Natural Medicine Advisory Bulletin 9: Feb/Mar 2024

Department of Regulatory Agencies Stakeholder Engagement Meeting: March 8th, 2024On Friday, March 8th, the Department of Regulatory Agencies (“DORA”) held its first Stakeholder Engagement meeting. This meeting marked the first opportunity for members of the general public to provide comments and feedback on draft rule language related to facilitator licensing and training. The most common feedback items included a need for clarity and specifics on accelerated licensure pathways, aversion to rules regarding physician clearance for certain participants, and the overarching need to allow group and residential facilitation.LicensingIf sheer number of comments is any indicator, the public’s biggest concern is the overly restrictive and cost-imposing nature of a requirement that participants meeting certain risk factors receive clearance or referral by a medical professional before receiving natural medicine. Many members of the public, including several attorneys and medical professionals, urged DORA to forgo codifying a strict list of medical conditions in favor of a screening tool. Dr. John Treem, physician and founder of the Psychedelic Public Policy Partnership, noted that many of the conditions listed in the draft rules are not medically defined, which will lead to confusion for both participants and facilitators. Those conditions include “severe suicidal ideation”, “cardiovascular disease”, and “severe chronic illness.”Quite a few speakers supported the inclusion of naturopathic doctors, who possess diagnosing and treating authority in Colorado, under the Clinical Facilitator framework. Fewer, though still a significant number, speakers supported including registered nurses (RNs). One member opposed the inclusion of RNs, claiming diagnosing and treating is outside the scope of that profession. In contrast, at least one speaker urged removing language restricting Clinical Facilitator licenses to professionals with “diagnosing and treating authority” from the rules completely, given that a Clinical Facilitator should not be diagnosing a participant for any conditions. One speaker requested that Recreational Therapists be included under the Clinical Facilitator framework.Many speakers also questioned the inclusion of language requiring approval for patients taking psychotropic medications. In addition to the term “psychotropic” being overly broad, clinical research has shown little evidence of increased safety risks when natural medicine is combined with common medications, such as SSRIs. According to one speaker, current research has shown that SSRIs may blunt the effects of natural medicine, but has not demonstrated any safety concerns. It was, however, agreed that lithium is the only medication for which natural medicine is truly contraindicated. By requiring additional medical appointments, or seeing a Clinical Facilitator, for participants taking psychotropic medications (other than lithium), there will be no appreciable gain in safety and a significant increase in cost and barriers to access, according to one speaker.Another oft-mentioned concern related to accelerated licensure pathways. Speakers requested clearer rules on educational equivalencies for other psychedelic-assisted modalities, training programs, and countries. Regarding legacy facilitators, several participants emphasized the need to ensure legacy facilitators have a clear, unambiguous pathway to licensure.Additional LicensesSeveral speakers spoke in favor of more flexibility in licensing. Multiple comments evidenced a desire for a category of licensure clearly directed to spiritual facilitation. One speaker suggested allowing some type of research license that would be available to university students and researchers interested in conducting research on natural medicine.Training programsThe most frequent feedback related to training program rules was a concern that the rules favor larger, established educational institutions. Requirements such as governing bodies, multiple faculty members, and specific student resources could push non-profit, sole proprietors, and smaller training programs out of the market, according to many who spoke on the issue. Several commenters expressed concerns about the costs of training generally.EducationOpinions diverged when it came to the educational aspect of facilitator training. Most members of the public in attendance voiced support for the current 150 hour curriculum. Some even favored an increase, citing the gravity of facilitation work as requiring robust training. The alternative view, that the current hour requirement is too high, was in the minority. Supporters of this position generally felt that the curriculum as drafted is too costly and that facilitation can be taught effectively in less time. Suggested additions to the curriculum included training on microdosing, harm reduction, business management, group facilitation, and the interaction of natural medicine with a woman’s menstrual cycle. One commenter expressed concern that certain concepts in the current curriculum could be viewed as religious, and thus not appropriate for state-mandated education. Additional suggestions included separating training on Colorado natural medicine rules from ethical training and making that component available online at no cost.PracticumSuggested modifications to the 40-hour practicum requirement included removing language suggesting a practicum consist of 5-6 administration sessions, adding a requirement that some amount of practicum hours be met through preparation and integration sessions, and adding a requirement that some hours be met by co-facilitating or assisting in facilitation. Nearly all comments related to practicum changes came from associates of Naropa University.Indigenous ConcernsAt a high level, many speakers voiced concern that Indigenous communities should be consulted and considered more in the rules the state is drafting. Specifically, speakers suggested that DORA actively solicit input from Indigenous communities, and that Indigenous Distinguished Educators be permitted to provide an ethical attestation or evidence in lieu of the 25-hour ethical training requirement. Several speakers expressed concern that the spirit of natural medicines may be offended if the rules do not adequately respect and honor indigenous wisdom and traditions and guard against exploitative, extractive, and commercializing practices. Members of the public also expressed some general concerns to DORA officials. One commenter emphasized the need to consider the effects of rules as they may impact rural communities. Another commenter questioned whether the state plans to address a growing market that is operating under the exemptions allowing remuneration for “bona fide harm reduction and support services” allowed under the personal use provisions of the Natural Medicine Health Act. According to this commenter, this market ranges from small-time facilitators to large-scale luxury retreats.



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