Changed
New Mexico module scope
June 12 recommendation
the New Mexico Module outline lists "Patient flow", "Emergency response plans", "Billing/coding", "Informed consent (for psychedelics)", "Documentation requirements (registration/data collection)", and "HIPPA compliance" under "Overview of Psilocybin Therapy in New Mexico" (p. 2)
July 9 rules draft
"(2) An overview of the use of psilocybin in a therapeutic model in New Mexico" (p. 4)
The draft states the module as five numbered items in place of the recommendation's multi-level outline.
Changed
Medical Psilocybin Act education
June 12 recommendation
"Medical Psilocybin Act: why, how, timeline, state vs federal laws, risks, malpractice" (p. 2)
July 9 rules draft
"(1) Education on the New Mexico Medical Psilocybin Act" (p. 4)
Changed
Cultural and historical content
June 12 recommendation
"Non-Western/traditional medical models, language barriers, involvement of other professionals including religious leaders, death doulas, indigenous healers, curanderas, others; history of psilocybin and psychedelic use in New Mexico" (p. 2)
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)
Changed
SERT content
June 12 recommendation
"SERT: spiritual, existential, religious, theological concerns, existential processing" (p. 2)
July 9 rules draft
"(4) Spiritual, existential, religious, and theological (SERT) aspects of psilocybin therapy" (p. 4)
Changed
Module tests
June 12 recommendation
each module outline ends with "Test" (pp. 2, 3, 4, 5, 6, 7)
July 9 rules draft
each module list ends with "Evaluation to demonstrate competency in the above areas" (pp. 4, 5)
New in the draft
Certifying clinician module hour minimum
June 12 recommendation
no counterpart (topics listed without hour counts, pp. 2-3)
July 9 rules draft
"a certifying clinician module consisting of a minimum of 8 didactic hours prior to applying for certification" (p. 4)
Changed
Certifying clinician module topics
June 12 recommendation
"Psilocybin pharmacokinetics", "Overview of Responsibilities for Diagnosing Clinician", "Education on diagnosing qualifying conditions/medical clearance", "Medical Monitoring/Emergency Situations", "Research Evaluation" (pp. 2-3)
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)
New in the draft
42 CFR Part 2 training
June 12 recommendation
no counterpart
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)
Not carried over
Benefit vs risk evaluation
June 12 recommendation
"Benefit vs risk evaluation" under education on diagnosing qualifying conditions (p. 2)
July 9 rules draft
no counterpart
Changed
Medication evaluation and interactions
June 12 recommendation
"Psilocin Medication/ Supplement Interactions" and "Medication evaluation/monitoring" (p. 2)
July 9 rules draft
"(1) Psilocybin action, interactions, and pharmacology" (p. 4)
"Medication evaluation/monitoring" has no separate item in the draft list.
New in the draft
Practitioner and facilitator core module hour minimum
June 12 recommendation
no counterpart (modules listed without hour counts, pp. 3-5)
July 9 rules draft
"a psilocybin therapy module consisting of a minimum of 25 didactic hours, prior to applying for certification" (p. 4)
Changed
Practitioner and facilitator core module structure
June 12 recommendation
separate module outlines for practitioners (pp. 3-5) and facilitators (pp. 5-7), each containing a "Basic Module", a "Psilocybin Therapeutic Module", and a "Set and Setting Module", each ending in "Test"
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)
Changed
Simulated patient requirement
June 12 recommendation
"Simulated Patient Module (including evaluation)" (pp. 5, 7)
July 9 rules draft
"(13) A simulated patient experience of no less than 5 hours in addition to the 25 didactic hours" (p. 4)
Changed
Research evaluation topics
June 12 recommendation
"Finding research on psilocybin", "Reading research on psilocybin", "Review of current research occurring" (pp. 4, 6)
July 9 rules draft
"(12) Research and data collection requirements" (p. 4)
Not carried over
Detailed therapeutic subtopics from the recommendation modules
June 12 recommendation
the following listed items have no matching phrase in the draft module lists: "Trauma Informed Care" (pp. 4, 5), "Touch (Supportive Touch/consent)" (p. 4), "Non-directive approach" (p. 4), "Power dynamics, including personal bias" (p. 4), "Cultural and spiritual humility" (p. 4), "Patient autonomy" (p. 4), "Group Treatment Modalities and Group Dynamics" (p. 4), "History of psilocybin use" (p. 4), "Audit of records (how it occurs)" (p. 3), "Transportation- to and from and ensure safety" (p. 4)
July 9 rules draft
no counterpart phrases in the 25-hour module list (p. 4)
Changed
Facilitator-specific module
June 12 recommendation
the facilitator outline includes "Overview of therapeutic practices (ie, a 101-type overview)" with "Ethics", "Confidentiality", and "Therapeutic Modalities", and "Responsibilities in focusing on patients" (pp. 5-6)
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)
The draft list numbers two consecutive items "(3)" (p. 5).
Changed
Practitioner-specific module
June 12 recommendation
the practitioner "Psilocybin Therapeutic Module" includes "Models of psilocybin treatment" and "Non-Ordinary States of Consciousness" (p. 4)
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)
Changed
BLS, CPR, first aid, and HIPAA certifications
June 12 recommendation
"Basic Life Support Certification (BLS)", "CPR", "Basic First Aid certification", and "HIPAA Certification" listed inside the basic modules (pp. 3, 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)
"Basic First Aid certification" has no counterpart in the draft training list; AED certification appears only in the draft.
Changed
Wilderness first aid and wilderness first responder certification
June 12 recommendation
"For those conducting sessions in natural environments: Wilderness First Aid certification; or, Wilderness First Responder certification" as a practitioner and facilitator training requirement (pp. 3, 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)
Carried over unchanged
Continuing education for certifying clinicians
June 12 recommendation
"a minimum of eight (8) hours of continuing medical education credits specific to psychedelic medicine or therapy every two years" (p. 9)
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)
Carried over unchanged
Continuing education for practitioners and facilitators (20 hours)
June 12 recommendation
"a minimum of twenty (20) hours of continuing education credits specified to psychedelic therapy and practice every two years" (p. 9)
July 9 rules draft
"a minimum of 20 hours of continuing education credits specific to psychedelic therapy and practice every two years" (p. 5)
The recommendation reads "specified to"; the draft reads "specific to".
Changed
Certification upkeep alongside continuing education
June 12 recommendation
"Keep current Basic Life Support Certification (BLS)/CPR/Basic First Aid in addition to the 20 hours of CEUs" (p. 9)
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)
Not carried over
Annual training requirement for diagnostic clinicians
June 12 recommendation
"Complete required NMDOH training and continuing educational training requirements annually" (p. 1)
July 9 rules draft
no counterpart using "annually"; the draft states continuing education intervals as "every 2 years" (p. 5)