Psychedelic Therapy & Law Update – September 2025

Slow start to NMHA Program, but Iboga (ibogaine) added

As of mid-September, 2025, the regulated program under Natural Medicine Health Act has only 5 approved full healing centers in Colorado. Sixteen micro-healing centers have been approved to date. Healing centers are not required to report their number of journeys until the end of the year, but an informal survey from the returned responses that 25 journeys have been carried out as of mid-August. The state initially projected that approximately 100 healing centers would seek licensure in the first year, but now projects it is more likely that 40 healing centers will seek licensure by the end of the year. There are more than 400 facilitators who have been approved to date, showing the pool of facilitators will be much larger than healing centers going forward.

In news related to the expansion of NMHA, on September 19, 2025, the Advisory Board on NMHA recommended adding iboga (with its main active ingredient being ibogaine) to regulated program as long as it can be done in compliance with the Nagoya Protocol. The Nagoya Protocol is an international treaty that requires consultation with indigenous communities and benefit sharing regarding the use of indigenous intellectual property or wisdom, like the therapeutic/spiritual use of iboga. The state regulators will ultimately need to ratify the recommendation and begin rulemaking on the unique features that will be required to deliver iboga safely and with respect to indigenous people. The Advisory Board will have about 9 months to develop recommendations for a regulatory program and rules around the use of ibogaine at healing centers. Please monitor these meetings closely and make public comment to improve the outcome of the rules in this area. If you want addition information about the upcoming opportunities in Colorado with ibogaine, contact Sean directly for a consult.

Various New Agreements for regulated NMHA work: medical clearance agreements, agreement for therapists/facilitators working with clients out of state and supervised practicum/consultation agreements

As NMHA work is getting underway, Sean is doing several additional agreements for people to protect all actors in the system. For example, Sean has written medical clearance agreements for doctors/NPs/psychiatrists to assess participants in the NMHA regulated system when there are risk factors detected in safety screens of participants. Also, Sean has supplemented the state screening forms to be clear that when Clinical Facilitators are working with out of state clients that they are not practicing therapy outside of their states of practice to avoid allegations of practicing therapy outside of where the person is licensed. Next, Sean has written agreements between healing centers and facilitators in training to provide the consultation needed to complete licensure. Similarly, Sean has written practicum agreements between healing centers and students of training organizations to make sure healing centers are protected in case the student causes some injury. Finally, as always, Sean is working on basic lease reviews, independent contractor agreements, and other basic business agreements to allow businesses in NMHA to protect themselves to the maximum extent possible. If you are interested in these forms, or other contracts, please reach out to Sean.

Canta Journeys: A Plant Medicine Concierge Service and Rapeh Project

Sean is proud to announce the launch of a new side project called Canta Journeys (he’s not backing off on his day job of being a psychedelic lawyer!). See the new website here. During Sean’s spiritual medicine work, he’s connected with some of the best practitioners and healers in plant medicine. Canta Journeys is designed to identify the best experiences for people in Sean’s network and to take them on the most amazing healing journeys of their lives. The main initial journey Sean is promoting is a Brazilian Santo Daime/Indigenous ayahuasca retreat from January 23-31, 2026: This is a week long retreat in Brazil with a combination of Santo Daime and indigenous practitioners doing multiple medicines, including ayahuasca, rapé, sananga, jurema, cacao, and others.

Canta Journeys also includes a project around rapé, or hape, the sacred tobacco snuff. There are several rapé varieties for sale on the website, along with individualized coaching around the sacred use of this special medicine. A percentage of profits from all the revenue is returned to indigenous people directly. As mentioned below in the Events section, Sean will be conducting various rapé workshops to educate people about this sacred medicine. For more information, reach out to Sean directly at sean@cantajourneys.com