August 2025 Psychedelic Law Update

Status of Colorado Model State Screening Forms

For many months, DORA has been promising to release the model screening forms that will satisfy the requirements of the Natural Medicine Health Act to conduct a psilocybin healing administration session under the state regulated program. However, the models forms have not yet been finalized or released. There is a draft version of the forms that can be found here. Some have been confused how currently licensed healing centers can operate without these forms being final. DORA recently clarified this by explaining that healing centers do not need to wait until the forms are final to operate. Healing centers need to ensure all of their screening forms meet the requirements of the rule independently. While the draft forms are a solid starting point, McAllister Law recommends you review the draft forms, or have a lawyer do it, to ensure everything is covered by your healing center screening forms. Contact Sean to ask about our flat fee costs to review your screening forms.

Clarifying the Facilitator in Training License in CO

Many people contact my office confused by the scope of the facilitator in training license. First, it is important to remember that facilitators in training have the right to engage in natural medicine services, including preparation, administration, and integration sessions even before they have completed the required supervised practicum and consultation needed to obtain full licensure.

Next, healing centers are required to have one facilitator as an owner or contractor with their healing center in order to be approved for licensure. McAllister Law has confirmed that the state will accept applications for healing centers with a facilitator in training as the only licensed facilitator associated with the healing center. Colorado has released guidance on this matter, which is reproduced here:

  • I currently have my Training Facilitator License. Can I apply for an Owner’s License for a Natural Medicine Business with the NMD-DOR, or do I need to be fully licensed as a Facilitator first?

If you possess a DORA-issued Training Facilitator license, you may apply for an Owner’s License (you do not have to be fully licensed as a Facilitator upon applying). However, you will need to be fully licensed as a Facilitator (by DORA) upon renewal the following year in order to avoid paying the application renewal fee.

  • I currently have my Training Facilitator License. Can I associate with (aka contract with) a Healing Center, or do I need to be fully licensed as a Facilitator first?

If you possess a DORA-issued Training Facilitator license, you may contract with a Healing Center (you do not have to be fully licensed as a Facilitator upon applying). A Training Facilitator contracting with a Healing Center must comply with all DORA-related requirements while in that role.

If you continue to have questions about this topic, feel free to reach out to Sean for a consultation.

Colorado Begins Considering Adding Iboga to Regulated Model

The state of Colorado has begun the process of considering whether iboga should be added to the regulated model. On August 14, 2025, the state NMHA Advisory Board had its first meeting considering this topic. The meeting minutes can be found here. The Advisory Board heard from various experts on the topic and will continue considering this topic in future meetings. There are many major concerns from the indigenous rights and social justice aspects of adding this additional natural medicine to the regulated program. The next meeting of the Advisory Board is on September 18, 2025. More information on the meeting can be found on the DORA calendar here. Contact Sean if you want more insight on this topic.

Connecting Facilitators with Healing Centers

McAllister Law is offering a free service to connect Facilitators and Cultivators/Manufacturers with Healing Centers. If you are interested in connecting with Healing Centers, please send an email with your qualifications and interests in working with Healing Centers. McAllister Law will pass these on to several healing centers looking for connections.

NMHA Applications, SOPs, Consent Forms, and Liability Waiver Forms

McAllister Law is helping applicants in the Colorado Natural Medicine program develop the numerous standard operating procedures, consent forms, and other plans required by the rules. Sean has developing flat fee SOPs and forms at an affordable cost to help satisfy all the requirements under the rules. For more information, see these lists of forms and cost: for healing centers/facilitators click here, for cultivation/manufacturing SOPs click here.