practice Amendments"), effective 1 May 2024, now renumbered as Utah Code 58-37-309 ("Drugs for behavioral health treatment") by Chapter 362, 2026 General Session, in the version effective 6 May 2026. Verified on 14 Oct 2026 against le.utah.gov: the current section text, the Legislature's May 2026 sunset review, and the introduced text of 2025 S.B. 248. The current text contains none of S.B. 248's changes, so S.B. 248 evidently was not enacted [source: Utah Code 58-37-309; OLRGC sunset review 2026]. 2026 H.B. 390 (a separate veterans' PTSD research study, not an amendment to this section) was checked against its enrolled text. Still unconfirmed: whether any health system has launched a programme under this section, and details of Johnson et al. 2008 beyond its abstract and a secondary summary [uncertain]. Clinical-frame guidance comes from the Utah Mental Illness Psychotherapy Drug Task Force report to the Legislature (October 2022), the state's own advisory document, and from Johnson, Richards and Griffiths (2008), the Johns Hopkins safety guidelines.

What it is. This is a legal authorisation, not a therapy. S.B. 266 added section 58-37-3.5 to Utah's Controlled Substances Act, and it became law without Governor Cox's signature in March 2024. In 2026 the section was renumbered as 58-37-309. It lets a qualifying healthcare system set up a "behavioral health treatment program" that includes treatment with psilocybin or MDMA. The drug must be a form in FDA Phase 3 investigational testing, and the system must judge the treatment to be supported by a broad body of scientific and medical research. The statute does not use the word "pilot". Media call it one because it is time-limited and tied to reporting. [source: SB0266S01; Utah Code 58-37-309; FOX 13, 28 Feb and 21 Mar 2024]

  • Who may provide: only a qualifying healthcare system. The 2024 text named two kinds: (i) a private, non-profit, vertically integrated health system running at least 15 licensed hospitals in Utah, and (ii) a health system closely affiliated with a state institution of higher education. The 2026 renumbered text (58-37-309, effective 6 May 2026) adds (iii) a system closely affiliated with a private postsecondary institution. [source: SB0266S01; Utah Code 58-37-309] Intermountain Health and University of Utah Health are the systems generally understood to qualify. In June 2024 the bill's sponsor said Intermountain physicians wanted to set up a clinic, and that the University of Utah system "became interested as well". [source: Daily Utah Chronicle, 10 Mar 2025; Cullimore interview, The Microdose, 24 Jun 2024] No public announcement that either system has launched a programme under this section has been identified, and the Legislature's May 2026 sunset review names no operating programme [uncertain]. Separately, 2026 H.B. 390 authorises the University of Utah's Huntsman Mental Health Institute to run a research study for veterans (see Status below); that study is not a programme under this section. [source: OLRGC sunset review 2026; HB0390 enrolled]
  • Conditions: patients take the drug only under the direct supervision and control of the health system and its Title 58-licensed providers. The 2026 text keeps "direct". No one under 18 may be treated under this authority. People who comply are not guilty of a Title 58 (state drug law) violation. The statute says nothing about civil liability; the sponsor said the bill leaves "the liability and risk to the health systems". [source: Utah Code 58-37-309; Cullimore interview 2024]
  • Reporting and sunset: before 1 July 2026, each system that creates a programme must give the Health and Human Services Interim Committee a written report. It covers the drugs used, patient outcomes, side effects and anything else needed to judge medicinal value. At the committee's 20 May 2026 sunset review, staff stated that no report had yet been received. The repeal (sunset) date is 1 July 2027 under Utah Code 63I-1-258. That gives a window of about three years from May 2024. [source: Utah Code 58-37-309; OLRGC sunset review 2026]
  • What the statute does not set: eligible diagnoses, screening rules, consent content, therapy structure, staffing ratios, therapist training or touch rules. All of these are left to the health system's own protocols. The sponsor said this was deliberate: the bill was not "too prescriptive" and left these questions "to the institutions". No such protocol was found published [uncertain]. [source: Cullimore interview 2024]
  • 2025 amendment bill S.B. 248, not enacted: S.B. 248 ("Controlled Substances Amendments", sponsor Sen. Cullimore) was introduced to:
    • add Title 58-licensed palliative-care providers and psychiatrists with five years' licensure and residence as eligible providers;
    • change "direct" supervision to "indirect";
    • extend the drug definition to natural forms;
    • move the report deadline to 1 July 2027 and the repeal to 1 July 2029;
    • keep psilocybin and MDMA in Schedule I, with automatic state rescheduling of a crystalline-polymorph psilocybin product if federal scheduling changes.
    The Senate Health and Human Services Committee recommended a 1st Substitute 5-0 on 28 Feb 2025. None of these changes appears in the current section: it still requires direct supervision, has no palliative-care or psychiatrist category, and the 2026 sunset review still gives the 2026 report and 2027 repeal dates. S.B. 248 therefore evidently did not become law; this is inferred from the current code, and the final legislative action is [uncertain]. [source: SB0248 introduced; SB248S10 committee report; Utah Code 58-37-309; OLRGC sunset review 2026] The same crystalline-polymorph rescheduling clause also appeared in 1st Substitute H.B. 500 (2025, "Controlled Substance Modifications"); its final status is [uncertain].
  • Status as of 2026: at its 20 May 2026 review, the Legislature's committee had received no programme report, and the review names no operating programme. [source: OLRGC sunset review 2026] A secondary legal explainer dated 21 June 2026 says neither health system had publicly announced a fully operational clinic. It names federal Schedule I status and drug supply as the main barriers. [source: Mind Medicine Law explainer, secondary] 2026 H.B. 390 ("Veterans PTSD Clinical Research Amendments", sponsors Rep. Dailey-Provost and Sen. Cullimore) was signed on 19 March 2026 and takes effect on 6 May 2026. It does not amend 58-37-309. It enacts Utah Code 26B-7-126, which authorises the Huntsman Mental Health Institute to run a clinical study of the safety and feasibility of psychedelic-assisted therapy (an investigational hallucinogenic controlled substance, such as MDMA, psilocybin or 5-MeO-DMT, given in a controlled clinical setting with manualised, trauma-informed preparatory and integrative psychotherapy) for veterans whose PTSD has not responded to at least one evidence-based treatment. Before starting, the Institute must meet FDA investigational-drug requirements, hold DEA Schedule I research registration, obtain IRB approval and have protocols for safety monitoring, drug administration and therapist fidelity. The study is to begin by 1 January 2027 if funding is sufficient, otherwise once it is; it is funded by appropriations and donations, reports to the HHS Interim Committee, and the section is repealed on 1 July 2032. The University describes it as a research study, not public access or legalisation; enrolment depends on funding. [source: HB0390 enrolled; University of Utah Health news, 24 Apr 2026; Deseret News, 16 Feb 2026] For clients who are veterans, this is a research route, reached through the study team, not a treatment programme. Federally, psilocybin and MDMA remain Schedule I. Neither has FDA approval in the sources used. [source: SB0248 introduced; Task Force 2022]

How change is meant to happen. The statute takes no position on therapeutic mechanism. The Task Force describes the model as psychedelic-assisted psychotherapy: a drug session sits inside a frame of preparation, continuous psychotherapeutic support during the session and integration afterwards. Change is attributed to the whole package of drug, therapy, set and setting. [source: Task Force 2022] Any more specific theory of change belongs to the trial protocol a health system adopts, not to Utah law [synthesis].

2. Framework

The law sets no phases. The sequence below combines the Task Force's recommended structure (which is advisory, not binding) with the statutory duties. [source: Task Force 2022; SB0266S01]

PhaseGoalTypical format (Task Force recommendation)Move on when
0. Referral and intakeConfirm the client is an adult under the care of a qualifying system and has a referring clinicianClinician-to-clinician referral; no self-referral [source: Task Force 2022; Mind Medicine Law, uncertain]The system accepts the referral
1. ScreeningExclude medical and psychiatric contraindications; assess psychosocial supportPsychiatric assessment, medical history, labs and ECG as the medical team decidesNo exclusion criteria met; support person and transport arranged
2. ConsentEnhanced informed consentWritten consent plus a patient-friendly safety handoutClient shows understanding and signs
3. PreparationRapport, expectations, psychoeducation2–3 sessions of 1–2 hours; at least one before any medication session; Johnson et al. add one meeting in the session roomTrust established; client can describe what may happen and how the team will respond
4. Supported medication session(s)Safe, supported experienceFull-day session on site, in person, with continuous psychotherapeutic support; at least one mental health therapist present throughout; two-monitor team (Johnson et al.)Medical and psychological criteria for leaving are met (set by the medical team); support person collects the client
5. Follow-up and integrationCheck stability; make sense of the experience; track outcomesNext-day contact (Johnson et al.); 2–3 integration sessions of 1–2 hoursStable functioning; outcome measures recorded for the system's report
6. ReportingMeet statutory dutySystem-level written report on drugs, outcomes and side effects to the LegislatureStatutory deadline

This guide gives no medication amounts, number of medication sessions, timing or route. Those decisions belong to the prescribing physician and the adopted protocol.

3. Guiding principles

[source: Task Force 2022 unless marked; Johnson et al. 2008 via summary]

  • Treatment stays inside a qualifying system. You may not provide or arrange the drug outside an authorised programme. An outside psychotherapist refers and supports. [source: SB0266S01]
  • Adults only. Never refer anyone under 18 under this authority. [source: SB0266S01]
  • Treatment happens under supervision on site. Nothing is taken home. The patient is observed in a clinical setting throughout. [source: SB0266S01; FOX 13]
  • Start with the strongest indications. The Task Force recommends beginning with adults who have moderate-to-severe unipolar depression, treatment-resistant depression, or anxiety or depression linked to terminal illness. Other indications go case by case on clinician referral. The statute itself lists no diagnoses.
  • Screen conservatively. Psychosis or bipolar risk in the client or the family is an exclusion. Practically, this means taking a three-generation family psychiatric history. [source: Task Force 2022; Johnson et al. 2008]
  • Consent is enhanced, not routine. Discuss specifically:
    • the possibility of changed beliefs or personality;
    • unwanted mystical experiences;
    • rare lasting psychotic states;
    • the possible use of therapeutic touch.
  • At least one therapist is present throughout every session. Johnson et al. specify a two-monitor team. Never leave the client alone.
  • Set and setting are part of the treatment. The room is calm and living-room-like, with music and eyeshades. The client chooses which personal items to bring. Religious imagery is used only if the client asks for it.
  • Psychological support comes first in distress. Reassurance and presence managed every distress episode in the Hopkins cohort. Medication rescue is a medical-staff decision. [source: Johnson et al. 2008 via summary]
  • Boundaries are absolute. Therapists never co-ingest with patients and use the drugs only within approved training programmes. Ethics and boundaries training is mandatory.
  • Document as if you will be audited. The Task Force recommends video recording of sessions, custody logs and auditable records. Systems must report outcomes and side effects to the Legislature.
  • Social support is a safety factor. A client with unstable housing or unstable relationships needs that assessed and addressed before treatment.
  • Follow the law as currently in force. The section is now Utah Code 58-37-309 (effective 6 May 2026) and is set to be repealed on 1 July 2027. Check le.utah.gov for later changes before acting. [source: Utah Code 58-37-309; OLRGC sunset review 2026]

4. Intervention inventory

Utah law sets the legal frame but no clinical procedures. The items below are the procedures the state's Task Force recommended and the Johns Hopkins safety guidelines describe, plus the duties the statute imposes. Each item is tagged. A participating health system may use a different trial-derived protocol, and none was found published [uncertain]. All example language is illustrative. Items 4.1–4.3 and 4.14–4.16 apply to a psychotherapist outside the programme. Items 4.4–4.13 apply to clinicians working inside a qualifying system's team.

4.1 Legal-status check and pathway explanation (outside therapist)

  • Purpose / when: whenever a client asks about "Utah's psilocybin law". Many clients think it created open access. It did not. [source: SB0266S01; Mind Medicine Law]
  • Steps:
    1. Explain the facts: treatment is possible only within a qualifying health system's programme, for adults, under on-site supervision.
    2. Explain that the law does not oblige any system to offer treatment. As of the Legislature's 20 May 2026 review, no programme had reported, and no public launch had been announced [source: OLRGC sunset review 2026; uncertain].
    3. Point out that retreats, private clinics and "Utah-legal" mushroom sellers are not covered by 58-37-3.5 as enacted. [source: Mind Medicine Law; SB0266S01]
    4. Use the current text (58-37-309). The 2025 S.B. 248 proposals to widen who can provide were not enacted. [source: Utah Code 58-37-309]
  • Example language (illustrative): "The Utah law lets two large health systems run supervised programmes for adults. It doesn't make psilocybin legal to buy or use elsewhere. If you're interested, the route is a referral through one of those systems, and I can help you ask."
  • Watch for: clients planning outside use on the belief that it is now legal. If so, move to 4.15.

4.2 Referral to a qualifying system

  • Purpose / when: a client may fit a programme. The Task Force recommends clinician referral and initial use only for the best-evidenced indications: moderate-to-severe unipolar depression, treatment-resistant depression, and anxiety or depression with terminal illness. A secondary source lists treatment-resistant depression or anxiety, PTSD, and serious illness with hospice enrolment [uncertain: not in statute]. [source: Task Force 2022; Mind Medicine Law]
  • Steps:
    1. Contact the system's psychiatry or research intake and ask whether a 58-37-3.5 programme or a trial is enrolling, and on what criteria.
    2. With consent, send a referral containing:
      • diagnosis and duration;
      • prior treatments and responses;
      • current medications (the medical team assesses interactions);
      • personal and family psychiatric history, especially psychosis or bipolar disorder;
      • suicide risk;
      • substance use;
      • social support.
    3. Agree in writing who holds clinical responsibility during the programme and how you will be updated.
  • Example language (illustrative): "I'll write to their intake team with your history. They'll do their own screening. If you aren't eligible, that's a safety judgement, not a judgement of you."
  • Watch for: no programme enrolling. Offer evidence-based alternatives and ClinicalTrials.gov trial searches [synthesis].

4.3 Pre-referral psychiatric screen (outside therapist)

  • Purpose / when: before referring, so the client is not set up for rejection or harm.
  • Steps: screen for the Task Force exclusions:
    • personal history of psychosis or bipolar I;
    • significant family history of psychosis;
    • cluster B personality disorder;
    • dissociative identity disorder;
    • unstable substance or alcohol use disorder;
    • active suicidal ideation;
    • depression severe enough to need inpatient care;
    • insufficient psychosocial support.
    Johnson et al. extend the family history to first- and second-degree relatives and include bipolar disorder. Note any medical conditions (see 4.4) for the medical team. You do not decide medical eligibility. [source: Task Force 2022; Johnson et al. 2008]
  • Example language (illustrative): "Has anyone in your family, including grandparents, aunts, uncles or cousins, ever had psychosis, mania, or been hospitalised for their mental health?"
  • Watch for: clients minimising history out of eagerness. Corroborate with records where possible [synthesis].

4.4 Medical and psychiatric screening (programme team)

  • Purpose / when: at intake, before consent is finalised. [source: Task Force 2022]
  • Steps:
    1. The psychiatric assessment covers the exclusions in 4.3.
    2. The medical team assesses medical exclusions, including:
      • serious cardiovascular disease, uncontrolled hypertension, prolonged QT or serious arrhythmia;
      • advanced liver disease or renal insufficiency;
      • history of seizure or stroke;
      • pregnancy or breastfeeding (pregnancy testing as the protocol directs).
      Labs and an ECG may be part of this.
    3. The medical team reviews interacting medications and substances and decides on any changes. Psychotherapists do not advise on stopping medication.
    4. Assess psychosocial stability: housing, relationships, a support person.
  • Example language (illustrative): "Part of today is medical: our physician will review your heart, blood pressure, other conditions and every medicine you take. Please don't change any medication yourself."
  • Watch for: pressure to relax criteria. Johnson et al. allow that therapeutic trials may relax some exclusions only with added safeguards. That is a protocol and medical decision. [source: Johnson et al. 2008 via summary]

4.5 Enhanced informed consent

  • Purpose / when: after screening, before preparation is complete. [source: Task Force 2022]
  • Steps: cover the following, give the patient-friendly safety handout, and obtain a signature.
    1. The drug's status: investigational, federally Schedule I, given under a time-limited state authority.
    2. Expected effects and common transient adverse effects (headache, nausea, anxiety).
    3. Risks of acute fear, panic or confusion.
    4. The possibility of changed beliefs or personality and of unwelcome mystical experiences.
    5. The rare possibility of a lasting psychotic state.
    6. The touch policy (4.8).
    7. Video or audio recording and how long recordings are kept (the Task Force suggests at least two years).
    8. Data collected for the system's report to the Legislature.
    9. The right to withdraw at any point before a session.
  • Example language (illustrative): "Some people come out of this with changed views about themselves, life or religion, and not always ones they welcome. I want you to weigh that before you agree."
  • Watch for: the client being unable to restate the key risks in their own words, or consent given only under family pressure. Pause the process [synthesis].

4.6 Preparation sessions

  • Purpose / when: to build trust and rapport, set expectations and give psychoeducation. The Task Force recommends 2–3 sessions of 1–2 hours, with at least one before any medication session. Johnson et al. add a meeting in the room where the session will happen. [source: Task Force 2022; Johnson et al. 2008]
  • Steps:
    1. Take a life history and explore the client's intentions [synthesis on content].
    2. Describe the course of a session day, the room, the music and eyeshades, and who will be present.
    3. Explain what the team will do if the client becomes frightened (4.9).
    4. Agree session rules: stay in the room; phone restricted; the touch agreement; how to ask for a break or the restroom.
    5. Confirm the support person and transport home.
    6. Hold one meeting in the session room.
  • Example language (illustrative): "If something frightening shows up, you won't be alone with it. One of us will be beside you the whole time. Often the most useful thing is to stay curious and let us support you through it."
  • Watch for: high anticipatory anxiety, unrealistic hopes of a cure, or a weak alliance. Add preparation time rather than proceed [synthesis].

4.7 Set and setting arrangement

  • Purpose / when: before and on the session day. [source: Task Force 2022; Johnson et al. 2008]
  • Steps:
    1. Prepare a quiet room on site, furnished like a living room, with restroom access.
    2. Provide eyeshades and headphones or speakers with music to support inward focus.
    3. Let the client bring personally meaningful items.
    4. Avoid overt religious iconography unless the client asks for it.
    5. Restrict phone use.
    6. Make sure medical staff and their equipment are nearby but unobtrusive [synthesis].
  • Example language (illustrative): "Bring a photo or object that matters to you, if you like. We'll keep the room simple otherwise."
  • Watch for: noise, interruptions, or staff coming and going. These undermine felt safety [synthesis].

4.8 Touch policy

  • Purpose / when: agreed in preparation and covered in consent. The Task Force says consent should address the possible need for therapeutic touch. The secondary summary of Johnson et al. used here does not mention touch [uncertain]. [source: Task Force 2022; Johnson et al. 2008 via summary]
  • Steps [synthesis, following common trial practice; check the system's protocol]:
    1. Define in advance which supportive touch is acceptable, if any (for example, a hand held or a hand on the shoulder), and what is never acceptable.
    2. Agree a clear signal for "no".
    3. During the session, ask before touching and accept a refusal.
    4. Record the agreement in the notes.
    5. Use two-person teams so no touch happens unobserved.
    6. Sexual contact is prohibited in all circumstances.
  • Example language (illustrative): "Would it help if I held your hand right now? You can say no."
  • Watch for: consent capacity changes during the session. When in doubt, don't touch and offer verbal presence instead [synthesis].

4.9 Two-person team conduct during the session

  • Purpose / when: throughout every medication session. The Task Force requires at least one mental health therapist to be present the whole time. Johnson et al. recommend at least two trained monitors: a primary monitor and an assistant. [source: Task Force 2022; Johnson et al. 2008]
  • Steps:
    1. Both monitors stay in the room. Arrange breaks so one is always present.
    2. Stay alert, and keep the client in the room and safe.
    3. Offer reassurance and interpersonal support when asked or when distress shows.
    4. Otherwise let the client stay with their inner experience. Avoid interpreting or steering [synthesis].
    5. Never co-ingest.
    6. Follow the protocol for recording.
  • Example language (illustrative): "You're safe. We're right here. Let it move through."
  • Watch for: the client trying to leave, which is the main dangerous behaviour Johnson et al. name. Watch also for monitor fatigue and for boundary drift. [source: Johnson et al. 2008 via summary]

4.10 Managing acute psychological distress

  • Purpose / when: fear, panic, paranoia or confusion during a session. This is the most common psychological risk. [source: Johnson et al. 2008 via summary; Task Force 2022]
  • Steps:
    1. Move closer and speak calmly.
    2. Reorient the client briefly to who you are and where they are.
    3. Remind them the state is drug-related and will pass.
    4. Encourage slow breathing and staying with the experience rather than fighting it [synthesis on specific wording].
    5. Offer agreed touch (4.8).
    6. Manage the reaction in the session room where possible. Johnson et al. warn that emergency departments unfamiliar with these drugs can escalate reactions.
    7. If support is not enough, call the medical team. Any pharmacological rescue is their decision.
    8. Document the event as an adverse event (4.13).
  • Example language (illustrative): "This is the medicine. It's strong right now and it will ease. I'm here, you're safe, breathe with me."
  • Watch for: escalating agitation, attempts to leave, self-harm statements, or suicidal ideation. The Task Force notes serious events such as suicidal ideation were more likely in people who did not respond to treatment. Escalate to medical staff and follow the system's risk protocol. [source: Task Force 2022]

4.11 Medical monitoring (medical staff responsibility)

  • Purpose / when: throughout the session, done by medical staff. [source: Task Force 2022]
  • Steps (for the psychotherapist):
    1. Know who the on-call medical lead is.
    2. Let medical staff carry out their checks without disrupting the client more than necessary.
    3. Report any physical complaint, such as headache, nausea or chest discomfort, to medical staff at once.
    Technical monitoring and rescue medications are not described here.
  • Example language (illustrative): "Dr. ___ is going to check your blood pressure; it'll take a moment and then we'll carry on."
  • Watch for: symptoms the client attributes to "the trip" that may be medical [synthesis].

4.12 End of session and next-day follow-up

  • Purpose / when: at the end of the session day and the following day. [source: Johnson et al. 2008 via summary; Task Force 2022]
  • Steps:
    1. Release only when the medical team's criteria are met. Hand the client over to the pre-arranged support person, with no driving.
    2. Give contact numbers.
    3. Make next-day contact to check stability and return to normal functioning.
    4. Ask specifically about persisting perceptual changes (possible HPPD, which is rare) and any psychotic symptoms.
  • Example language (illustrative): "Since yesterday, have you noticed any visual changes that haven't gone away, like trails, halos or patterns?"
  • Watch for: ongoing perceptual disturbance, sleep loss, agitation or unusual beliefs. Refer to psychiatry the same day [synthesis].

4.13 Documentation, adverse-event recording and statutory reporting

  • Purpose / when: throughout. The statute requires each participating system to report to the Legislature the drugs used, patient health outcomes, side effects and other evaluation information. [source: SB0266S01; Task Force 2022]
  • Steps:
    1. Collect standardised outcome measures at baseline and follow-up, as chosen by the system [synthesis on measures].
    2. Record every adverse event with its timing, severity and management.
    3. Keep custody and handling records, and session video or audio as consented.
    4. Keep records auditable.
    5. Report serious events through the system's usual incident channel and any trial or IRB channel [synthesis].
  • Example language (illustrative): "We'll ask you to fill in the same questionnaires at intervals so the programme can report what actually happened to patients."
  • Watch for: missing follow-up data. A legislative report depends on it.

4.14 Integration sessions (programme team, or outside therapist by agreement)

  • Purpose / when: after each medication session. The Task Force recommends 2–3 integration sessions of 1–2 hours, with the minimum possibly set by a regulator. It does not specify content. [source: Task Force 2022] The steps below are [synthesis].
  • Steps:
    1. Invite an open narrative of the experience without interpreting it.
    2. Identify the emotionally significant moments and any distress that remains.
    3. Link insights to the client's original goals and current life.
    4. Turn one or two insights into concrete behavioural steps, and review them at the next session.
    5. Normalise ambiguity: not every image needs a meaning.
    6. Screen again for low mood, suicidality, perceptual change and sleep.
    7. Plan ongoing care beyond the programme.
  • Example language (illustrative): "What from that day still feels alive for you? … If you took that seriously this week, what would you do differently?"
  • Watch for: distressing or unwanted spiritual content, which was flagged in consent. Respect the client's own framework and don't impose one. Watch also for idealisation of the drug, or a dip in mood after the session.

4.15 Harm-reduction support for clients using outside the programme (outside therapist)

  • Purpose / when: a client plans to use, or has used, psilocybin or MDMA outside a 58-37-3.5 programme. That use remains illegal in Utah and federally. [source: SB0266S01; SB0248 introduced] The steps below are [synthesis], with the screening content drawn from the Task Force and Johnson et al.
  • Steps:
    1. Neither encourage nor facilitate use. Never help the client obtain, prepare or take a substance.
    2. Assess the reasons for use, the client's risk profile and their expectations, using the exclusions in 4.3 and 4.4.
    3. Explain in general terms:
      • psychosis or bipolar risk is a major hazard;
      • some psychiatric medications (Johnson et al. name lithium and tricyclics) and other drugs can interact dangerously, so they should talk to a prescriber or pharmacist;
      • unregulated products may be misidentified or adulterated;
      • being alone, or in an unsafe setting, raises risk.
    4. Build a safety plan: a sober trusted person, a crisis contact, and when to seek emergency care.
    5. Offer the regulated route (4.2) as an alternative.
    6. Offer integration support afterwards, as in 4.14.
    7. Document carefully and follow your licensing board's guidance and your service's policy [synthesis].
  • Example language (illustrative): "I can't help you get or use it, but I care about you being safe. Can we go through your medications and history so you know your risks?"
  • Watch for: suicide risk masked as a "healing trip", a history of mania or psychosis, and mixing substances. Respond with standard risk assessment and refer to psychiatry.

4.16 Coordination and aftercare (outside therapist)

  • Purpose / when: a client is enrolled in a programme. [synthesis]
  • Steps:
    1. With consent, agree on communication with the programme team.
    2. Pause trauma-processing work during the active phase if the team prefers.
    3. Keep the client's usual crisis plan current.
    4. After the programme, take over integration and continued therapy as agreed.
    5. Keep tracking outcomes.
  • Example language (illustrative): "While you're in the programme, I'll stay in touch with their team so nothing falls between us."
  • Watch for: split loyalties or conflicting advice. Agree in writing who decides what.

5. Handling problems

The sources cover screening, distress management and adverse events. The rest of this section is [synthesis] unless tagged.

  • No programme available or the client is ineligible. This is likely as of 2026: no programme had reported to the Legislature by May 2026 [source: OLRGC sunset review 2026; Mind Medicine Law]. Validate the disappointment and explain that exclusions exist for safety. Offer evidence-based alternatives, including searches for registered trials. Watch for despair or a move to outside use (4.15).
  • The client hides history to qualify. Corroborate with records and family where consented. Explain that concealment raises the personal risk of psychosis or mania. If it comes out later, the programme team decides whether to proceed.
  • Anticipatory anxiety or ambivalence. Add preparation sessions. Rehearse the distress plan in 4.10. Remind the client that they can withdraw at any point before a session, and that withdrawing is a legitimate outcome.
  • Resistance or control during the session (the client fights the experience). Use the reassurance in 4.10. Don't push the client to "surrender". Honour any request to sit up, remove the eyeshades or take a break.
  • Overwhelm, panic or attempts to leave. Follow 4.10. Keep the client safe in the room and call medical staff. Avoid emergency department transfer where on-site management is safe. [source: Johnson et al. 2008 via summary]
  • Suicidal ideation during or after a session. Use standard risk assessment and safety planning. Means-safety counselling is limited to storage and removal. Make a same-day psychiatric review. Report it as an adverse event. The Task Force notes higher risk among non-responders. [source: Task Force 2022]
  • Persisting perceptual change or psychotic symptoms. Arrange urgent psychiatric referral, document, and report. Both are rare but recognised. [source: Johnson et al. 2008 via summary; Task Force 2022]
  • Non-adherence (missed preparation or integration sessions, or broken rules on medication changes). Pause before any medication session. Integration non-attendance should prompt outreach, because unprocessed difficult experiences can worsen mood.
  • Rupture, for example the client feeling unsupported during the session or upset by touch. Name it in integration, take responsibility, review the video with consent and with the team, and repair. Escalate any boundary complaint through the system's incident process.
  • Boundary violations or misconduct by staff. The two-person team, video recording and ethics training are the safeguards. [source: Task Force 2022; Johnson et al. 2008] Report concerns to the system and the relevant licensing board.
  • Unwelcome spiritual or identity changes. Consent covered this possibility [source: Task Force 2022]. Integrate the experience within the client's own worldview. Involve the client's chosen faith leader if they ask.
  • Legal uncertainty, such as a client asking whether the law has changed or the programme has ended. The current section is 58-37-309, set to be repealed on 1 July 2027. The 2025 proposal to extend this to 2029 was not enacted. Check le.utah.gov for any later change. [source: Utah Code 58-37-309; OLRGC sunset review 2026] Don't advise clients on legal exposure. Refer them to legal counsel.
  • Expectation of a cure. Re-anchor treatment goals, plan continued therapy, and frame the session as one part of treatment.

Sources

Pages consulted:

Papers cited:

  • Johnson, M. W., Richards, W. A., & Griffiths, R. R. (2008). Human hallucinogen research: guidelines for safety. Journal of Psychopharmacology, 22(6), 603–620. Cited via the abstract and a secondary summary [uncertain on detail].

Not found or not verified [uncertain]:

  • which 2026 bill became Chapter 362 (the renumbering to 58-37-309);
  • whether H.B. 500 (2025) was enacted;
  • whether any health system (Intermountain Health, University of Utah Health or another) has launched a programme, published a protocol or filed its legislative report (none had been received by 20 May 2026);
  • the full text of Johnson et al. 2008.
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