Natural Medicine Advisory Bulletin 12: May and June 2024

Facilitator Licensing & TrainingDORA’s first set of rules, released in April, mark the first rules for Colorado’s regulated Natural Medicine program to become official. Following a final rulemaking hearing on May 3rd, 2024, the rules were approved by the Colorado Attorney General’s office on May 30th, and are final and effective as of June 30th. These rules establish the foundational framework for the profession of facilitation, including license types and qualifications, application and renewal processes, education standards, and procedures for approval of facilitator training programs.Facilitator Training ProgramsHaving received signoff from the Attorney General on rules related to facilitator licenses and training programs, DORA has prioritized procedures for approval of facilitator training programs.During the June 21st meeting of the NMAB, Program Director Lorey Bratten shared a preview of DORA’s online application portal for training programs, which officially opened on July 2nd. Ms. Bratten also shared an initial checklist of documents that will be required when applying for approval. Initial application fees for a facilitator training program are set at $10,000 for the first year. In response to some NMAB concerns regarding costs, DORA officials indicated they would explore the feasibility of an installment or payment-over-time option.For those interested in applying for approval as a training program, Vicente has created a helpful guide.Standards of Practice and AdvertisingInitially released on May 15th, 2024, this second set of rules primarily codifies portions of the Facilitator Code of Ethics, as recommended by the NMAB. A final rulemaking hearing on these rules was held on June 20th, 2024. During the hearing multiple members of the public urged DORA to streamline disclosure requirements, minimize duplicative paperwork, and provide more flexibility for facilitators to employ touch in certain populations, such as participants seeking Natural Medicine Services for pain relief.Standards of PracticeIn general, Standards of Practice rules prescribe certain aspects of a facilitator’s conduct, including:Required documentation and disclosuresConfidentiality and storage of participant recordsInformed consent processes and disclosuresPermitted and prohibited use of physical touchProhibitions on discrimination and exploitationProhibitions on sexual, romantic, financial, or otherwise conflicting relationships with participants and participants’ immediate familyProhibitions on accepting fees for referralsRequirements around a Facilitators state of mind, including a prohibition on consuming Natural Medicine while providing Natural Medicine ServicesMaintaining competency as a facilitatorAdministration session duration, based on dosageRules also establish a facilitator’s responsibilities with regards to preparation, administration, and integration sessions, including group administration and integration. Notably, these rules permit administration outside of Healing Centers, as well as group administration. Additional rules regarding administration outside of licensed Healing Centers are anticipated, based on recommendations from the Natural Medicine Advisory Board.Following an initial stakeholder engagement meeting on May 14th, 2024, DORA removed a prohibition on providing Natural Medicine Services to individuals with whom the facilitator has a “close personal relationship” with. Modified language now restricts provision of Natural Medicine Services to individuals, and their immediate family, with whom a facilitator has had a sexual, romantic, or intimate relationship within the past year.AdvertisingRules regarding advertising of Natural Medicine Services prohibit false, misleading, or deceptive advertisements, as well as solicitation of testimonials.Disciplinary Procedures & Unlicensed PracticeBy far the shortest, DORA’s third set of rules defines grounds for disciplinary action against a licensed facilitator, including certain felonies and misdemeanors, abuse of alcohol or controlled substances, violations of laws or regulations related to Natural Medicine, misrepresentation and deception, unprofessional or dishonest conduct, unlicensed practice of facilitation, aiding or abetting the unlicensed practice of facilitation, and failure to report certain required events. Licensees are required to report criminal convictions and any instance of unprofessional or dishonest conduct. “Unprofessional or dishonest conduct” encompasses crimes involving dishonesty or willful misrepresentation, crimes related to the practice of facilitation, and disciplinary actions taken against a facilitator by another jurisdiction or licensing board.A final hearing on these rules is set for Monday, July 8th, 2024. The public is invited to provide feedback in person during the hearing or submit written comments to dora_dpo_rulemaking@state.co.us.



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