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Cannabis Law Report Audit-Style Reports Series — Report 1
Executive Summary
This compliance review examines the regulatory architecture, licensing operations, enforcement record, and structural vulnerabilities of Oregon’s Psilocybin Services (OPS) program — the first state-licensed psilocybin system in the United States — from its commercial launch in June 2023 through the close of Q3 2025. The review draws on data published by the Oregon Health Authority (OHA) through its OPS Data Dashboard, legislative records, administrative rulemaking materials, and independent program analyses.
Key Findings:
- Licensing volume has grown but market sustainability is in question. As of Q3 2025, OPS has licensed approximately 35 service centers, but 12 have closed since early 2024 — a 34% cumulative closure rate — due primarily to unsustainable operating costs including a $10,000 annual license fee, mandated security infrastructure, and persistent banking access constraints.
- Training program oversight presents a systemic compliance gap. Of 30 training program curricula approved since program launch, five have had their licenses revoked through enforcement action and seven were voluntarily withdrawn. The program’s financial incentive structure — in which training programs earn significant revenue from facilitator students — creates conflicts of interest that may undermine quality control.
- A single testing laboratory serves the entire state. Oregon’s supply chain testing architecture relies on one OHA-licensed and ORELAP-accredited testing facility, creating both a critical supply chain vulnerability and an absence of redundant integrity checks on testing results.
- Geographic access remains deeply unequal. As of 2025, over 100 cities and 25 counties have enacted bans or moratoriums on psilocybin businesses, concentrating the industry along the I-5 corridor. Residents of approximately 70% of Oregon’s land area have no local access to licensed services.
- ADA compliance litigation is pending. Cusker v. Oregon Health Authority — in which U.S. District Judge Mustafa T. Kasubhai denied OHA’s motion to dismiss in late May 2025 — poses a significant regulatory realignment risk, potentially requiring structural modifications to how services are delivered to disabled and homebound clients.
- Rulemaking responsiveness is robust but reactive. OPS engages in annual rulemaking cycles with substantial public participation, but recent examples — including the discovery of an “unintended loophole” in service center hours rules in August 2025 — illustrate vulnerabilities in pre-adoption rule review.
Recommendations: OPS should prioritize (1) establishment of a secondary testing laboratory to eliminate single-point-of-failure risk; (2) restructuring training program financial relationships to reduce quality-control conflicts of interest; (3) expansion of the compliance inspection program to include proactive, unannounced inspections; and (4) a formal response plan for the Cusker litigation that preserves program integrity if ADA accommodations are required.
I. Program Overview and Regulatory Authority
Oregon Ballot Measure 109, approved by 55.8% of voters in November 2020, authorized the Oregon Health Authority to develop and administer a state licensing system for the manufacture, testing, delivery, and supervised administration of psilocybin to adults 21 and older at licensed service centers.¹ The resulting Oregon Psilocybin Services Act is codified at ORS Chapter 475A. Following a two-year development period during which OHA engaged in extensive rulemaking with input from the Oregon Psilocybin Advisory Board (OPAB), OPS began accepting license applications on January 2, 2023.² The program’s administrative rules are published at Oregon Administrative Rules (OAR) 333-333.
OPS licenses four categories of businesses — manufacturers, service centers, testing laboratories, and training programs — and issues facilitator licenses and worker permits to individuals.³ Service centers are regulated as non-medical entities: clients do not require a diagnosis or prescription, and service centers are prohibited from operating within licensed healthcare facilities or from making medical claims.⁴
The program’s funding structure is primarily fee-based. Licensed service centers pay a $10,000 annual license fee. Facilitator training programs pay a $500 curriculum approval fee.⁵ The OPS Training program, Licensing, and Compliance (TLC) system serves as the primary technology platform for applications, licensing, and data reporting.⁶
II. Licensing Volume and Market Structure
A. Overall Licensing Statistics
As of Q3 2025, OPS has issued cumulative approvals across all license categories since program initiation. Facilitator licenses constitute the dominant license category, representing approximately 91% of all individual licenses in OPS (excluding worker permits). As of Q3 2025, OPS has issued 572 facilitator applications in total, with 366 currently licensed or approved.⁷
Service center licensure has experienced significant volatility. As of Q3 2025, OPS has approved 35 service center licenses in total since program launch, but only 23 remain operational — representing 12 closures since early 2024.⁸ The 34% cumulative closure rate reflects persistent market conditions including prohibitive operating costs, banking exclusion, and geographic market constraints, rather than a single peak operational count. Manufacturer licensure shows similar attrition patterns reflecting declining demand expectations as service centers close.⁹ A single testing laboratory holds a license to serve the entire state’s testing needs.¹⁰
B. Training Program Oversight Concerns
Of 30 training program curricula approved by OHA since program inception, 18 programs remain active as of Q1 2025, 5 have had their licenses revoked through enforcement action, and 7 were voluntarily withdrawn.¹¹ The revocation rate of 5 out of 30 (approximately 17%) is the more probative compliance indicator — revocations represent enforcement-driven removals — while voluntary withdrawals may reflect market exit rather than quality failure. Together, these figures represent a 40% non-continuation rate that raises questions about the rigor of initial curriculum review and the financial viability of training programs in the current market.
The OPS training program oversight structure has a notable structural vulnerability: the financial incentive of private training programs depends heavily on attracting and retaining student-facilitators. Facilitator training programs typically charge between $4,500 and $12,000 per student for curriculum.¹² Program analysis from Psychedelic Alpha noted that training programs bear the burden of evaluating and endorsing their own graduates, and that significant tuition investment “may represent a significant enough investment to discourage them from rejecting a facilitator who has completed their program” — creating a direct financial conflict of interest in quality control.¹³
OPS does not independently audit facilitator training quality on a programmatic basis; its oversight of training programs is limited under ORS 475A to “review, approval, denial, or revocation of psilocybin training program curriculum.”¹⁴ The Higher Education Coordinating Commission (HECC) is separately responsible for institutional licensure of training programs.¹⁵ This dual-oversight structure creates potential gaps where program quality issues may not be caught by either agency.
C. Facilitator Oversupply
The facilitator population has grown to a level that industry observers characterize as structurally unsustainable relative to the number of licensed service centers and available employment. With 366 licensed facilitators and only 23 operational service centers, the majority of licensed facilitators cannot find sustainable full-time employment within the OPS system.¹⁶ Harris Sliwoski LLP’s year-end 2024 assessment characterized the facilitator influx as “strong (unsustainable),” noting that “there are far too many facilitators, nearly all of whom are gig workers and cannot find sustainable, full-time work in the OPS milieu.”¹⁷
This oversupply creates compliance pressure: financially stressed facilitators operating with limited income have greater incentive to work outside the OPS system. In January 2025, OPS added new rules under OAR 333-333-5120(14) explicitly prohibiting licensed facilitators from “supervising” individuals experiencing psilocybin outside a service center, except in specified circumstances — a rule that addresses but does not eliminate the risk of unlicensed out-of-system facilitation.¹⁸
III. Compliance and Enforcement Record
A. Administrative Violations and Final Orders
OPS maintains a Data Dashboard that publishes final orders for license denials and administrative violations. As of the Q1 2025 reporting period, OPS confirmed that only two service center applications have been denied, with no denials recorded in any other license category.¹⁹ This low denial rate is consistent with both a permissive entry standards interpretation and an alternative explanation — that initial applicants were well-prepared and self-selected for compliance — though the absence of published inspection data prevents any definitive characterization. Facilitator applicants require only a high school diploma or GED, completion of a state-approved 120-hour training program, a passing score of 75% on the licensing examination, and a criminal background check.²⁰
Administrative violations are tracked through the TLC system and published on the OPS Data Dashboard following Senate Bill 303’s January 2025 data collection mandate.²¹
B. Safety Record
Through Q1 2025, OPS reported 1,509 clients receiving services between January and April 2025.²² Of those clients, six experienced behavioral, medical, or post-session reactions — representing an adverse reaction rate of approximately 0.4% of sessions in that quarter.²³ Since sessions began in summer 2023, a total of 13 emergency service reports have been documented across all licensed service centers, spanning more than 26,500 psilocybin products sold.²⁴ No product recalls were issued in Q1 2025.
The OHA defines adverse events narrowly — encompassing only incidents requiring emergency services, medical attention, or hospitalization — in contrast to clinical trial adverse event standards, which encompass any unintended response.²⁵ This definitional narrowing makes Oregon’s safety statistics difficult to compare with clinical research data and may understate the frequency of distressing but non-emergency experiences.
C. Regulatory Gap: Hours of Operation
In August 2025, OPS discovered what it characterized as “an unintended loophole in administrative rules regulating hours of operation and authorized temporary uses for service centers.” The agency issued a temporary rule effective August 29, 2025, amending OAR 333-333-4300(6) to require that authorized temporary uses may only occur between 6:00 AM and 11:59 PM local time.²⁶ The temporary rule was adopted as permanent on January 22, 2026.
The discovery of this loophole — after more than two years of program operation — illustrates the limits of a rule review process that depends primarily on external stakeholder comment rather than systematic internal compliance auditing. The potential for after-hours service operations to occur without regulatory detection underscores the need for proactive enforcement capacity.
D. Facilitator Scope-of-Practice Compliance
Oregon facilitators are prohibited under OAR 333-333 from providing therapy, diagnosing conditions, or making medical claims about psilocybin. These prohibitions are structural to the program’s non-medical design and protect it from federal preemption arguments based on unauthorized medical practice. Compliance monitoring for scope-of-practice violations is almost entirely absent from OPS’s published enforcement record. The program has no announced mechanism for detecting violations short of client complaints — and clients in altered states during or after sessions may not recognize or be positioned to report facilitator conduct that crosses into prohibited therapeutic territory. OPS should require service centers to maintain session records sufficient to enable audited review of facilitator-client interactions, and should develop competency verification procedures that assess scope-of-practice compliance post-licensure rather than relying solely on pre-licensure curriculum review.²⁷
IV. Geographic Access and Local Opt-Out Analysis
A. Scale of Local Bans
Oregon Measure 109 included a local opt-out provision allowing cities and counties to prohibit psilocybin businesses within their jurisdictions through a voter referendum process. In the November 2022 general election, 25 counties and over 100 cities voted to enact temporary or permanent bans.²⁸ Following the November 2024 election, sixteen additional communities — including Lake Oswego, Warrenton, Seaside, Oregon City, and Redmond — voted to expand or make permanent existing restrictions.²⁹
As of 2025, over 100 cities and 25 counties have enacted bans or moratoriums on psilocybin businesses, limiting the program’s geographic reach to primarily the I-5 corridor from Portland to Eugene, with pockets of access in Deschutes and Jefferson counties.³⁰ Statewide, only 23 licensed service centers remain operational, concentrated in Oregon’s largest population centers including Portland, Eugene, and Gresham.³¹
B. Compliance Implications of Geographic Concentration
The geographic concentration of licensed service centers creates three distinct compliance risk profiles. First, concentrated markets face greater competitive pressure, increasing the financial stress on individual licensees and the incentive to cut corners on compliance. Second, concentrated markets create access inequity that may incentivize unlicensed out-of-system facilitation in areas without legal services. Third, the patchwork of local regulations creates confusion about what is permitted in which jurisdictions — a compliance burden for both clients and facilitators who may serve clients traveling from opt-out areas.
A reporting analysis by KGW documented that finding property for a service center “can be difficult” due to local bans, and that centers face challenges with more rigid zoning restrictions even in jurisdictions that have not formally opted out.³²
C. Regulatory Context: Oregon’s Broader Drug Policy Shift
Oregon’s broader drug policy environment shifted substantially in 2024 when the legislature enacted HB 4002, rolling back Measure 110’s decriminalization provisions effective September 1, 2024. This legislative reversal is relevant to OPS for three reasons: it demonstrates that Oregon voters and the legislature are capable of retracting permissive drug policies when implementation is perceived to have failed; it renewed law enforcement attention to drug activity that may create compliance spillover effects on OPS licensees; and it fractured the political coalition that supported both decriminalization and psilocybin access in 2020. OPS’s long-term political sustainability depends in part on avoiding the implementation failures — fee mismanagement, regulatory inequity, inadequate internal controls — that contributed to Measure 110’s legislative reversal.
V. Structural Compliance Vulnerabilities
A. Single Testing Laboratory
Oregon’s psilocybin products are required to be tested by a laboratory licensed by OPS and accredited by the Oregon Environmental Laboratory Accreditation Program (ORELAP). As of Q1 2025, a single testing laboratory serves the entire state.³³ This single-point-of-failure creates two distinct and compounding compliance risks.
First, a supply chain disruption risk: any interruption to the sole laboratory’s operations — through equipment failure, personnel loss, regulatory action, or business closure — would halt product testing statewide and could force service center closures with no alternative testing pathway available.
Second, a testing integrity risk: the absence of any redundant laboratory means there is no cross-check on the single lab’s results. The experience of the Massachusetts cannabis market illustrates this risk concretely: in 2025, the Massachusetts Cannabis Control Commission was confronted with a licensed testing laboratory (Assured Testing) that had actively failed to report contamination in thousands of cannabis samples between April 2024 and April 2025.³⁴ Oregon’s analogous risk is not that a second lab would have caught contamination in the first instance — it is that with only one lab, any systemic failure in testing methodology or result reporting has no institutional check. A second accredited laboratory would not only reduce supply chain disruption risk; it would create the competitive and technical redundancy that makes integrity failures harder to sustain undetected.
OPS rules require products to be cultivated, processed, or produced by licensed manufacturers and tested in an ORELAP-accredited laboratory.³⁵ The testing protocol includes speciation testing (confirming Psilocybe cubensis only), contaminant screening, and potency verification. Oregon law prohibits the cultivation of wild-harvested mushrooms and synthetic psilocybin.³⁶ These quality-control requirements are sound but their integrity depends entirely on a single licensed laboratory.
B. Banking and Financial Compliance Constraints
Oregon psilocybin businesses face the same banking exclusion that has constrained the cannabis industry for over two decades: because psilocybin remains a Schedule I controlled substance federally, federally insured financial institutions cannot provide traditional banking services without potential federal liability exposure. Harris Sliwoski LLP’s analysis of the OPS program consistently identified “intractable issues caused by federal prohibition, especially around taxation and lack of banking” as structural constraints on program viability.³⁷
The banking constraint affects compliance in concrete ways: cash-intensive businesses are harder to audit, more vulnerable to theft, and face greater difficulty documenting financial transactions for regulatory purposes. The $10,000 annual license fee itself must be paid, and service center operators routinely navigate payment processing without traditional bank accounts or credit card processing services.
C. Advisory Board Restructuring and Independence
Oregon House Bill 2387, which passed the Oregon House unanimously in April 2025, restructured the Oregon Psilocybin Advisory Board to require representation from tribal communities, mental health professionals, licensed service center operators, and licensed facilitators, and reduced the board’s total size to nine members.³⁸ Legislative testimony in March 2025 noted that “a disconnect between the agency rules and oversight of the program, and the real experiences of those” in the psilocybin provider community had motivated the restructuring.³⁹
While greater industry representation improves the board’s practical expertise, it also increases the potential for regulatory capture — the phenomenon by which regulatory bodies come to reflect the interests of regulated parties rather than the public interest. OPS should consider whether OPAB’s advisory functions should include independent public health and consumer protection voices with no financial stake in the regulated industry.
VI. ADA Compliance: Cusker v. Oregon Health Authority
A. Background and Procedural Posture
In mid-2024, four plaintiffs — including three licensed psilocybin facilitators and a physician specializing in advanced illness — filed suit in the U.S. District Court for the District of Oregon, alleging that OHA’s psilocybin services program violates the Americans with Disabilities Act by failing to accommodate homebound individuals who cannot travel to a licensed service center.⁴⁰ The plaintiffs had previously asked OHA to develop a process for in-home accommodations; OHA responded that home use is not permitted under state law.
In a ruling issued in late May 2025, U.S. District Judge Mustafa T. Kasubhai denied OHA’s motion to dismiss, holding that the plaintiffs had standing and that requiring ADA-compliant accommodations would not violate federal law or the principles of federalism.⁴¹ The court drew on Smith v. 116 S Market LLC (9th Cir. 2020), which held that requiring ADA compliance from a marijuana dispensary did not force the dispensary to facilitate distribution of a Schedule I substance — it merely required equal access.⁴²
B. Compliance Implications
The Cusker litigation presents OPS with a structural compliance dilemma. If the court ultimately requires OHA to develop reasonable accommodation processes for homebound clients, this would require modifications to transportation rules (which currently prohibit psilocybin product transport to private residences), security protocols, chain-of-custody procedures, and facilitator-to-client supervision requirements — all of which were designed for licensed service center settings.⁴³
The regulatory response to Cusker will require coordination between OPS, the Oregon Legislature, and potentially the Oregon Secretary of State, to amend rules and authorize new product transport and home administration categories. Colorado’s Department of Regulatory Agencies confronted a similar question and initially considered permitting home services before narrowing the pathway to palliative care only.⁴⁴ Oregon’s outcome will depend on whether OHA characterizes any required accommodation as a “fundamental alteration” of the program — a defense that would exempt the accommodation from ADA requirements — or whether courts find that a more limited modification suffices.
VII. Rulemaking Record and Process Compliance
OPS has conducted annual rulemaking cycles since program launch, with extensive public engagement including Rules Advisory Committees (RACs), public hearings with Spanish and ASL interpretation, written public comment periods, and post-adoption letters to licensees.⁴⁵ The 2024 rulemaking cycle involved 20 hours of RAC meetings, over 60 written public comments, and more than four hours of public hearings.⁴⁶ The 2025 rulemaking cycle adopted new and updated administrative rules effective January 1, 2026.⁴⁷
The January 2025 rule amendments — the most significant since program launch — addressed: mandatory SB 303 data collection by service centers; increased facilitator training hours (8 additional hours of instruction plus 4 hours of continuing education); annual renewal cycles for facilitator training program curricula and worker permits (replacing five-year terms); a new compliance investigations framework; and strengthened duty-to-report obligations for licensees.⁴⁸
However, 63 stakeholders filed a joint public comment arguing that several of the January 2025 rule amendments “would increase costs for all licensees, and further push psilocybin services out of reach for many Oregonians.”⁴⁹ This cost-access tension is a persistent structural challenge: the compliance burden necessary to maintain program integrity is being borne by licensees who then pass those costs to clients — in a market where sessions already average approximately $2,500 for a three-part process and are rarely covered by insurance.⁵⁰
VIII. Findings and Recommendations
Finding 1: Testing Infrastructure Concentration. Oregon’s reliance on a single ORELAP-accredited testing laboratory for the entire state creates both supply chain disruption risk and testing integrity risk without redundant institutional checks. Recommendation: OPS should prioritize licensing of a second testing facility and should develop contingency protocols for supply chain disruption scenarios.
Finding 2: Training Program Quality Control Gaps. The financial structure of private training programs creates conflicts of interest that OPS’s curriculum-only oversight cannot adequately address. The 17% revocation rate among approved training programs warrants enhanced post-approval monitoring. Recommendation: OPS should require third-party audits of training program operations and graduation outcomes, and should develop competency-based performance standards for evaluating facilitators post-training rather than relying exclusively on curriculum review.
Finding 3: Proactive Inspection Deficit. Current enforcement is primarily complaint-driven and administrative-violation-based. There is no published evidence of a proactive, risk-based inspection program for service center operations. Recommendation: OPS should establish a proactive inspection cycle with a defined percentage of unannounced inspections annually, consistent with best practices in other state drug regulatory programs.
Finding 4: ADA Compliance Exposure. The Cusker litigation represents a foreseeable compliance realignment requirement. The absence of a regulatory plan for ADA accommodations leaves OPS reactive to judicial directives rather than proactively compliant with federal disability law. Recommendation: OPS should engage the Oregon Legislature to authorize a limited in-home services pathway — at minimum for palliative care patients — with appropriate security, transport, and supervision rule modifications.
Finding 5: Banking and Financial Compliance. The absence of banking access creates ongoing cash-management and audit-trail vulnerabilities for licensed businesses. Recommendation: OPS should advocate at the state level for Oregon legislation creating a state-chartered financial institution or credit union authorized to serve psilocybin licensees, analogous to models proposed for state cannabis markets.
Policy Observation: Geographic Access Inequity. The concentration of all licensed service centers in a small number of urban jurisdictions does not constitute a licensing system compliance failure under the OPS program’s governing statutes, but it represents a structural outcome that may undermine the program’s legislative purpose and long-term political sustainability. Observation: OPS should track geographic access metrics and report annually on the proportion of the state population within reasonable travel distance of a licensed service center, as part of its SB 303 public reporting obligations.
IX. Conclusion
Oregon’s Psilocybin Services program represents the most advanced, rigorously governed regulated psilocybin system in the world. Its rulemaking processes are thoughtful, its public engagement is extensive, and its safety record through Q3 2025 demonstrates that supervised psilocybin administration can be conducted without significant adverse events at population scale. At the same time, the program faces structural vulnerabilities — in testing infrastructure, facilitator training quality control, geographic access, ADA compliance exposure, and banking constraints — that require proactive regulatory attention before they generate compliance failures analogous to those documented in early-stage cannabis regulatory agencies elsewhere.
The program’s single greatest asset is the willingness of OPS to conduct regular rulemaking and to respond to emerging compliance issues through formal administrative processes. The greatest institutional risk is that the administrative burden and cost of compliance will continue to drive service center attrition to the point where the program serves only a small, wealthy, urban population — a policy outcome that conflicts with the equity goals embedded in Oregon’s psilocybin statute.
Client-facing rights protections applicable to program participants — including informed consent requirements, ADA accommodation pathways, anti-discrimination provisions, and grievance mechanisms — are addressed comprehensively in the Policy Reform / Governance / Oversight series. See Civil Rights Safeguards in Psychedelic Service Delivery Models, in this series.
Endnotes
¹ Oregon Ballot Measure 109 (2020); Ballotpedia, Oregon Measure 109, Psilocybin Mushroom Services Program Initiative (2020), https://ballotpedia.org/Oregon_Measure_109,Psilocybin_Mushroom_Services_Program_Initiative(2020) (55.8% approval).
² Oregon Health Authority, Oregon Psilocybin Services, https://www.oregon.gov/oha/ph/preventionwellness/pages/oregon-psilocybin-services.aspx; ASTHO, State Policies Supporting Evidence-Based Therapeutic Psilocybin Use, https://www.astho.org/communications/blog/state-policies-supporting-evidence-based-therapeutic-psilocybin-use/ (describing January 2, 2023 license application opening).
³ Or. Rev. Stat. §§ 475A.100–475A.500; OregonFacilitator.com, Oregon’s Law, https://oregonfacilitator.com/oregons-law.
⁴ Or. Rev. Stat. § 475A.215(7); Harvard Gazette, Why Regulators May Toss Cold Water on Buzz Over Psychedelics (Jan. 2024), https://news.harvard.edu/gazette/story/2024/01/why-regulators-may-toss-cold-water-on-buzz-over-psychedelics/.
⁵ ACS Lab, Oregon’s Psilocybin Mushroom Testing and Training Rules Are Out (2022), https://www.acslab.com/mushrooms/cultivation-oregons-psilocybin-rules (describing $500 curriculum approval fee and $10,000 service center annual license fee).
⁶ Oregon Health Authority, Oregon Psilocybin Services – Data Dashboard, https://www.oregon.gov/oha/ph/preventionwellness/pages/psilocybin-data-dashboard.aspx.
⁷ Psychedelic Alpha, The Oregon Psilocybin Services Tracker (Q3 2025 update), https://psychedelicalpha.com/data/the-oregon-psilocybin-services-tracker.
⁸ Id. (12 closures since early 2024).
⁹ Psychedelic Alpha, Oregon Psilocybin Services Tracker: Q1 2025 (Oct. 2025), https://psychedelicalpha.com/news/oregon-psilocybin-services-tracker-q1-2025 (attrition patterns among manufacturer licensees).
¹⁰ Id. (“Currently, a single testing lab handles supply testing for the entire state.”).
¹¹ Id. (30 curricula authorized; 18 active, 5 revoked, 7 voluntarily withdrawn as of Q1 2025).
¹² Odyssey PBC, How to Apply for a Psilocybin Facilitator License (2025), https://www.odysseypbc.com/blog-posts/how-to-apply-for-a-psilocybin-facilitator-license-2025-guide (facilitator training costs $4,500–$12,000 per the Odyssey PBC cost guide; Psychedelic Alpha’s Q1 2025 Tracker reports a narrower range of $6,000–$12,000 based on program survey data).
¹³ Psychedelic Alpha, Q1 2025 Tracker, supra note 9 (analysis of financial conflict of interest in training program quality control).
¹⁴ Oregon Health Authority, Oregon Psilocybin Services – Psilocybin Training Program Information, https://www.oregon.gov/oha/ph/preventionwellness/pages/psilocybin-training-program-approval.aspx.
¹⁵ Id. (Higher Education Coordinating Commission separately licenses career training programs and degree-granting institutions).
¹⁶ Psychedelic Alpha, The Oregon Psilocybin Services Tracker, supra note 7 (366 licensed facilitators, 23 operational service centers as of Q3 2025).
¹⁷ Harris Sliwoski LLP, Oregon Psilocybin: State of the State (2024) (Dec. 27, 2024), https://harris-sliwoski.com/psychlawblog/oregon-psilocybin-state-of-the-state-2024/.
¹⁸ Emerge Law Group, Oregon Psilocybin Services Rule Changes: Effective January 1, 2025 (Dec. 16, 2024), https://emergelawgroup.com/blog/oregon-psilocybin-services-rule-changes-effective-january-1-2025/ (describing OAR 333-333-5120(14) prohibition on facilitating outside service centers).
¹⁹ Harris Sliwoski LLP, supra note 17 (“OPS data also confirm that only two service center applications have been denied, with no denials in any other category.”).
²⁰ Journal of the American Academy of Psychiatry and the Law, The Perilous Policy of Oregon’s Psilocybin Services, 51(2):160 (June 2023), https://jaapl.org/content/51/2/160 (minimum facilitator qualifications: age 21+, high school diploma or GED, completion of approved 120-hour training, 75% examination score, criminal background check).
²¹ Oregon Health Authority, OPS Data Dashboard, supra note 6.
²² Oregon Health Authority, Oregon Psilocybin Services Publishes Interactive Data Dashboard (June 2025), https://www.oregon.gov/oha/ERD/Pages/Oregon-Psilocybin-Services-publishes-interactive-data-dashboard.aspx.
²³ Id. (1,509 clients Q1 2025; OHA’s dashboard categorizes six total adverse events for Q1 2025, counting two severe behavioral, three medical adverse, and one post-session reaction; Psychedelic Alpha’s aggregated table reflects five events under different severity groupings consistent with its classification framework).
²⁴ Psychedelic Alpha, Q1 2025 Tracker, supra note 9 (13 total emergency service reports since summer 2023 across 34 centers and over 26,500 products sold).
²⁵ Id. (Oregon defines adverse events narrowly as incidents requiring emergency services, medical attention, or hospitalization, distinct from clinical trial AE definitions).
²⁶ Oregon Health Authority, Oregon Psilocybin Services – Administrative Rules, Temporary Rule Notice (Aug. 29, 2025), https://www.oregon.gov/oha/ph/preventionwellness/pages/psilocybin-administrative-rules.aspx.
²⁷ Journal of the American Academy of Psychiatry and the Law, supra note 20 (raising scope-of-practice concerns; describing facilitator prohibitions on diagnosing or treating health conditions and on making health-related claims); OAR 333-333-3010 (prohibiting service center operators and facilitators from making medical claims or providing clinical diagnosis or treatment).
²⁸ Tripsitter, Efforts to Delay or Ban Oregon Psilocybin Program Reveal Urban/Rural Divide (Feb. 2023), https://tripsitter.com/legal/usa/oregon/counties-against-psilocybin/ (“25 of Oregon’s 36 counties and more than 100 cities . . . exercised the opt-out clause”).
²⁹ Harris Sliwoski LLP, supra note 17 (describing 15 additional cities and one county voting to ban psilocybin services in November 2024 election, listing Lake Oswego, Warrenton, Seaside, Oregon City, and others).
³⁰ OregonPsychedelics.org, Oregon Psychedelics Information Portal (2025), https://oregonpsychedelics.org/ (as of 2025: over 100 cities and 25 counties with bans or moratoriums).
³¹ AP via Standard-Speaker, A Growing Number of Oregon Cities Vote to Ban Psilocybin (Nov. 22, 2024), https://www.standardspeaker.com/2024/11/22/oregon-psilocybin-bans/.
³² KGW News, It’s Regarded as a Breakthrough Treatment for Depression — So Why Are Oregon’s Psilocybin Centers Closing?, https://www.kgw.com/article/news/local/the-story/psilocybin-therapy-struggles-to-take-off-across-oregon/283-5d55ce11-169f-4d51-ae22-b05e874264fb.
³³ Psychedelic Alpha, Q1 2025 Tracker, supra note 9.
³⁴ NBC Boston, Violations and Mismanagement Uncovered in Audit of Cannabis Control Commission (Aug. 15, 2025), https://www.nbcboston.com/news/local/violations-and-mismanagement-uncovered-in-audit-of-cannabis-control-commission-dizoglio-says/3790580/ (Assured Testing lab’s failure to report contamination in thousands of samples April 2024–April 2025).
³⁵ ASTHO, supra note 2 (testing laboratory requirements including ORELAP accreditation).
³⁶ OregonPsychedelics.org, supra note 30 (Oregon law permits only Psilocybe cubensis products; wild-harvested mushrooms and synthetic psilocybin prohibited).
³⁷ Harris Sliwoski LLP, Oregon Psilocybin: Slow Start (Feb. 2025), https://harris-sliwoski.com/psychlawblog/oregon-psilocybin-slow-start/.
³⁸ The Marijuana Herald, Oregon House Unanimously Approves Bill Expanding Psilocybin Access and Oversight (Apr. 15, 2025), https://themarijuanaherald.com/2025/04/oregon-house-unanimously-approves-bill-expanding-psilocybin-access-and-oversight/.
³⁹ Oregon House Committee on Behavioral Health and Health Care, Testimony re HB 2387 (Mar. 17, 2025), https://apps.oregonlegislature.gov/liz/2025r1/Downloads/PublicTestimonyDocument/157234.
⁴⁰ Marijuana Moment, Federal Judge Allows Lawsuit Seeking Home Psilocybin Care To Proceed, Rejecting Oregon Officials’ Motion To Dismiss (June 5, 2025), https://www.marijuanamoment.net/federal-judge-allows-lawsuit-seeking-home-psilocybin-care-to-proceed-rejecting-oregon-officials-motion-to-dismiss.
⁴¹ Cusker et al. v. Oregon Health Authority, No. 6:24-cv-00998 (D. Or. May 2025) (Kasubhai, J.); Reason, New Ruling Moves Oregon Closer to Legal In-Home Psilocybin Use (June 4, 2025), https://reason.com/2025/06/04/new-ruling-moves-oregon-closer-to-legal-in-home-psilocybin-use/.
⁴² Smith v. 116 S Market LLC, No. 20-55304 (9th Cir. Dec. 16, 2020); Psychedelic Week, Oregon Psilocybin Suit for Disability Access May Proceed Says U.S. Court (June 2, 2025), https://www.psychedelicweek.com/p/oregon-psilocybin-federal-suit-disability-ada-home-access.
⁴³ OPB, Psilocybin in Oregon May Help Address Fears of Death, But People Can’t Always Access It (Dec. 5, 2024), https://www.opb.org/article/2024/12/05/psilocybin-mushroom-therapy-disability-access-mental-health-oregon-portland/.
⁴⁴ Psychedelic Week, supra note 42 (Colorado DORA initially considered home services before narrowing to palliative care only).
⁴⁵ Oregon Health Authority, Oregon Psilocybin Services – Administrative Rules, supra note 26; OPS Summer 2024 Newsletter, Oregon Health Authority (June 21, 2024), https://content.govdelivery.com/accounts/ORDHS/bulletins/3a34836 (post-adoption letters sent to licensees describing rule changes).
⁴⁶ Oregon Health Authority, Oregon Psilocybin Services – 2024 Rulemaking, https://www.oregon.gov/oha/ph/preventionwellness/pages/psilocybin-2024-rulemaking.aspx (20 hours of RAC meetings, 60+ written comments, 4+ hours of public hearings in 2024 rulemaking cycle).
⁴⁷ Oregon Health Authority, Administrative Rules, supra note 26 (new rules adopted October 24, 2025, effective January 1, 2026; permanent adoption of temporary hours rule January 22, 2026).
⁴⁸ Emerge Law Group, supra note 18 (summarizing January 2025 rule changes).
⁴⁹ Harris Sliwoski LLP, supra note 17 (joint public comment from 63 stakeholders).
⁵⁰ KGW News, supra note 32 (session costs averaging approximately $2,500 for three-part process; rarely covered by insurance).