The Colorado Department of Regulatory Agencies (DORA), through the Colorado Division of Professions and Occupations, is seeking public input on its existing natural medicine rules, including whether facilitators may engage in ceremonial use. The requested feedback is part of DORA’s broader stakeholder engagement plan on various aspects of the rules.
The question runs contrary to the text and intent of the Natural Medicine Health Act, but personal and ceremonial use have been suspected to be the actual target for the Division.
Written comments are due Monday, September 14, and DORA has published a full list of the questions it is seeking feedback on. Stakeholders will also have the chance to provide oral comments at a stakeholder meeting Thursday, September 17.
Your input is needed. Please review DORA’s questions prior to providing written feedback. In addition to facilitator conduct and the unlicensed practice, DORA is seeking input on microdosing, administration sessions outside of healing centers, data collection, and adverse events.
DORA Facilitator License: What Rule 8.3(C) Could Change
As it relates to Facilitator conduct and the unlicensed practice, the Division appears to question whether licensed facilitators may take part in ceremonial practice, including the non-commercial ceremonies that Colorado law permits any adult to provide. Holding a license does not strip a facilitator of the rights they hold as a private person. Treating licensure as a forfeiture of those rights would do real harm:
- It could discourage skilled practitioners from entering the regulated system, leaving fewer licensed facilitators.
- It could push ceremonial practice away from trained, accountable providers, leaving participants less safe.
- It could infringe the deeply held religious and spiritual rights that many facilitators exercise in their own lives.
Regulators respond to the people their rules govern. Facilitators, healing centers and other stakeholders who want to weigh in on Colorado’s ceremonial use rules have a limited window to do so.
Natural Medicine Rulemaking: Other Rules Under Review
Beyond facilitator conduct and unlicensed practice, DORA’s current natural medicine rulemaking review touches several other areas:
- Microdosing and low-dose administration, including whether preparation and integration sessions can be streamlined for supervised low-dose sessions
- Administration sessions outside healing centers, including documentation standards for palliative, hospice, disability or homebound participants
- Data collection requirements, including facilitators’ dual obligation to maintain identifiable records for DORA while submitting de-identified data to the Colorado Department of Public Health and Environment
- Adverse health event reporting, including whether the current 24-hour reporting window for serious events is workable
How to Comment on Colorado’s Natural Medicine Facilitator Rules
Stakeholders have two ways to participate before the process moves forward:
- Submit written comments by Monday, September 14, 2026, through DORA’s comment form
- Testify at the stakeholder meeting Thursday, September 17, 2026, at 1 p.m. MT, held via webinar; register here
This stakeholder meeting is for discussion and information gathering only. No final decisions will be made there, and any proposed rule changes will still go through the formal Administrative Procedure Act process, including additional notice and opportunity for public comment.
Additional Resources
Vicente LLP’s psychedelics and natural medicine team continues to monitor developments in Colorado’s natural medicine regulatory framework. Contact our team for guidance on how these proposed rule changes could affect your license, practice or business.
