New Mexico Medical Psilocybin Program · Advisory Board
Updated August 24, 2026.
On July 17 the Advisory Board voted 7-0 to defer the didactic and practicum hours to the Training and Education Committee. On July 23 the department published its proposed rule with the practicum hours unchanged; that publication and its August 28 hearing were later set aside. The committee's recommendation was submitted on July 27 and refined at the August 21 committee meeting to 80 didactic hours and a staged practicum of 114 or 102 hours by role; the recommendation page holds it in full. On August 25 the department published the revised proposed rule: the therapy module doubled to 65 didactic hours with 10 simulated patient hours, the practicum unchanged at 100 and 120 hours with a case-presentation evaluation added inside them. The rule hearing is October 2, fixed by notice. The figures below are from the August 25 published text. The current state of the rulemaking is on Where things stand.
Certifying clinician
Diagnoses, authorizes entry; holds a NM controlled-substance number
Practitioner the recommendation proposes renaming the role the Licensed Provider
Licensed therapist role; supervises facilitators
Facilitator
Guides sessions; no prescribing, no license required for this role
All figures from the revised proposed rule of August 25: didactic and continuing education, 7.35.3.18, pp.11–13; practicum, 7.35.3.19, pp.13–14. The practicum figure for practitioners includes the 20 supervisory hours in 7.35.3.19 (D). Practitioners and facilitators must also hold current BLS, or CPR and AED, or New Mexico EMT licensure, plus HIPAA certification within the preceding two years.
What changed on August 25
Both figures were covered by the July 17 deferral vote. Comparison: July 23 published p.11 against August 25 published p.12.
2 · The August 21 committee record Record
The committee met on August 21, reviewed its subcommittee’s refined proposal beside the department’s own, and took no vote; the chair held one off deliberately with the proposals close and the department’s stated publication date four days out. The refined position, 80 didactic hours with minimums in nine content areas and a staged practicum of 114 or 102 hours by role closing in case presentation and consultation, is stated in full on the recommendation page. No recording or transcript of the meeting is held on this site yet; the absence is tracked in the gaps register, and the working extraction is in the repository behind this site.
What the meeting settled, and what it left open
Both proposals set 80 classroom hours in place of the published 40, and their totals land within twenty hours of each other; the difference is structure. Whether per-area hour minimums belong in the rule or in guidance documents the rule points to was argued and left unresolved: the department recommends content areas without per-area hours, the subcommittee’s authors argued minimums are the objective criteria that let the department approve or reject a program. The department stated that the statute does not allow practicum work with people who lack a qualifying condition, which is why its structure carries no well-participants stage; that its proposal permits trainee compensation after 50 practicum hours; and that its 10 post-graduation mentorship hours are an obligation on programs, optional for the graduate. The schedule was restated: revised rules on August 25, and the rule hearing, whose first setting of August 28 was set aside with the July 23 publication, anticipated for October 2. The next committee meeting was set for September 4, 9 to 11 AM.
3 · The July 17 committee record Record
The Training and Education Committee met on the afternoon of July 17, after the morning board meeting that deferred these hours to it. This is what was presented. The department published its proposed rule six days later. Full transcript: July 17 committee meeting, unofficial and not speaker-attributed.
Presentation · Dr. Anne Metz, clinical facilitator (Fluence programs, Oregon and Colorado; consulted on national certification standards; states no conflicts of interest in New Mexico)
Metz offered general recommendations, not a finalized plan, drawn from the committee’s June 12 and June 25 drafts, the Healing Advocacy Fund’s qualitative analysis of Colorado training (interviews with 24 operators, graduates, indigenous scholars, and legacy practitioners), a comparison of Oregon’s 120 and Colorado’s 150 training hours, and the Memoru consultation model in Boulder. She framed the task as calibration: rigorous enough to be defensible to the public and the legislature, lean enough to stay accessible, because every required hour is a real cost. She estimated a 120-hour practicum costs a licensed clinician roughly $18,000 to $24,000 in lost revenue, before tuition, supervision, and travel, and said that burden lands on the clinicians the program most wants and eventually on patients.
Four recommendations
Open questions she raised
From the July 17 Training and Education Committee meeting. Attributed to Dr. Anne Metz. Her written recommendations, the one-page summary, and the slides are on the documents page.
What the committee was told about timing
Asked whether an informal working group needed a formal structure, Dominic Zurlo told the committee the department was moving forward with a proposed rule and that input was needed quickly: "the sooner if there are specific topics to include in or suggestions as far as hours, we really need them sooner rather than later." No deadline was given. The hearing was described as "about six weeks from now." The committee set its next meeting for August 21, which fell after the July 23 publication and seven days before the hearing as first set for August 28; that publication and hearing were later set aside.
July 17 Training and Education Committee meeting.
Other requests made on the record
July 17 Training and Education Committee meeting.
1
The published rule sets hours by role: 8 didactic hours for the certifying clinician with no practicum, and 70 didactic hours plus a 10-hour simulated-patient experience, plus 100 to 120 practicum hours for facilitators and practitioners. The 70 is a 65-hour shared module, at least one third of it in person, plus a 5-hour role module. A New Mexico module is also required of everyone, including reciprocal applicants, and no hour count is stated for it anywhere in the rule.
Inside the practicum: at least 80 hours in administration day sessions, at least 14 different patients across at least 8 different sessions, the first 20 hours with low-risk patients, plus at least 20 hours of preparation and integration. Practitioners add 20 supervisory hours. The student must pass case presentations on two of their last four patients to complete the practicum. All hours take place in an approved healing center or other approved location. The practicum may not begin until at least half the didactic requirements and all the simulated patient requirements are complete. Source: 7.35.3.19, pp.13–14.
The 100/120 practicum figure originated in the June 12 committee recommendation and has carried unchanged through every draft since, including the July 23 and August 25 publications, despite the Advisory Board voting 7-0 on July 17 to send it back to committee. The shared didactic module has been raised twice while deferred: from 25 hours to 30 on July 23, and from 30 to 65 on August 25. Sources: published rule, pp.11–14; origin, June 12 recommendation, pp.7–9; July 17 board transcript.
4
The practicum figure binds almost entirely on new in-state facilitators and practitioners. Certifying clinicians owe no practicum, and three clauses already in the draft cut the practicum to 40 contact hours or waive it for everyone else.
| Clause | Where it lives | What it does |
|---|---|---|
| Discretionary waivers | 7.35.3.19 (G), 7.35.3.18 (H) p.14, p.13 |
The department "may otherwise waive, temporarily suspend, or reduce the practicum requirements" to certify enough providers to build the program. Discretionary, no deadline. Lettered (F) in the July 23 text; the August 25 text adds a matching discretion over the didactic requirements at 7.35.3.18 (H). |
| In-state bridge | 7.35.3.19 (H) p.14 |
Applicants who apply by December 31, 2027, complete the didactic by that date, and graduate from a program the department certifies or lists by that date, demonstrate 40 contact hours instead of the full practicum. The rule states this as four explicit conditions, and requires two individual sessions and one group session. Source: 7.35.3.19 (H), p.14, lettered (G) in the July 23 text. The July 9 draft read June 30, 2027; every publication since carries the December 31, 2027 date the board set on July 9. |
| Reciprocity waiver | 7.35.3.10 (D) p.5 |
Out-of-state applicants applying by December 31, 2027 show 40 contact hours; the department may further reduce reciprocity practicum. This waiver requires two individual and two group sessions, one more group session than the in-state bridge asks for, a disagreement unchanged in the August 25 text. Reciprocity is no longer a standalone section; it sits inside the out-of-jurisdiction application process. Source: 7.35.3.10 (D), p.5. Chair Ian Dunn described December 31 on July 9 as a legislative backstop, not a target date. |
Which providers land in which route is set on Which licenses qualify and Routes to a permit. In short: the certifying clinician (a prescriber-eligible license, holding the controlled-substance number) owes 8 didactic hours and no practicum; the practitioner and facilitator owe the full stack; a reciprocity or bridge applicant owes 40 contact hours. Source: 7.35.3.19, pp.13–14 and 7.35.3.10, p.4.
For the first years, most providers can reach certification through a 40-contact-hour path or a discretionary reduction. The full 100 / 120 binds new in-state trainees after December 31, 2027. This describes the clauses in the published rule, not a position on them.
5
New Mexico proposes the least didactic and the most practicum of the operating comparators. Oregon and Colorado license people with no prior credential; the closest analog to New Mexico's already-licensed providers is the former buprenorphine waiver, at 24 hours.
| Program | Didactic | Practicum | Consult / mentor | Applies to | Source |
|---|---|---|---|---|---|
| New Mexico published August 25 | 70 hrs + 10 hr sim. | 100 / 120 hrs | 10 hrs mentoring | New Facilitators & Practitioners; already NM-licensed | 7.35.3.18–.19, pp.11–14 |
| Oregon Psilocybin Services | 120 hrs | 40 hrs | none | Facilitators; no prior license or degree | OAR 333-333 |
| Colorado Natural Medicine | 150 hrs | 40 hrs | 50 hrs consultation | Facilitators; no prior license | 4 CCR 755-1-3 |
| CIIS certificate private, not a state license | 140–150 hrs | none built in | ~30 hrs mentor | Already-credentialed clinicians / clergy | CIIS |
| Buprenorphine waiver former DATA-2000, ended 2023 | 24 hrs (NP/PA) 8 hrs (MD) |
none | none | Licensed prescribers, to add one authority | SAMHSA |
Oregon and Colorado train unlicensed people, so their large classroom load covers what New Mexico assumes a licensee already holds. Keenan Ryan named the buprenorphine waiver, 24 hours for already-licensed prescribers, as the nearest match to New Mexico's population. Sources verified against each rule; see the Sources block.
6
No New Mexico cost analysis has been done. Larry Leeman asked for one before any number is set. This section holds the variables and the out-of-state reference prices; the New Mexico totals are open research.
What drives the cost
Reference prices that exist (Oregon and Colorado market, not New Mexico projections)
Cost per pathway (pathways from Which licenses qualify). Totals are blank because the New Mexico research is not done.
New in-state facilitator
Full didactic + full practicum
New in-state practitioner
Adds 20 supervisory hours
Reciprocity / out of state
Practicum cut to 40 contact hours
Discretionary waiver / in-state bridge
Practicum reduced or waived
Research inputs still needed: what a New Mexico healing center charges a trainee for session access, whether trainees may practice on one another, real tuition once programs are approved, and how many providers the state needs. These are the numbers to gather, not assumptions to insert here.
A central cost variable is who the novice practices on. The 80 practicum hours are real administration sessions. Leeman said a novice should not do those on patients with the four qualifying conditions, and that in other programs they happen with other trainees. Dosing a healthy trainee is not clearly authorized by the Medical Psilocybin Act, so that route depends on a fix-it bill, which Ian Dunn noted is not expected before January. Until then the discretionary waiver at 7.35.3.19 (F) and the 40-hour bridge are the tools that exist.
7
Five questions were left open at the July 9 board meeting. Each is recorded below with the positions stated, attributed to the members who stated them. None was resolved by the committee before the department published on July 23; the August 25 revision answered the didactic question in the text, raising the shared module to 65 hours with 10 simulated patient hours, and left the practicum figures standing.
Is ~35 didactic hours enough?
Leeman: no, below any program he has seen; more practicum does not remove the need for more didactic.
Ryan: the closest benchmark is the buprenorphine waiver, 24 hours for already-licensed providers.
Burgard: maybe a little higher than 25; these are already-licensed professionals, so it need not go far.
quotes →Raise the didactic, or cut the practicum?
Peskuski: do not lower practicum without raising didactic; both are inadequate as they stand.
Jennings: settle both with a definite number, not "I feel it should be more."
quotes →Who does a novice practice on?
"Practicum in general does not happen with people that have the diagnoses in our program... They happen with people who are other trainees."
He would require two sessions, as Colorado does, and revise the draft so a trainee is eventually the supervised provider, not only an observer.
full quote →A legislative fix, or the waivers
Dosing a healthy trainee is not clearly allowed by the Act, so training on trainees needs a fix-it bill. Dunn: the law is not expected to change before January.
Until then the published text's discretionary waiver, 7.35.3.19 (F), and the 40-hour bridge are the existing tools. See the three clauses.
What will it cost?
Leeman: run a cost analysis before adding anything; the cheapest Colorado trainee session he found was about $200. The frame is in section 6; the New Mexico numbers are not filled.
quotes →Who should set the number?
Leeman: seat it after expert testimony, as the end-of-life committee did; bring in people with experience and no commercial conflict. He named the California Institute of Integral Studies. This step the committee controls, with no legislative dependency.
quotes →Community and public input
Community input form · July 17, 2026
"The 35 hour didactic requirement seems insufficient. I hope there will be more time for a thoughtful discussion and a rationale before the number of didactic hours is set. An official training and education committee intercession work group would be helpful in pulling together all of the different ideas that have been discussed informally. Then a clear recommendation could be brought to the advisory board."
On the didactic hour requirement, from Kate Hawke.
Public comment read into the July 17 committee meeting · submitted on her behalf
On what should define a credible facilitator training program, Amy Wong-Hope offered four points and a framing on safety:
"Safety is not merely a protocol surrounding the intervention. Safety is an essential ingredient in the intervention itself."
Public comment, from Amy Wong-Hope.
Thank you for the opportunity to offer my perspective on what should define a credible psilocybin facilitator training program.
First, the curriculum must be clinically and trauma informed. Facilitators need sufficient knowledge of trauma, dissociation, psychiatric risk, grief, medical concerns, substance use, and the populations they may serve, including people experiencing depression, PTSD, substance-use concerns, serious illness, and end-of-life distress. They must be able to recognize complexity and individual vulnerability, understand the limits of their scope, and know when to consult, refer, pause, or decline to proceed.
Second, ethics must be woven throughout the program, not confined to a single module. Students should repeatedly engage with consent, power, touch, boundaries, dual relationships, cultural humility, conflicts of interest, and heightened suggestibility. Ethical competence means being able to perceive risk, tolerate uncertainty, seek consultation, receive feedback, and repair harm. It is an ongoing practice.
Third, programs need a meaningful practicum. Students should be observed practicing preparation, screening, difficult conversations, boundary setting, crisis response, facilitation, and integration. Competence should be demonstrated through supervised experience, not assumed from attendance or written assignments. Periodic practicum-based competency review (at some regular interval?) could help facilitators keep these skills active.
Fourth, admissions and evaluation should assess interpersonal maturity, emotional regulation, self-awareness, self-reflective accountability, and the capacity to receive and integrate feedback. Facilitators should also participate in ongoing consultation or peer-consultation groups. These practices demonstrate readiness to hold responsibility for vulnerable people.
Ultimately, safety is not merely a protocol surrounding the intervention. Safety is an essential ingredient in the intervention itself. A strong program prepares facilitators to bring sound judgment, accountability, humility, and respect for the full personhood of every participant.
Community submissions and public comment, shared for consideration. Unverified; not this site’s position and not verified fact. Public comment is drawn from the July 17 meeting; form submissions are published only with the submitter’s consent, and email is never published. Add your own input.
Verbatim from the unofficial July 9 transcript, speakers inferred. Linked from the questions above.
Keenan Ryan · Acting CMO, Medicaid (covering designee)
"If you look at the previous X waiver, they've required already licensed professionals in the field, so nurse practitioners, physicians assistants, etc., so similar to what you have here, to receive 24 hours of training just for this one specific agent and so I'll just put that there for you guys to make your own decision on, but I think that's probably your best benchmark that I can think of..."
Larry Leeman · board member, UNM
"I don't think 25 hours didactic is adequate for the, for the practitioners if they haven't had evidence of other training... It's well below like with any program in the world that I have seen is like... And I think by adding more practicum, we don't obviate the need for more of the didactic."
Chris Peskuski · board member
"I don't think we can separate these issues. If we lower the practicum hours without balancing it with the didactic somewhere, and I feel like those are woefully inadequate to begin with. All of this is connected, and there's accessibility issues that also come up with how many patients are actually going to be available for people to do practicums."
Dan Jennings · board member
"I'm going to echo Dr. Leeman and Chris on this. I think that it does make sense to go back to the committee, but for both the didactic and the practicum... And I think there needs to be a definitive consensus to the number of hours. But because I think we just get into this and go, I feel it should be more, I feel it should be less."
Larry Leeman · board member, UNM
"Practicum in general does not happen with people that have the diagnoses in our program... They happen with people who are other trainees. I think that's really appropriate. It's safe. It's probably less stress for everyone. And so I'm strongly in favor of a fix-it bill that actually allows for the training using psilocybin for trainees... I would suggest that people are required to have two of those sessions that would reflect what Colorado does... the way it's written you don't actually have to be doing anything it says you can just be observing... I'd like to see it revised that say that you can start out observing, but you actually have to be being observed and being, you know, supervised... And I think really for the whole program, we need to look at some cost analysis. When the people do the practice in Colorado, the cheapest I've seen is it's costing, $200 and that's for people sitting for two sessions and having one... We shouldn't be adding anything without figuring out how much it's going to cost."
Brenda Burgard · board member
"I agree that we should have more practicum hours than less didactic. That, yeah, experience, knowing how to do all of this is crucial to everything here."
Ian Dunn · board chair
"So I'm currently on the fence about more practicum or didactic. Only on the grounds that these are already licensed professionals that can provide a lot of aspects of therapy... So I do support that maybe it should be a little higher than 25. I just don't think it needs to go crazy."
The transcript's inferred labels run this passage under Brenda Burgard; the chair's handoff "And Ian." inside it places these sentences with the next speaker called, board chair Ian Dunn.
Larry Leeman · board member, UNM
"I would also suggest an approach to be used that we use an end of life committee, which is to bring in several experts. And I think we could do that. We can invite someone from California Institute of Integral Studies... let's bring in some people that have experience and ideally don't have, you know, any kind of a commercial conflict in their form."
Department presentation · Dominic Zurlo
"We are hearing from a wide variety of different people, some who have said we actually should have more like 200 or 300 hours, and others who are saying this should be very minimal, for example, just a weekend on it... We do have Section G, which is a waiver of practicum requirements, so that if we found that some of these practicum requirements were onerous or too expensive or any of those, the program could actually waive them... if we have to make adjustments, we can, and we can do that as a reduction without having to go back through the rulemaking process at that point."
The July 16 End-of-Life Care committee treated hours toward a specialization as an addendum on top of the core totals, not folded into them. The proposed range, the nine-session end-of-life curriculum presented that day, and the questions left open for the training committee are all recorded there, against the same core figures as section 1 above, now at their August 25 values.
Specialization hours, the session outline, and what was left open →
Source: End-of-Life Care committee meeting, July 16, 2026. Core figures as published: published rule pp.11–14.