Section by section

July 9 rules draft

"This rule applies to all patients, practitioners, clinicians, facilitators, healing centers and other approved locations, and educational programs who participate and seek to participate in the New Mexico medical psilocybin program." (p. 1); "promulgated pursuant to the following statutory authorities: the New Mexico Department of Health Act, Subsection E of Section 9 -7-6 NMSA 1978; and the Medical Psilocybin Act, Section 26-2D-7, NMSA 1978." (p. 1)

July 9 rules draft

"the certification of certifying clinicians, practitioners, facilitators, and approved locations" (p. 1)

July 9 rules draft

no counterpart (the July 9 draft contains no definitions section)

July 9 rules draft

"An applicant seeking certification as a psilocybin educational program shall submit a complete application through the electronic system designated by the department." (p. 1); the 21 listed items include "An organizational chart depicting the applicant's governance and operational structure", "Proof of registration with the New Mexico secretary of state", "A record retention plan", "A safety and emergency response plan appropriate to the program's operational settings", and "A written outline of the program's complaint and grievance procedures available to students" (p. 1)

July 9 rules draft

"(15) Copies of all course syllabi and a web address at which the program will publicly maintain updated syllabi for prospective students" (p. 2); "(18) A signed consent authorizing the department to publicly list the curriculum and syllabi submitted with the application, if approval is granted" (p. 2)

July 9 rules draft

"(17) A plan demonstrating how the program will ensure that enrolled students complete all required components and graduate within two years of enrollment" (p. 2)

July 9 rules draft

"(19) A third-party evaluation report assessing the organization and curriculum and demonstrating that the program meets the requirements for medical psilocybin educational programs" (p. 2)

July 9 rules draft

"(20) Proof of established arrangements with healing centers or other department-approved locations for student practicum placements" (p. 2)

July 9 rules draft

"(21) Documentation demonstrating that, no later than June 30, 2027, the program will employ at least two faculty members who hold current practitioner or facilitator certificates issued by the department." (p. 2)

July 9 rules draft

"shall notify the department ... of any of the following changes, and shall not implement the change until written approval is issued by the department", covering "Any revision to the program's curriculum", "Any change in ownership", "Any change in physical locations", "Any modification, termination, or addition of practicum site agreements", and "Any change in instructional staff" (p. 2)

July 9 rules draft

"If approved, the approval shall take effect on the date of the notice and shall remain valid for two years. ... An applicant whose application has been denied may resubmit a corrected application within six months. No applicant may resubmit an application more than two times following an initial denial." (p. 2)

July 9 rules draft

denial permitted if "The submitted curriculum does not comply with the Department's required curriculum standards", "The applicant fails to submit all required documentation or submits incomplete materials", or "Program instructors, staff, or representatives have made false or misleading statements to the Department, to students, or to the public." (p. 2)

July 9 rules draft

"shall submit a complete renewal application packet through the department-approved electronic system no more than 60 days and no less than 30 days prior to the certification's expiration date" (p. 2)

July 9 rules draft

"A psilocybin educational program may voluntarily relinquish its certification at any time, for any reason ... by submitting written notice of relinquishment to the department" (p. 2)

July 9 rules draft

"The department or its designee may conduct remote or on-site assessments of a psilocybin education program, healing center or other approved location, with or without prior notice, during normal business hours" (p. 3); "the department or its designee may not interrupt or disturb patient sessions without prior written consent from the patient(s) except in emergency situations" (p. 3)

July 9 rules draft

assessments "may include review and observation of the current curriculum, instructional delivery, and related educational activities to determine whether the curriculum is being implemented with fidelity" and "shall include a review of the program's record retention plan" (p. 3)

July 9 rules draft

"The department may revoke the certification of a psilocybin educational program, healing center or other approved location that does not meet the requirements of the Medical Psilocybin Act or this rule, or that fails during an assessment to demonstrate ongoing compliance." (p. 3)

July 9 rules draft

"The evaluation team shall consist of no fewer than three individuals"; "Each evaluator shall possess at least three years of professional experience" in psilocybin therapy practice, medical or research practice, or "Educational curriculum development and evaluation", each supported by "a master's or doctoral degree" in a listed field (p. 3)

July 9 rules draft

disqualifying conflicts include "Participation in the design, development, or teaching of the curriculum being evaluated" and "Holding a financial interest in, receiving compensation from, or serving in any governance or advisory capacity with the program or organization being evaluated." (p. 3)

July 9 rules draft

the report shall include "An assessment of the reliability, validity, and fidelity of implementation of the curriculum", "Performance evaluations of all faculty members participating in the program", and "A review and evaluation of any reported student grievances" (pp. 3-4)

July 9 rules draft

"(2) An overview of the use of psilocybin in a therapeutic model in New Mexico" (p. 4)

July 9 rules draft

"(1) Education on the New Mexico Medical Psilocybin Act" (p. 4)

July 9 rules draft

"(3) Education on the social, cultural and historical aspects of psilocybin use, including traditional use by native American and other populations in New Mexico" (p. 4)

July 9 rules draft

"(4) Spiritual, existential, religious, and theological (SERT) aspects of psilocybin therapy" (p. 4)

July 9 rules draft

each module list ends with "Evaluation to demonstrate competency in the above areas" (pp. 4, 5)

July 9 rules draft

"a certifying clinician module consisting of a minimum of 8 didactic hours prior to applying for certification" (p. 4)

July 9 rules draft

"(1) Psilocybin action, interactions, and pharmacology; (2) Overview of certifying clinician responsibilities; (3) 42 CFR Part 2; (4) Education on diagnosis of qualifying conditions; (5) Determining medical clearance for psilocybin therapy; (6) Psychedelic emergencies/urgencies and medical monitoring; (7) Research and data collection requirements" (p. 4)

July 9 rules draft

"42 CFR Part 2" appears in the certifying clinician module (p. 4) and in the practitioner and facilitator module (p. 4)

July 9 rules draft

no counterpart

July 9 rules draft

"(1) Psilocybin action, interactions, and pharmacology" (p. 4)

July 9 rules draft

"a psilocybin therapy module consisting of a minimum of 25 didactic hours, prior to applying for certification" (p. 4)

July 9 rules draft

a single 14-item list for both roles, including "(5) Set and setting", "(6) Ethics in therapeutic settings", "(7) Patient-centered approaches and care", "(8) Preparation and integration sessions", "(9) Administration session", "(10) Psychedelic de-escalation techniques", "(11) Self-care" (p. 4)

July 9 rules draft

"(13) A simulated patient experience of no less than 5 hours in addition to the 25 didactic hours" (p. 4)

July 9 rules draft

"(12) Research and data collection requirements" (p. 4)

July 9 rules draft

no counterpart phrases in the 25-hour module list (p. 4)

July 9 rules draft

"a facilitator-specific training module consisting of a minimum of 5 didactic hours" including "(1) Peer facilitation ethics", "(2) How to work as part of a care team", "(3) What it means to be present with a patient", "(3) For informational purposes: basic concepts of psychotherapy" (pp. 4-5)

July 9 rules draft

"a module on psychedelic and psilocybin therapeutic approaches consisting of a minimum of 5 didactic hours" including "(1) Education of psilocybin specific therapeutic modalities and non-ordinary states of consciousness" and "(2) How to work as part of a care team" (p. 5)

July 9 rules draft

"complete and maintain proof of current certification prior to applying for medical psilocybin certification in: (1) The Health Insurance Portability and Accountability Act (HIPAA); and, a. Basic Life Support (BLS); or b. Both Cardiopulmonary Resuscitation (CPR) and Automated External Defibrillator (AED) certification" (p. 5)

July 9 rules draft

stated as an outdoor location staffing requirement: "If the natural environment setting is 15 minutes or more away from emergency medical service response or a hospital, urgent care, or other emergency medical services, then there must be at least two individuals present who are not receiving treatment and who have: (a) Wilderness first aid certification; (b) Wilderness first responder certification; or (c) Licensure as a New Mexico emergency medical technician" (p. 12)

July 9 rules draft

"a minimum of 8 hours of continuing medical education credits specific to psychedelic medicine or therapy every 2 years" (p. 5)

July 9 rules draft

"a minimum of 20 hours of continuing education credits specific to psychedelic therapy and practice every two years" (p. 5)

July 9 rules draft

"keep current Basic Life Support, or Cardiopulmonary Resuscitation and Automated External Defibrillation certification in addition to the 20 hours of continuing education credits" (p. 5)

July 9 rules draft

no counterpart using "annually"; the draft states continuing education intervals as "every 2 years" (p. 5)

July 9 rules draft

"The practicum shall consist of a minimum of 100 hours of supervised practice training for facilitators and 120 hours for practitioners and must be completed prior to applying for certification." (p. 5)

July 9 rules draft

"a minimum of 80 hours of administration and same-day therapy sessions, where students are provided the opportunity to experience, observe, or conduct supervised facilitation of administration and therapy sessions in-person with a minimum of 14 different patients over a minimum of eight different administration and same-day therapy sessions" (p. 5)

July 9 rules draft

"A minimum of six different patients during a minimum of six individual administration and same-day therapy sessions; and ... A minimum of two different group administration and same-day therapy sessions with four or more patients in each group" (p. 5)

July 9 rules draft

"a minimum of 20 hours of in-person preparation and post-integration therapy sessions ... a minimum of six different patients during individual sessions ... at least one group preparatory and one group post-integration session with a minimum of four or more patients" (p. 5)

July 9 rules draft

"Practitioners shall complete an additional minimum of 20 hours as a practitioner supervising facilitators during in-person administration and same-day therapy sessions, which shall include a minimum of two different patients during individual administration and same-day therapy sessions, and a minimum of one group administration and same-day therapy sessions with a minimum of four or more patients in the group." (p. 5)

July 9 rules draft

"All practicum hours shall take place in an approved healing center or other approved location." (p. 5)

July 9 rules draft

"Practicum supervisors and students shall follow these rules as they apply to facilitation and therapy, including but not limited to standards for HIPAA and Hi-TEC confidentiality and limits on scope of practice." (p. 5)

July 9 rules draft

"The department may otherwise waive, temporarily suspend, or reduce the practicum requirements for individuals applying for certification, in order to facilitate the certifying of individuals trained by other governmental approved programs to build the initial infrastructure of the program" (p. 6)

July 9 rules draft

"An application for certification that is received by the department by June 30, 2027 from someone who has completed the didactic requirements after June 20, 2025 through an educational program subsequently certified by the department by June 30, 2027 shall not be required to complete the full practicum hours otherwise required by New Mexico, but shall demonstrate completion of at least 40 hours of contact time with a minimum of two separate individual sessions or two separate group sessions for preparation, administration, and integrative therapy with psilocybin treatment conducted in any jurisdiction where psilocybin therapy is legal." (p. 6)

July 9 rules draft

"All educational programs shall provide each practitioner and facilitator student with a minimum of 10 hours of mentoring sessions after graduation and after practicum hours are completed." and "These mentoring sessions may not have additional associated charges beyond the cost of the educational program itself." (p. 6)

July 9 rules draft

"The 10 hours are valid for up to 12 months after practicum hours are completed." (p. 6)

July 9 rules draft

"Educational programs shall maintain the following records for a minimum of five years: (1) All course syllabi; and (2) Enrollment records, including but not limited to the: (a) Name of each student; (b) Date of start and completion for each student; (c) Examination results for each student; (d) Dates, locations, and number of patients seen during each of the practicum sessions" (p. 6)

July 9 rules draft

"(e) Names of facilitators supervised by practitioner students during practicum." (p. 6)

July 9 rules draft

"Educational programs shall upload the completion certificate into the department approved online portal.", "Educational programs shall provide current and former students their records upon request.", "Educational programs shall provide records required to be maintained under this rule to the department upon request." (p. 6)

July 9 rules draft

"An educational program shall ensure that records are maintained in accordance with applicable law." (p. 6)

July 9 rules draft

individuals trained in "a current psilocybin educational program that has been approved by a state, U.S. territory or commonwealth, a federally-recognized tribe, pueblo, or Indian nation in New Mexico or elsewhere in the United States, or the government of another nation" may apply; applicants shall "Provide documentation of completion of the government approved psilocybin educational program from another jurisdiction", "Complete the New Mexico module", and "Complete the required practicum or demonstrate completion of a practicum or practice with the minimum number of patients and hours as required in New Mexico" (p. 6)

July 9 rules draft

"If a portion of the practicum hours have been completed in another jurisdiction and are able to be verified by the department, the remaining required practicum hours may be completed through a New Mexico approved educational program so long as the total hours and minimum number of patients required by the New Mexico program are met. For the practitioner certification, the reciprocal applicant will need to ensure they complete the 20 supervisory practicum hours in New Mexico." (pp. 6-7)

July 9 rules draft

"An applicant for reciprocity whose application is received by the department by December 31, 2026 shall not be required to complete the full practicum hours required by New Mexico, but shall demonstrate completion of at least 40 hours of contact time with a minimum of two separate individual sessions or two separate group sessions for preparation, administration, and integrative therapy with psilocybin treatment." (p. 7)

July 9 rules draft

"The department may otherwise waive, temporarily suspend, or reduce the practicum requirements for individuals applying for reciprocity, in order to facilitate the certifying of individuals trained by other governmental approved programs to build the initial infrastructure of the program." (p. 7)

July 9 rules draft

acceptance requires "Documentation that the program is included on the list of department-approved reciprocal psilocybin educational programs from other jurisdictions, which shall include medical psilocybin educational programs approved by the states of Oregon or Colorado" or documentation of other governmental approval plus "proof that the curriculum is substantially equivalent to the didactic requirements applicable to New Mexico educational programs" (p. 7)

July 9 rules draft

"Department approval of reciprocal psilocybin educational programs that is based on approval from another jurisdiction is valid for up to two years from the date of approval; provided that the department's approval shall terminate upon revocation, suspension, or expiration in the original jurisdiction." with renewal "for two more years" after a curriculum review requested "up to 30 days prior to their expiration" (p. 7)

July 9 rules draft

"Approved educational programs shall offer an option for a student to take the test for each module without attending the lessons or classes for the module, except the New Mexico Module"; "The cost to take the test for each module cannot be more than one-fourth (¼) of the normal price of each of the educational modules" (p. 7)

July 9 rules draft

"If the student receives a passing grade for a module test, they will have been considered to have completed the module"; "The educational program may allow students to re-take the test without attending the lessons or classes for the modules at their discretion"; students "must still complete all other requirements for the educational program including the New Mexico Module, certifications, simulated patient, and practicum requirements" (p. 7)

July 9 rules draft

"A patient may not be certified or treated by a certifying clinician, practitioner, or facilitator who is related to the patient within the second degree of consanguinity or the first degree of affinity, including a spouse, child, stepchild, parent, step-parent, sibling, grandparent, mother-in-law, father-in-law, son-in law, or daughter-in-law of the patient." (p. 7)

July 9 rules draft

"A person who holds an ownership interest in a certificant shall not hold an ownership interest in a permittee." (p. 7)

July 9 rules draft

"An applicant must submit a completed application packet through the electronic system designated by the department"; "If the application is approved, the approval is effective on the date of notice and will be valid for two (2) years."; "the applicant may re-submit their application within six months"; "Applicants may not re-submit their application more than twice"; "Applicants may appeal a denial utilizing the process outlined in this rule." (pp. 7-8)

July 9 rules draft

denial required if "Not all required items have been submitted or are not complete", including "Insufficient or expired licensure" and "Missing or inadequate documentation of certification, education or practicum requirements", or if "The applicant has made false or misleading statements in the application or to the department or the public" (p. 8)

July 9 rules draft

"For renewal, applicants must complete a new applicant packet through the department-approved electronic system no more than 60-days and no less than 30-days prior to the expiration of their certification." (p. 8)

July 9 rules draft

"Certificants may voluntarily relinquish their certification at any time and for any reason, by providing written notice to the department." (p. 8)

July 9 rules draft

"Certificants must provide and consent to having contact information with a minimum of name, phone number, and email address published publicly." (p. 8)

July 9 rules draft

"Documentation of current NM professional license (e.g. MD, NP)" (p. 8)

July 9 rules draft

"Certificate or verification of results NM Controlled Substance number" (p. 8)

July 9 rules draft

"Documentation of completion of the department required Certifying Clinician training requirements" and "Documentation of continuing education requirements" within a certification application packet (p. 8)

July 9 rules draft

"Completed W-9 form"; "Documentation that they have tested out of the didactic portion of the required curriculum"; "Attestation they are not a registered sex offender and the department will deny or revoke a certification for anyone who is a registered sex offender"; personal data including "Date of birth", "NM Driver's License or state ID", "Phone/email/mailing address", "Legal names", "Affirmation and consent forms" (p. 8)

July 9 rules draft

"Documentation of current professional license to practice in New Mexico (e.g. PSY, LSW, LCSW)" (p. 8)

July 9 rules draft

"Completed W-9 form"; "Documentation of completion of department-approved practitioner training program"; "Documentation of completion of the department-approved practicum requirements"; documentation of current "Basic Life Support (BLS); or Both Cardiopulmonary Resuscitation (CPR) and Automated External Defibrillator (AED) certification"; "Documentation of current HIPAA certification"; the sex offender attestation; and personal data items (pp. 8-9)

July 9 rules draft

"Documentation of completion of the department-approved facilitator training program"; "Documentation that they have tested out of the didactic portion of the required curriculum"; "Documentation of completion of the department-approved practicum requirements"; documentation of current "Basic Life Support (BLS); or Cardiopulmonary Resuscitation (CPR) and Automated External Defibrillation (AED) certification"; "Documentation of current HIPAA certification"; the sex offender attestation; and personal data items (p. 9)

July 9 rules draft

"Documentation of completion of a psilocybin educational program from another governmental jurisdiction"; "Documentation of active Practitioner or Facilitator or equivalent licensure or certification in another jurisdiction"; "Documentation of minimum core practicum hours and NM-required practicum hours"; "Documentation of completion of NM-specific training module"; verification of BLS or CPR and AED certification; "Documentation of current HIPAA certification"; the sex offender attestation; and "Personal data as appropriate" (pp. 9-10)

July 9 rules draft

"Documentation of diagnosis of qualifying condition by a certified Diagnosing Clinician" plus personal data: "Date of birth", "Phone/email/mailing address", "Legal name", "Affirmation and consent forms" (p. 10)

July 9 rules draft

certificants "shall utilize the electronic system designated by the department to record information including" the "Diagnosis qualifying the patient", "Attestations about evaluating and treating the patient", date and type of service for evaluation, preparation, administration ("Including approved location", "Unique Identification Number of medicine used", "Dosage"), "Initial Integrative Therapy Session", "Any adverse events", and "Information required for the Equity and Access Fund" (p. 10)

July 9 rules draft

"In order to certify a patient, a certifying clinician must have an actual clinician- client relationship with the patient. A certifying clinician shall conduct an in-person physical or mental evaluation of the applicant or qualified patient prior to issuing a certification. A certifying clinician may only issue a patient certification on the basis of an evaluation conducted via telemedicine if the certifying clinician has previously examined the patient in person within the previous 6 months." (p. 10)

July 9 rules draft

prohibition may follow "failure to comply with any provision of this rule", "falsification of any material or information submitted to the department", "threatening or harming a patient, an employee of a producer or laboratory, a clinician, a practitioner, or an employee of the department", or "any determination by the clinician's licensing body that the clinician has engaged in unprofessional or dishonorable conduct" (p. 10)

July 9 rules draft

a request for administrative review "shall: (a) be made within 30 calendar days, as determined from the date of the denial notice"; the review "shall be completed ... no later than 15 calendar days from the date that the program receives the written request"; "The administrative review proceeding is not an adjudicatory hearing"; "there shall be no right to judicial review of a decision by the administrative review committee" (pp. 10-11)

July 9 rules draft

program participation "does not relieve the qualified patient from" listed liabilities, including "criminal prosecution or civil penalties for fraudulent representation to a law enforcement officer", "liability for damages or criminal prosecution arising out of the operation of a vehicle while under the influence of psilocybin", and criminal prosecution or civil penalty for possession, distribution, transfer, or use "in the workplace of the qualified patient's employment", "at a public park, recreation center, youth center, or other public place", "to a person not approved by the department", or "outside New Mexico" (p. 11)

July 9 rules draft

"A. consumption or possession of psilocybin that is not consumed or obtained as part of an administration session conducted in accordance with the requirements of this rule" (p. 11)

July 9 rules draft

required items include an organizational chart, state registrations, business licenses, certificate of occupancy, "proof of ownership of any property on which medical psilocybin administration sessions will be conducted" or an owner's signed statement, "Plan for secured storage for medical psilocybin", "Plans for wastage of any unused medical psilocybin", "Plan for transparency and disclosure of fees for patients", and "Proof that the location has a functioning communication device which can reliably reach emergency medical services" (pp. 11-12)

July 9 rules draft

outdoor locations require "A detailed description of the outdoor administration area, including identification of safe entrance and exits, and verification that the area is free from hazards", "An emergency safety and response plan", "Proof that emergency medical services can reliably be contacted from, and respond to, the location", and the two-person wilderness or EMT credential requirement when "15 minutes or more away from emergency medical service response" (p. 12)

July 9 rules draft

"Other approved locations include a patient's residence or other temporary location utilized if it is not possible for the patient to physically go to a Healing Center for reasons of medical necessity."; submissions include "A list of the certified individuals who will be utilizing the approved location", "Plan for secure transportation and, safe storage for medication", "Plans for wastage of any unused medicine", "A safety and emergency response plan", "Plan for storage of firearms safety during and after treatment sessions", "Plans demonstrating confidentiality of patients will be maintained", and "A description of why the location is appropriate for treatment sessions" (p. 12)

July 9 rules draft

"A healing center shall not possess firearms on their premises." (p. 13)

July 9 rules draft

"Psilocybin products may only be consumed in an approved location."; "Only patients and certified individuals may be present during a patient treatment unless each patient gives prior written consent for other individuals to be present, except in emergency response situations." (p. 13)

July 9 rules draft

"Maintain a copy of a daily log of activities related to psilocybin in the approved electronic system"; "May only sell or provide psilocybin products obtained from permitted producers"; "May not promote unregulated cultivation and processing of psilocybin products and may not sell unregulated psilocybin products."; healing centers must display or provide the certification, "Information regarding safe transportation after an Administration Session", "The healing center's patient bill of rights and responsibilities", informed consent information, complaint filing information, and "How to report an adverse health event to the department" (p. 13)

July 9 rules draft

every approved location shall document procedures for "evacuating and relocating patients", "emergency response when a patient experiences a medical or other emergency", "addressing disruptive conduct", "patients who attempt to leave a treatment session against medical advice", and "ensuring there are practitioners and facilitators present at all times according to the minimum patient/provider ratio required by the department"; if procedures are used, "there will be a documented report submitted within 48 hours through the electronic system" (pp. 13-14)

July 9 rules draft

products "must be kept within a locked area" that is "An area enclosed on all sides with permanent walls and secured with at a minimum, a properly installed steel door with a steel frame, and a commercial grade, non-residential lock; or, A locked safe; or," and "Products that require refrigeration may be stored within a locked refrigerator or freezer." (p. 14)

July 9 rules draft

"Any potential adverse health event associated with medical psilocybin services shall be reported to the Department no later than two (2) business days after the healing center is notified, using the electronic system."; reports must include "Patient record number", "Unique identification number of the product(s) used", "Any participant reaction requiring medical attention", "Any challenging psychological, emotional, or behavioral reactions", "Any incident requiring emergency response", and "Other incidents which have a negative impact on a patient(s)" (p. 14)

July 9 rules draft

"Patients or staff may lodge a complaint with the department."; complaints "should be in writing and submitted by U.S. mail or through the electronic system" and include "Name and contact information for the complainant which will remain confidential" and "The nature of the complaint and any other individuals who may be involved" (p. 14)

July 9 rules draft

"The department may issue a notice of contemplated action to deny, suspend, or revoke, or take other disciplinary action" against patients, certificants, healing centers, other approved locations, and educational programs "(not including an educational program that is recognized through reciprocity)"; grounds include "violation of, or failure to comply with, any provision of this rule", "conduct that shows willful or reckless disregard for health or safety", and "falsification or misrepresentation of any material or information submitted to the department" (pp. 14-15)

July 9 rules draft

a hearing request must be mailed "no later than 30 calendar days from the date that the notice of contemplated action is received" (p. 15); "the hearing shall not be held later than 60 calendar days from the date the department receives the request for hearing" (p. 15); "Hearings shall be conducted in Santa Fe, NM" with telephone or web video options (p. 15); "The appellant shall bear the burden of establishing by a preponderance of the evidence that the decision made or proposed by the department should be reversed or modified." (p. 16); the hearing officer recommends action within 30 calendar days of the last submission, and "The secretary shall issue a final written decision ... no later than 45 calendar days after receipt of the hearing officer's recommendation." (p. 16)

July 9 rules draft

"The provisions of this rule are separate and severable. If any provision of this rule is held to be invalid, unconstitutional, or unenforceable, the remaining provisions shall stay in effect." (p. 17)

July 9 rules draft

no counterpart in the training or continuing education sections; wilderness credentials appear only as an outdoor location staffing requirement (p. 12)

July 9 rules draft

no counterpart

July 9 rules draft

no counterpart; the draft requires "Basic Life Support (BLS); or Both Cardiopulmonary Resuscitation (CPR) and Automated External Defibrillator (AED) certification" (p. 5)