Which licenses qualify

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Source: the revised proposed rule, August 25, 2026. Entry credentials, prerequisites, the controlled substance number and the two-year certification: 7.35.3.9, pp. 2-3. Mentoring and testing out: 7.35.3.17, p. 11. Curriculum hours and continuing education: 7.35.3.18, pp. 11-13. Practicum and supervision hours: 7.35.3.19, pp. 13-14. Reciprocity deadline change: July 9 meeting transcript.

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Entry credentials: 7.35.3.9 (D), (E) and (F), revised proposed rule p.3. Reciprocity clause, which names certifying clinician alongside practitioner and facilitator: 7.35.3.10 (B), p.4. The August 25 text states each license's required practice, permitting diagnosis of the qualifying conditions for the certifying clinician and therapy, counseling, or behavioral services for the practitioner, with examples (e.g. MD, NP; e.g. PSY, LSW, LCSW); what a given license allows still sits with its governing board, the test the June 12 recommendation p.1 states and this table applies. End-of-life doula and palliative care specialist are read below.

Nothing in the chain lists licenses. The scope test was first written down in the June 12 recommendation, page 1, which defers the question to each license's governing board: a practitioner needs "a current and valid license from a recognized New Mexico licensing board which allows for the delivery of counseling, mental health therapy, or behavioral health therapy within their licensure scope of practice (as outlined by their governing licensure Board)," and a certifying clinician needs a license "which allows diagnosing the qualifying medical condition within their licensure scope of practice." The August 25 text now writes a scope requirement into the application items themselves: a certifying clinician documents a license "to practice in New Mexico and diagnose the qualifying conditions," and a practitioner a license "to practice therapy, counseling, or behavioral services in New Mexico," at 7.35.3.9 (D) and (E), p. 3. What any given license allows still sits with its governing board.

Reading each board's scope against that test produces two verdicts the legend did not previously carry, and the published rule addresses neither case.

Supervised only. New Mexico issues licenses whose scope reaches counseling and diagnosis but which may not be practiced independently. The associate and master tiers say so in their own rules: an LMSW "may not practice independently as a private practitioner," and the LMHC and LAMFT scope is expressed "under an appropriate clinical supervisor." Nothing in 7.35.3 addresses a license of this kind. A supervised counselor could be certified as a practitioner and then work an administration session without the supervision their own board requires; no provision of the published rule reaches that supervision.

The question the supervised tiers leave open. If a supervised licensee were certified as a practitioner, would the clinical supervisor their own board requires also need a permit under this program? No document and no meeting record held in this repository asks it. The published rule's supervision language sits entirely inside the program: a facilitator works under the direct supervision of a practitioner at 7.35.3.13 (B), and the practicum, its supervisors, and the practitioner's 20 supervisory hours sit at 7.35.3.19. The supervision a supervised license carries from its own licensing board appears nowhere in the 19 pages. Until that question is answered, no route can be stated for these licenses, and their rows are the only rows in the second table that link no starting point on Routes to a permit.

One condition. A LADAC's scope is treatment and intervention services specific to alcohol and other drug use disorders, and it reaches diagnosis of chemical abuse and chemical dependency disorders only. Assessment, treatment and diagnosis of mental health disorders sits expressly outside it. Substance use disorder is a qualifying condition, so the LADAC route exists for those patients and not for the others. It is the only verdict in the tables that runs by condition rather than by license, and the same question recurs at 7.35.3.8 (B)(8)(a), which requires the certifying clinician to attest that "The applicant has a qualifying diagnosis" without asking whether that clinician's scope covers that diagnosis.

Who may issue a certification the rule asks for. The rule names an issuer only where it writes "New Mexico". A professional license must be a license "to practice in New Mexico", and the emergency medical technician route reads "Licensure as a New Mexico emergency medical technician". Every other credential it requires is named without an issuer: basic life support, cardiopulmonary resuscitation, automated external defibrillator, HIPAA certification, wilderness first aid, and wilderness first responder. Each of those is issued nationally or privately and none is issued by New Mexico. The words "national", "nationally", and "accredited" do not appear anywhere in the 19 pages of the rule, and no certifying body is named for any of them. New Mexico issuance is required where the rule writes it, and elsewhere the rule accepts a certification without saying who may grant it or what would make one acceptable. For a person whose credential is national rather than a state license, the consequence is this: a national board certification cannot satisfy 7.35.3.9 (D)(1) or (E)(1), and it does not have to, because the facilitator route at 7.35.3.9 (F) asks for no license at all.

A note on the certifying column. 7.35.3.9 (D)(2) requires a "NM controlled substance number" of every certifying clinician, and most behavioral health licenses do not prescribe. That requirement, rather than the scope test, holds the column at Partial across the behavioral health rows.

Sources: June 12 recommendation p. 1 for both scope tests; published rule 7.35.3.8 (B)(8)(a), p. 2 and 7.35.3.9 (D) and (E), p. 3. Need source: the scope language for every New Mexico license named on this page comes from NMSA 1978 Section 61-9A-5 for the counseling and therapy board and from 16.63.9.9, 16.63.10.9 and 16.63.11.9 NMAC for the social work board. Neither document is held in this repository and neither has been read directly, so no scope language on this page is quoted as verbatim and every row drawn from it carries a Need source mark. Reading those two sources, and citing each row to its own subsection, is open work.

Certified by the department, on application

Certifying clinician, practitioner, and facilitator, at 7.35.3.9, each valid two years. Healing center, at 7.35.3.11 (A), two years, on a 25-item application. Other approved location, at 7.35.3.11 (B), 90 days, applied for by a practitioner or facilitator, with no renewal path in the rule. Psilocybin educational program, at 7.35.3.12, two years. Of these, only the facilitator route requires no professional license of any kind.

Authorized to handle the medicine without being certified

Healing center owners and employees, at 7.35.3.14 (C), may purchase, possess, sell and administer psilocybin to patients. The rule sets no license requirement, no training requirement, and no education requirement for them. It conditions the authority on being "registered with the department" and on designation by the healing center. No such registration exists anywhere in 7.35.3 or in 7.35.2. The authority therefore cannot be exercised as written, because the registration it is conditioned on was never created, and it is the one route to administering psilocybin that carries no qualification requirement of any kind.

Qualified students, at 7.35.3.20 (H)(5), count toward group session staffing at one per two patients once "registered with a certified educational program" and having "completed at least 50 hours of their practicum." The department never registers, numbers, or verifies a student, so the threshold rests on a private program's records.

Required on site, credentialed by somebody other than the department

Where an outdoor session is 15 minutes or more from emergency medical services, 7.35.3.11 (A)(22)(d) requires "at least two individuals present who are not receiving treatment" holding wilderness first aid certification, wilderness first responder certification, or New Mexico emergency medical technician licensure. No health license, no department credential, and no departmental approval. The rule does not say whether the practitioner and facilitator already on site may be these two people, or whether they must be two more.

Engaged privately, with criteria the department never checks

Third-party evaluators, at 7.35.3.16, must number at least three, each with three or more years of professional experience, collectively covering psilocybin therapy practice, medical and research practice, and curriculum evaluation, with a graduate degree behind each domain. The department never approves, lists, or disciplines them. Instructors, at 7.35.3.12 (A)(14), are judged on "collective expertise" across the whole roster, so no individual instructor need hold any credential. Certified faculty, at 7.35.3.12 (A)(22), must number two by December 31, 2027 and may hold "practitioner or facilitator certificates", so two certified facilitators satisfy it and this is a teaching route reachable with no health license. Practicum supervisors are named once, at 7.35.3.19 (E), with no credential, no ratio, and no sign-off authority stated.

Two people in the room: the co-facilitation route

Nothing in the rule requires a person to hold the whole role alone, and the staffing provision assumes the opposite. 7.35.3.20 (H)(5) requires "a minimum of one practitioner and one facilitator for individual patient sessions", so every session already has two certified people in it. 7.35.3.13 (B) sets the relationship: a facilitator "is authorized to work alongside a practitioner during medical psilocybin services" and "works under the direct supervision of a practitioner".

This is the route for a person whose practice the rule does not name and whose credential is not a New Mexico license. A traditional healer, a chaplain, a peer supporter, or a death doula becomes a certified facilitator, which requires no license of any kind, and works alongside a practitioner who holds one. The pair satisfies the rule where the individual does not. What that person must complete is the facilitator training and the practicum at 7.35.3.9 (F) and 7.35.3.19, so the barrier is hours and placement rather than eligibility, and it is the same barrier every facilitator faces.

Two limits sit on it as written. 7.35.3.13 (B) confines a facilitator to "peer support to qualified patients, as well as logistical and administrative support", and adds that a facilitator "shall not perform any patient care outside this scope, unless another license held by the facilitator permits it", so a traditional practice carried into the room is bounded by a scope written for a support role. And the practicum must be completed inside an approved healing center or other approved location under 7.35.3.19 (D), which is the same rural and access bottleneck raised on July 17. The rule creates no way to recognize existing practice in place of those hours, which is the legacy pathway question below.

Named in the record, with no route in the rule

A legacy or traditional practitioner seeking to come into the regulated program from outside it. Dezbaá raised it at the July 17 committee meeting, and Larry Leeman and Chris Caldwell both supported a legacy pathway. The rule's only alternative route, at 7.35.3.10, requires a completed psilocybin educational program from another jurisdiction: one approved by a government, one developed in collaboration with higher education institutions or with government-approved psychedelic research studies, or one on the department's approved list. It offers nothing to a person whose training was not a program. New Mexico recognizes traditional practice in two other places and in neither of them through this rule.Need source A training permit holder, proposed by Dr. Anne Metz and declined by the department in favour of the qualified student at 7.35.3.20 (H)(5). A practicum site supervisor on an apprenticeship model, proposed by Dr. Anne Metz, with her own open question of who would vet them. A well participant, the non-patient a first practicum stage would work with. An end-of-life specialist or endorsement overlaying the three roles, from the July 16 committee. None of these is in the published text.

Sources: published rule 7.35.3.9, 7.35.3.11, 7.35.3.12, 7.35.3.14, 7.35.3.16, 7.35.3.19 and 7.35.3.20, August 25, 2026, cited by subsection above. Meeting positions: July 17 Training and Education Committee transcript, and the July 16 End-of-Life Care committee, of which no record is held in this repository. Need source: the claim that New Mexico recognizes traditional healing practice through the Unlicensed Health Care Practice Act and through a Medicaid pathway for tribally recognized healers is stated here as a finding and has not been read against those sources directly.

No state in the United States licenses, certifies, registers, or title-protects a chaplain. Chaplaincy runs on voluntary private certification, and hospitals rather than governments are what make it compulsory in practice. New Mexico is no exception and issues no chaplain credential of any kind. The national certifications are private: Board Certified Chaplain from the Board of Chaplaincy Certification Inc., which asks for a bachelor's degree plus 72 graduate semester hours of theological education, four units of clinical pastoral education, faith-group endorsement, and 2,000 hours of chaplaincy work; parallel certifications from the National Association of Catholic Chaplains and from Neshama: Association of Jewish Chaplains, each requiring its own ecclesiastical endorsement; the Spiritual Care Association's three tiers; and the ACPE Certified Educator credential for those who teach clinical pastoral education. Hospice and palliative chaplaincy has its own advanced layer on top of board certification.Need source

One certifying body credits non-academic training. The Board of Chaplaincy Certification allows an applicant trained in a non-academic tradition, naming Buddhist and Indigenous traditions specifically, to satisfy the education requirement by documenting up to 7,200 hours of mentored study in place of a graduate degree. That is a worked example of recognizing lineage-based training inside a credential, and it bears on the legacy pathway question below.Need source

Pastoral counselor is a licensed title in six states, and New Mexico is not one of them. Kentucky, Maine, New Hampshire, North Carolina, Tennessee, and reportedly Arkansas license it. Contemporary accounts state those laws were passed principally so that pastoral counselors could bill health insurance, which makes them a precedent about payment rather than about competence. In New Mexico the position is different in kind: pastoral counselors holding a graduate degree are exempted from the Professional Psychologist Act, which is permission to practice without a psychology license rather than a credential of their own.Need source

The certification a New Mexico statute once pointed at no longer exists. The American Association of Pastoral Counselors stopped certifying and then dissolved in March 2019, its members and assets moving to the Association for Clinical Pastoral Education by that June. No body inherited the credential. ACPE certifies educators and offers continuing education, not pastoral counselor certification. New Mexico appears to have carried a pastoral counselor exemption tied to that association's certification with a sunset of June 30, 1998, and to have removed the reference in 1999, leaving a degree-only exemption. Whether any New Mexico provision still names the association is unresolved here; a condition written against a defunct certifier cannot be met by anyone.Need source

Two New Mexico exemptions do the work instead, and neither is a route into this program. The Counseling and Therapy Practice Act exempts duly ordained, commissioned, or licensed ministers providing pastoral services on behalf of a church, and separately exempts practitioners of Native American healing arts. It also shelters an alternative, metaphysical, or holistic practitioner, but only for nonclinical activity, which is a limit for anyone whose practice touches diagnosis or treatment. The Professional Psychologist Act carries the longer list, covering ministers, lay pastoral-care assistants, Christian Science practitioners, science of mind practitioners serving a church without compensation, and pastoral counselors with graduate degrees. Alongside both sits the Unlicensed Health Care Practice Act, a disclosure regime rather than a credential, which names culturally traditional healing practices including those of a curandera, sobadora, partera, medica, and arbolaria, and healing traditions including plant medicines and foods, prayer, ceremony and song.Need source

Need source, and this whole section is marked so. Every statement above about New Mexico statutes, about the six pastoral counselor states, and about the private certifying bodies is a finding assembled from research this repository cannot yet verify against a primary document, because those documents are not held here and could not be read directly. The New Mexico provisions concerned are the exemptions sections of the Counseling and Therapy Practice Act and the Professional Psychologist Act, and the Unlicensed Health Care Practice Act at NMSA 1978 Sections 61-35-1 through 61-35-8. Nothing in this section is quoted as verbatim statutory text. The claims about the psilocybin rule itself, in the box above, are drawn from 7.35.3.9 (D), (E) and (F), p. 3 and are checkable.

The end-of-life doula has one route, and it is the facilitator route. The two licensed roles are closed to a doula as such. A certifying clinician must submit "Documentation of current professional license to practice in New Mexico (e.g. MD, NP)" at 7.35.3.9 (D), and a practitioner must submit "Documentation of current professional license to practice in New Mexico (e.g. PSY, LSW, LCSW)" at 7.35.3.9 (E). New Mexico credentials doulas, but only birth doulas: the Doula Credentialing and Access Act, effective July 1, 2025, created a voluntary state certification with a public registry and a Medicaid payment pathway, and scoped it by its own definition to the pre-conception period, pregnancy, childbirth and the postpartum period. End-of-life doulas fall outside it, and no other New Mexico credential reaches them, so the certification an end-of-life doula holds comes from a private training body and is not a New Mexico professional license.Need source The facilitator route asks for no license at all: 7.35.3.9 (F) requires the practicum, current BLS or both CPR and AED or New Mexico emergency medical technician licensure, HIPAA certification completed within the preceding two years, and a W-9. A doula who completes the facilitator training and practicum is eligible on the same terms as any other applicant, and the same is true of a chaplain and of a hospice volunteer.

The palliative care specialist is graded by the license underneath the specialty. Palliative care is a field of practice, not a New Mexico license, and the rule never names a specialty. A hospice and palliative medicine physician is read on the Physician row, a palliative care nurse practitioner on the Nurse Practitioner row, a palliative care social worker on the LCSW row, a palliative care nurse on the Registered Nurse row, and a palliative care chaplain on the Chaplain row. Those rows do not agree with one another, which is the point: the same palliative care team can hold three different sets of routes. The facilitator column is the one they share, because it turns on no license.

Both readings are walked step by step on Routes to a permit. The palliative care specialist is a starting point of its own there, a specialty rather than a license, with the certifying clinician and practitioner verdicts set by the license held. The end-of-life doula's one route opens from the no-health-license start, on the facilitator pathway.

Neither role exists in the rule as itself. A doula may be in the room, in the fourth class set out under every role: 7.35.3.20 (D) admits "the other individual(s)" on each patient's prior written consent. What the rule does not do is give that person a permit, a scope, a training standard, or a place in the staffing ratio at 7.35.3.20 (H)(5), which counts only practitioners, facilitators, and qualified students. Larry Leeman named this at the July 16 End-of-Life Care committee meeting as the gap that a chaplain or end-of-life doula has no post-training slot in the three-role structure. Nothing in the rule published on July 23 creates one. The template exists in New Mexico law: the state built a doula certification with a registry and a payment pathway and pointed it at birth.

Entry credentials: 7.35.3.9 (D), (E) and (F), revised proposed rule p.3. Presence at an administration session: 7.35.3.20 (D), p.14. Staffing ratio and the qualified student: 7.35.3.20 (H)(5), p.15. The absence of a New Mexico license for end-of-life doulas is stated here as the reason the two licensed columns are closed; the rule itself names no such license and no such role. The post-training slot gap: End-of-Life Care committee meeting, July 16, 2026, attributed to Larry Leeman; no record of that meeting is held in this repository. The layer these two roles would carry, if the committee adopts one, is below the line that follows.