Natural Medicine Advisory Bulletin #4: September 2023

***One new non-voting participant was introduced in the September meeting of the Qualifications, Licensing, and Training subcommittee. The new participant, Luke Priel, is a former facilitator trained in Indigenous practices.            First on the agenda was a presentation by Hadas Alterman on the American Psychedelic Practitioners Association’s Professional Practice Guidelines for Psychedelic Assisted Therapy. These 12 guidelines, published in August 2023, are claimed to be the first comprehensive set of professional practice guidelines (PPGs) for psychedelic-assisted therapy (P-AT). A seven-member working group from the APPA and BrainFutures developed the guidelines over 10 meetings. The goals of the guidelines are to 1) guide clinical practice 2) define standards of training through core competencies and 3) develop an accreditation program for P-AT training programs. The guidelines were developed with the US medical access pathway in mind, however Ms. Alterman stated that substituting “psychological support” for “psychedelic-assisted therapy” would make the guidelines applicable to a supported adult-use pathway like Colorado’s regulated natural medicine program. The intended audience at this time is regulators, insurance payors, boards like the NMAB developing qualifications for training and certification, training programs, and educators. The current PPGs address broad practice areas and the APPA is developing more specific ethical guidelines. Next steps will be publication in peer-reviewed literature, stakeholder discussions, development of core competencies for accreditation, and development of specific Clinical Practice Guidelines. The guidelines are held under a Creative Commons copyright that allows non-commercial non-derivative use, granting the APPA and BrainFutures the exclusive privilege of modification.              The true meat of the meeting was in the latest revision of the licensing model which includes a scope of practice for facilitators. Leaving aside questions of federal law, Dr. Alisa Hannum began by identifying potential problems for facilitators at the state level. The primary concerns are:A facilitator operating solely under the facilitator license is at risk for unlicensed practice of medicine or psychotherapy if facilitation looks too much like that other profession.A facilitator operating with additional licenses, for example a medical license, could be disciplined by that professional board if providing natural medicine services violates that board’s regulations.Under the revised spheres model, the key differentiator between licensing spheres is holding a license with independent diagnosing and treatment authority. The model now calls for 3 types of licenses:Wellness Natural Medicine FacilitatorNatural Medicine Psychotherapy FacilitatorNatural Medicine Medical Facilitator A “Licensed Wellness Natural Medicine Facilitator” may provide natural medicine services but is explicitly prohibited from practicing medicine or psychotherapy as defined in the practice acts of those professions. A “Dual Licensed Wellness Natural Medicine Facilitator” may provide other non-medical, non-psychotherapy services they are licensed by the state to provide in conjunction with natural medicine services.A “Licensed Natural Medicine Psychotherapy Facilitator” would be permitted to provide psychotherapy in conjunction with natural medicine services provided they hold an appropriate psychotherapy license. Holders of this license may not independently practice medicine or provide natural medicine services to persons with cardiovascular risk factors, diseases of the liver, seizure disorders, or life-threatening illness unless referred by someone licensed to diagnose and treat those conditions. Students working under the supervision of a Licensed Natural Medicine Psychotherapy Facilitator would be allowed to provide natural medicine services. The suggested scope of practice allows registered psychotherapists to apply for this license “if appropriate”.A “Licensed Natural Medicine Medical Facilitator” would be allowed to provide medical services in conjunction with natural medicine services provided they hold an MD, DO, PA, or NP degree.Part of the motivation in defining these scopes is to ensure any complaints about facilitators are handled by a Natural Medicine regulatory board and not the boards of other professions. All license types would be required to complete Basic Life Support certification, DORA-mandated Facilitator training, and 40 hours of supervised practicum training. The requirements may be modified if an applicant meets criteria for accelerated training.Citing the examples of forced hysterectomies and the DSM’s historical classification of homosexuality as a diagnosable mental disorder, Dr. Clarissa Pinkola-Estés pointed out that Western models of diagnosis should be taken with a grain of salt. She advised allowing for differential diagnosis and not requiring strict adherence to prior diagnoses.Next, the subcommittee discussed training program requirements. Stating a desire to allow training programs to provide training in both Oregon and Colorado and recognizing certain statutorily mandated categories of training, Dr. Hannum presented a draft curriculum that reorganizes much of the Oregon requirements into the framework required by Colorado statute. Total hour requirements were briefly discussed without any conclusions.Non-voting participant James Eshlemen presented a version of the Oregon program with several additions. He emphasized the need for three additional training modules specifically: 1) Inner Genius development; 2) Soft Skills; and 3) Self Care. Several NMAB members found these to be important additions, particularly the need for scenario-based training to prepare facilitators for difficult and unexpected experiences. Another point emphasized was the need for facilitators to recognize when they are not in the correct mental or spiritual space to facilitate.Non-voting participant Dr. Shannon Hughes briefly presented an outline of possible practicum requirements. The subcommittee generally agreed that first hand experience of the effects of psychedelics is quite desirable. Absent the ability for the state to require such experience, alternatives were discussed including giving greater weight to voluntary firsthand experience and allowing training programs to include a firsthand experience component in their curriculums.Dr. Bradley Conner quickly discussed the latest code of ethics, recognizing the need to add provisions for group facilitation and authorized non-healing center locations.The meeting closed with a brief presentation of Lundy’s latest equity document. Non-voting participant Luke Priel advised that any practitioner, including those practicing in a ceremonial setting, be required to take basic safety training. This suggestion was shut down by the Attorney General reminding the group that the state cannot and will not mandate activity outside of the regulated program.Next meeting: October 19, 2023 at 1pm MST.



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