The committee recommendation · the August 21 position · beside the August 25 published text

The committee recommendation

On July 17 the Advisory Board voted 7-0 to send the practicum and didactic hours, with the definitions, to the Training and Education Committee. The committee submitted a summary of the recommended rules on July 27 and refined its position at the August 21 committee meeting; no vote was taken, and the recommendation went to the department for the revised rules. The department published those rules on August 25. This page states the recommendation in full, and what the published text took, altered, and declined. Public comment continues through the rule hearing on October 2.

Updated August 26, 2026.

Status

NOWThe recommendation stands at the August 21 position below, and the revised proposed rules published August 25 answer it. The published text takes the 80-hour didactic total, recomposed as 65 module hours plus 10 simulated patient hours without the nine per-area minimums; declines the staged practicum, keeping 100 and 120 hours with a two-case presentation evaluation inside them; keeps the 10 mentoring hours the recommendation replaced; and declines both role renames. The comparison is in the section below.

THENThe rule hearing is October 2, 9:00 AM, fixed by the notice published August 25, and written comment must be received by its close. Changes can still be made through the hearing, as they were in the producer rulemaking; whatever stands after it goes to the New Mexico Register as the adopted rule.

Against the published text of August 25

Requirement	The recommendation, August 21	The published text, August 25
Didactic total #	80 hours, with minimums in nine content areas summing to 63	80 hours as a module total: 65 therapy-module hours plus a 5-hour role module and 10 simulated patient hours, with 26 required topics and no per-area minimums. The text: "a psilocybin therapy module consisting of a minimum of 65 didactic hours with at least one third of the didactic hours conducted in person, and 10 hours of simulated patient experience". 7.35.3.18 (C), p.12
Simulated patient #	2 hours, inside the 80	10 hours: "An in-person simulated patient experience of no less than five hours" and "an additional simulated patient experience of no less than five hours, which may be in- person, virtual, either synchronous or asynchronous". 7.35.3.18 (C)(2), pp.12-13
Practicum #	102 hours for Facilitators, 114 for Licensed Providers, in five named stages beginning with well participants	Unchanged from July 23: "a minimum of 100 hours of supervised practice training for facilitators and 120 hours for practitioners", built from 80 administration-day hours and 20 preparation-and-integration hours, the practitioner's 20 supervision hours inside the 120. No well-participants stage; the department stated on August 21 that the statute does not allow practicum work with individuals who do not have a qualifying condition. The first 20 hours are with patients "determined by the supervising practitioner to be low-risk for adverse events or other complications". 7.35.3.19 (A), pp.13-14
The competency checkpoint #	An 18-hour case presentation and consultation group with program faculty, two cases, before full licensure	No consultation group and no dedicated hours. The text: "the student shall present a minimum of two of the last four patients to the practicum supervisor as case presentations for evaluation, and must receive a passing grade on the case presentations to complete their practicum". 7.35.3.19 (C), p.14
After the practicum #	Nothing further required	"a minimum of 10 hours of mentoring sessions after graduation and after practicum hours are completed", program-provided at no added charge, valid 12 months. 7.35.3.17 (A), p.11
The role names #	Licensed Provider; medical screener proposed for the certifying clinician	Practitioner and certifying clinician, defined in the amended 7.35.2.7, the certifying clinician "certified by the department to diagnose or confirm a previous diagnosis of a qualifying condition"; neither proposed name appears in the published texts. The definitions are reproduced and annotated on the rule page. 7.35.2.7 as amended, pp.1-4
Where the two agree #	The New Mexico module for every role with no reciprocity exemption; the emergency response credential; continuing education at 8 and 20 hours every two years; and the December 31, 2027 transition at 40 contact hours.

Each row carries its own address: the # beside a row's name links straight to it, so one item can be cited in a message or a written comment. Quoted fragments are the published text's exact words, spacing artifacts of PDF extraction excepted. The two positions can be moved against each other on the working model of the hours. What each August 25 change asks of a person is noted at the provision on The published rule.

The pathway, in one picture

The three roles

CCThe certifying clinician performs medical screening and clearance: that the diagnosis exists and that psilocybin treatment is medically appropriate. The recommendation proposed renaming the role the medical screener; the August 25 text keeps certifying clinician, and defines it with the controlled-substance number inside the definition. Counseling-side readiness sits with the role below.

LPThe Licensed Provider, the recommendation's name for the role the published text calls the practitioner. The August 25 text keeps practitioner, defining it in the amended 7.35.2.7 as a certified clinician providing psilocybin integrative therapy. In the recommendation's terms: a professional holding a license to deliver medical, counseling, mental health, or behavioral health care.

FThe Facilitator supports patients through psilocybin sessions in a non-clinical role. All three roles are practitioners; the three names say what each one does.

The recommendation, by role

Requirement	Certifying clinician	Licensed Provider	Facilitator
Didactic hours	8	80	80
Staged practicum	none	114	102
Emergency response credential	not required	required	required
Continuing education, every two years	8 hrs CME	20 hrs CE	20 hrs CE

Hours figures throughout are minimums; hours earned simultaneously count once toward the total. The working model of the hours lets you move the quantities and see what changes for the person doing the training.

The didactic: 80 hours

MODULEA New Mexico module for every role, with no exemption by reciprocity, covering the Act, the medical and therapeutic model, social, cultural, and historical aspects of psilocybin use including traditional use by Native American and other populations in New Mexico, spiritual, existential, religious, and theological aspects, and the state research and data collection requirements, ending in a competency evaluation.

8The certifying clinician / medical screener completes a module of at least eight didactic hours: pharmacology and interactions, the role's responsibilities, 42 CFR Part 2, diagnosis of qualifying conditions, medical clearance, psychedelic emergencies and monitoring, and challenging experiences including hallucinogen persisting perception disorder.

80Licensed Providers and Facilitators complete at least 80 didactic hours, below Oregon's 120 and Colorado's 150; the recommendation states the calibration is deliberate, since graduates in both states report longer didactic requirements did not buy greater depth.

Content area	Minimum hours
Core psychotherapy skills and ethics, including patient-centered care, cultural competency, confidentiality, informed consent, self-care, somatic awareness and touch, and 42 CFR Part 2	22
End-of-life and palliative care considerations	8
Trauma and trauma-informed care	7
Preparation and integration sessions	6
Medicine, dosing, and clinical research, including psilocybin actions, interactions, and pharmacology	5
Screening, suicidality, and crisis response	5
Administration session, including set and setting, non-ordinary states of consciousness, and use of music	4
Management of challenging psychedelic experiences, including de-escalation techniques	4
Role playing and/or simulated patient experience	2
Total specified minimums	63

The remaining 17 hours go to the topics required without an hour minimum: an overview of Licensed Provider and Facilitator responsibilities, including care-team work and the non-clinical peer support facilitator role, and treatment models. The recommendation notes that the seven trauma hours are not PTSD treatment training and should not be represented as such; where PTSD treatment falls outside a provider's scope, collaboration with a PTSD-trained provider is the appropriate path.

The staged practicum: 102 or 114 supervised hours

Supervised practice is sequenced from lower-risk to higher-risk experience, and no one completes it without real client contact. Every hour is supervised, every stage spans preparation, administration, and integration, and hours earned simultaneously count once toward the total. All practicum hours take place in an approved healing center or other approved location.

Stage	Min. hours	Compensated	Medicine sessions	What it involves
1. Well participants	24	No	2	Participants without a qualifying or risk-heightening condition, completed before seeing patients with qualifying conditions.
2. Co-facilitation	24	No	2	Co-facilitated with a department-permitted Licensed Provider; low-acuity patients.
3. Group work	12	Yes	1	Group preparation, administration, and integration.
4. Provider supervisory hours	12	Yes	1	Licensed Provider track only: co-facilitating with a permitted facilitator for same-day therapy sessions.
5. Supervised practice with case consultation	42	Yes	2	24 hours with two clients designated by the hosting school or healing center, 12 hours each: an eight-hour medicine day, two preparation sessions, and two integration sessions. Both cases are presented within an 18-hour consultation group. May occur in the two years after the training license.
Total	102 / 114		8	Eight client medicine sessions in total, four of them before compensation may occur.

The facilitator total is 24 + 24 + 12 + 42 = 102; the Licensed Provider total adds the 12 supervisory hours for 114. Once a student completes 48 hours, the end of stage two, they are qualified to provide care to high-acuity patients when accompanied by a Licensed Provider: a graduated on-ramp that expands what a student can do as demonstrated experience accumulates.

Case presentation and consultation: the checkpoint

Every student participates in at least 18 hours of case presentation and consultation with educational program faculty, which programs may provide through a contracted third party. Each student presents at least two cases in which they personally provided direct psilocybin services: a full case conceptualization spanning concerns, risk factors, supportive factors, treatment considerations, and aftercare recommendations, completed before full licensure. The recommendation states its own rationale: rather than relying on raw hour counts, someone experienced evaluates the new provider's actual casework before independent practice. The 18 hours remain valid for up to 12 months after the practicum, and the model mirrors the consultation structure developed at Memoru in Boulder.

Also in the recommendation

CPRBefore applying, Licensed Providers and Facilitators hold current emergency response credentials: basic life support, CPR and AED certification, New Mexico EMT licensure, or a clinical license that includes these competencies.

CECertification is not the end of training: at least eight hours of continuing medical education every two years for the certifying clinician / medical screener, and at least 20 hours of continuing education specific to psychedelic therapy and practice for the other two roles, with emergency-response credentials kept current.

RECORDSEducational programs keep records at least five years: syllabi, enrollment, examinations and transcripts, the dates, locations, and patient counts of practicum sessions, and the facilitators each Licensed Provider student supervised.

2027A transition pathway: the department may waive, suspend, or reduce practicum requirements to recognize people trained by other government-approved programs, and applicants who complete their didactic requirements and graduate from a department-certified or approved program by December 31, 2027 may satisfy a reduced practicum of at least 40 documented contact hours.

Against Colorado

Stage	Colorado	New Mexico, recommended
Didactic	150	80
Practicum, including case presentation and consultation	40	114 LP · 102 facilitator
Consultation phase, no medicine sessions required	40	none separate
Psilocybin medicine sessions in training	2	8, 4 before compensation
Total hours	230	194 LP · 182 facilitator

This comparison is the recommendation's own: fewer total hours than Colorado, with more of them supervised practice on real clients and four times the medicine sessions.

How the recommendation evolved

JUL 17Dr. Anne Metz presented the structure to the committee: rename the permit, a single didactic standard, a staged practicum with a lawful path to client contact, and consultation sign-off tied to two presented cases.

JUL 27The summary of the recommended rules went to the department: 80 didactic hours, a staged practicum of 60 or 70 hours by role, and 20 hours of case presentation and consultation. It remains the committee's filing of record, and is not published on this site.

AUG 21The position above was presented at the committee meeting: the practicum at 102 or 114 hours with compensation and medicine-session rules, the consultation at 18 hours inside the total, and the nine content-area minimums stated. No vote was taken; the recommendation went forward to the department.

AUG 25The department published the revised proposed rules: the 80-hour didactic total taken without the per-area minimums, the staged practicum declined with the totals kept at 100 and 120, the two-case checkpoint taken as an evaluation inside the practicum, the mentoring kept, and the role renames declined.

Sources, and their limits

The recommendation is reported from the August 21 committee meeting: the document shown on screen and read aloud, captured live. The department's recording of the meeting, once posted, is the record; until then no recording or transcript is held on this site, an absence tracked in the gaps register. The July 27 summary of the recommended rules is cited by name and is not published on this site. What was said at the meeting, including the department's own presentation there, is on the record page.

What landed. The revised proposed rules published on August 25, and the section above states what they took, altered, and declined against this recommendation. The full provision-level comparison is in the repository's analysis, and the published text is typeset with its annotations on the rule page.

Provenance: the source document and this page’s revisions▸

The document this page is read from

August 25, 2026

Revised proposed ruleCurrent state of truth

The revised proposed rule, published August 25 with the notice fixing the October 2 hearing, superseding the set-aside July 23 text. Raised the practitioner and facilitator therapy module from 30 didactic hours to 65, at least one third in person, and the simulated patient requirement from 5 hours to 10. Added eleven curriculum topics without per-area hour minimums, a case-presentation evaluation inside the unchanged 100 and 120 practicum hours, a low-risk requirement on the first 20 administration-day hours, and a didactic waiver. Kept the role names certifying clinician and practitioner, defining them in amendments to 7.35.2.7 published the same day.

This document supersedes four earlier ones. Each of them, what it is, what superseded it and when, and a download, is in the register at Meetings and filings.

Revisions to this page

August 26, 2026 The against-the-published-text rows deepened to quote level: each row carries the published text's exact words and its own anchor, so a single item can be linked from a message or a written comment.
August 26, 2026 The comparison posture switched on: a section states what the August 25 text took, altered, and declined against the August 21 position, the status and evolution sections carry the outcome, and the roles state the published names beside the recommendation's proposed renames.
August 24, 2026 An accuracy pass corrected the Licensed Provider description: the name is the recommendation's, used by the department's presenter at the August 21 meeting while the department's own side-by-side kept practitioner.
August 24, 2026 Role vocabulary entered the site's own voice: the middle role is the Licensed Provider, the recommendation's name for the role the published text calls the practitioner, and the screening role is written certifying clinician / medical screener, the recommendation's proposed rename, still being pushed. Verbatim quotes and provision names keep the documents' own words.
August 24, 2026 Rebuilt as the recommendation, standing alone: the three roles, the by-role table, the pathway drawn as a diagram, the 80 didactic hours with the nine content-area minimums, the staged practicum table, the case presentation and consultation checkpoint, the emergency credentials, continuing education, records, and the 2027 transition, the recommendation's own Colorado comparison, and its history from July 17 through August 21. Nothing on the page is diffed against another text, because no proposed rule is currently published; what was said at the August 21 meeting, including the department's presentation there, stays on the record page. Sourced to the August 21 meeting, with the absence of its recording tracked in the gaps register.
August 21, 2026 The THEN line now states the schedule as restated: the department stated at the August 21 committee meeting that revised proposed rules publish August 25 and that the rule hearing, first set for August 28, is anticipated for October 2, with the final notice to fix the date.
July 28, 2026 The Case presentation and consultation row cited the published 10-hour figure to 7.35.3.19 (C), which carries the practitioner's separate 20 supervisory hours; the published counterpart of the recommended consultation requirement is the mentoring requirement, and the row now cites 7.35.3.17 (A), p. 10, verified against the published PDF. The page name is now the same in the title, the heading, and the menu: the committee recommendation.
July 28, 2026 One grouped menu on every page replaced the flat seven-item navigation, with the Documents dropdown at its right edge, and every stylesheet link now carries the style.css content hash so a page and its styles arrive from the same deploy.
July 27, 2026 Created in the July 27 redesign, and brought to the submission the same day: the summary of the recommended rules reached the department on July 27, and this page states its figures beside the published text, 80 didactic hours, a staged practicum of 60 or 70 hours by role, and 20 hours of case presentation and consultation on two cases, with the July 17 presentation kept as the basis. The document itself is not published on this site; every figure is stated here and named to its source.