Natural Medicine Advisory Bulletin #6: November 2023

***November’s meeting of the full Natural Medicine Advisory Board began with a brief administrative update from recently-appointed program director Lorey Bratten, mostly around new document-sharing procedures for the board. Ms. Bratten was followed by Ashely Moller of the Colorado Attorney General’s office, who encouraged the board to submit legal questions to the AG’s office prior to the next board meeting in anticipation of addressing them in a closed-to-the-public executive session. Next, Department of Revenue representatives Dominique Mendiola and Allison Robinette gave an update on the Department’s current and future work related to the regulated natural medicine program. Ms. Mendiola gave a high-level recap of two of the Department’s Listening Sessions on the subject of First Responder Training. One big outcome of these two sessions was the identification of professions the Department should target with education campaigns which include veterinarians, EMS dispatchers, mental health professionals, harm reduction workers, crisis response teams, and emergency room staff. A second area coming into focus is the content of the education campaigns the Department will run. Feedback from the listening sessions has indicated a number of important education components including the limits of currently in place personal use allowances, adverse events & risk mitigation, serotonin syndrome, cultural information related to natural medicine, and specific information first responders will need to effectively assist in the event of a psychedelic crisis. Ms. Robinette then gave a forward-looking overview of the coming months with an emphasis on the official rulemaking process and the specific procedural steps required by the Colorado Administrative Procedure Act. With a goal of having effective rules in place by October 1st, 2024, the Department aims to file Notices of Permanent Rulemaking between March 1st and June 30th of 2024. DOR will conduct listening sessions through the end of 2024 and stakeholder work groups throughout the rulemaking process. The Department will continue its current consultation with the NMAB through February 2024. Next came a highly anticipated segment of the meeting – a review of the consolidated draft recommendations of each subcommittee of the NMAB. To kick off this segment Program Director Lorey Bratten read a preamble disclaimer that the document is subject to change and should not be relied upon by the public for any purpose. Board Chair Lundy reminded the members of the NMAB of their request for initial draft recommendations for this meeting. Lundy indicated that the document was still a work in progress, allowing the subcommittee chairs to give an update on the status of their draft recommendations. Dr. Bradley Conner gave the update for Emergency Response, Safety, and Ethics. Having spent significant time on the Facilitator Code of Ethics, that work is paused pending adjustments that will be made based on recommendations from other subcommittees. Before the December NMAB meeting the subcommittee will finalize draft recommendations around preparation, administration, and integration sessions as well as administration session lengths related to dose. Dr. Conner also gave an update for Products, Research, and Data. Draft recommendations regarding batch sizes and testing procedures will be updated by the December NMAB meeting. The subcommittee is in the early stages of drafting recommendations on data and research but is focused there. Despite Public Health & Health Equity not meeting in November, Billy Wynne mentioned two changes since October. The first is that the subcommittee will recommend that the state produce a health equity report only to the extent it does not increase license costs. The second is that the subcommittee will recommend the state partner with a 3rd party vendor to allow payment over time of license fees. The Indigenous and Religious Use and Outreach Subcommittee also did not meet in November. Members Skippy Upton-Mesirow and Clarissa Pinkola-Estés reiterated the requests of that subcommittee that outdoor cultivation be permitted and that Federally Recognized Tribes and Indigenous groups be permitted to participate in the for-profit regulated model. Dr. Alisa Hannum gave the update for the Qualifications, Licensing, and Training subcommittee primarily recognizing three areas that the subcommittee is still working on. First, the allocation of training hours will likely see a shift of some number of ethical training into a supervised consultation period and out of the classroom. Second, the addition of a training license is all but agreed upon however the subcommittee is still working out when in the overall training curriculum that license would be available. Third, the subcommittee is committed to offering accelerated training options, particularly for facilitators licensed in Oregon, but the specifics of doing so are still being worked out. Finally, Dr. Hannum identified a gap in the need to license supervisors, indicating a possible additional “consultant”-type license. The subcommittee will revisit this subject in December after hearing from the Attorney General’s office. NMAB Chair Lundy closed the meeting with several reminders and requests. They plan to submit draft recommendations to the state following the December NMAB meeting. Recognizing that several subcommittees will meet after the full board in December the consolidated recommendations document will be subject to change until January. Lundy and Ashely Moller requested that board members review the full schedule of 2024 NMAB meetings to ensure they will be able to regularly attend and consider stepping down from the board if they are unable. The next meeting of the Natural Medicine Advisory Board is scheduled for December 15th, 2023 at 1pm MST. 



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