New Mexico Medical Psilocybin Program · Advisory Board

The rules draft, section by section

Updated July 25, 2026. The current text is the July 23 published proposed rule. This page is layered: what the training and education rules say now is first, then the full section-by-section comparison of the June 12 recommendation against the July 9 draft that preceded it.

Every provision of the training and education rules, and where each one came from. The July 23 published proposed rule is the current text and the one going to the August 28 hearing. The document chain, and what each version superseded, is in the provenance block at the foot of this page.

Current text · July 23

The training and education provisions, as published

These are the provisions the Advisory Board deferred to the Training and Education Committee on July 17, plus the sections they depend on. Every figure is from the published proposed rule. The full provision-level worksheet, including what is broken in the published text, is on Practicum requirements.

ProvisionPublished July 23Change from July 9
Shared didactic module
7.35.3.18 (C), p.11
30 didactic hours plus 5 hours simulated patient Raised from 25. Three topics added: Trauma-Informed Care, Dosing, Non-ordinary states of consciousness. The required list grew from 14 items to 17.
Role modules
7.35.3.18 (D) and (E), p.12
5 hours facilitator-specific, 5 hours practitioner-specific Unchanged
Certifying clinician module
7.35.3.18 (B), p.11
8 didactic hours, no practicum Unchanged
New Mexico module
7.35.3.18 (A), p.11
Required of everyone including reciprocal applicants. Cannot be tested out of. No hour count is stated anywhere in the rule.
Practicum total
7.35.3.19 (A), pp.12-13
100 hours facilitators, 120 hours practitioners Unchanged. Deferred to the committee by a 7-0 board vote on July 17 and published six days later.
Inside the practicum
7.35.3.19 (A) and (B), pp.12-13
80 hours administration day sessions, 14 different patients across 8 sessions, plus 20 hours preparation and integration Unchanged in substance. "Same-day therapy" was scrubbed for "administration day" throughout, with one fragment left in 7.35.3.19 (A).
Practitioner supervisory hours
7.35.3.19 (C), p.13
20 hours supervising facilitators Unchanged
When the practicum may start
7.35.3.19 (A), p.12
Only after at least half the didactic requirements and all the simulated patient requirements are complete New. No equivalent in the July 9 draft, and it appears in neither July 17 transcript.
Mentoring
7.35.3.17 (A), p.10
10 hours after graduation and after the practicum, at no extra charge, valid 12 months Unchanged
Continuing education
7.35.3.18 (G), p.12
20 hours every 2 years for practitioners and facilitators; 8 CME hours for certifying clinicians Unchanged
In-state practicum waiver
7.35.3.19 (G), p.13
40 contact hours instead of the full practicum, for applicants who apply and complete the didactic by December 31, 2027 and graduate from a program certified or listed by then. Requires 2 individual and 1 group session. Deadline moved from June 30, 2027, and restructured into four explicit conditions. The session test changed from "or" to "and".
Out-of-jurisdiction waiver
7.35.3.10 (D), p.4
40 contact hours, applying by December 31, 2027. Requires 2 individual and 2 group sessions. Deadline moved from December 31, 2026. Reciprocity is no longer a standalone section. The two waivers now disagree on group sessions, one against two.
Students in the staffing ratio
7.35.3.20 (H)(5), p.14
One practitioner per 8 patients; one facilitator or qualified student per 2 patients. A qualified student has completed 50 practicum hours. New. Raised by Denali Wilson at the July 17 committee meeting and taken back by the department that day.

Every provision above remains open to public comment at the August 28 hearing. The practicum and didactic hours were deferred to the Training and Education Committee by a 7-0 board vote on July 17; that recommendation is in progress and had not reached the department before publication. The full record is on Training hours.

Where the rules came from

What the committee recommended, and what the department drafted

The earlier layer of the record, kept so the chain stays walkable. Every provision is grouped under the July 9 draft's own section headings and shows that draft's text side by side with the June 12 recommendation it came from, so you can see what was new, what changed, what carried over untouched, and what the recommendation had that did not make it in. Page numbers link into the source PDFs. For what the rules say now, see the section above.

New means it first appeared in the July 9 draft. Changed means the language moved from the recommendation. Carried over means it was unchanged from the recommendation. Not carried over means the recommendation had it and the July 9 draft did not. The count on each section header is a per-section breakdown of these four.

Preliminary sections (7.35.3.1 through 7.35.3.6) 1 1 1
New in the draft

Rules-format preliminary sections (issuing agency, scope, statutory authority, duration, effective date, objective)

June 12 recommendation

no counterpart

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)

Several later sections carry the citation line "[7.35.2.x NMAC - N, x/xx/2026]" although the part is numbered 7.35.3 (pp. 5, 6, 7).

Changed

Rename of "diagnostic clinician" to "certifying clinician"

June 12 recommendation

"Diagnostic Clinician: Qualifications required to certify patients for the medical psilocybin program" (p. 1)

July 9 rules draft

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

The draft's patient application section uses the phrase "certified Diagnosing Clinician" once (p. 10).

Not carried over

Definitions of "practitioner" and "facilitator"

June 12 recommendation

"Practitioner: means an individual who is a licensed healthcare professional who is certified by the department to provide medical psilocybin integrative therapy, supervise facilitators, supervise administrative sessions, supervise same-day therapy sessions, and who has completed department required trainings." (p. 1); "Facilitator: an individual who has completed training and education approved by the department to be able to assist practitioners during the administration sessions and who has been registered with the department." (p. 1)

July 9 rules draft

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

Application requirements for psilocybin educational programs (7.35.3.X) 6
New in the draft

Educational program application packet

June 12 recommendation

no counterpart

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)

New in the draft

Curriculum and syllabi submission with public posting

June 12 recommendation

no counterpart (the recommendation required programs to maintain "All course syllabi" as records, p. 8, but had no application or public-posting requirement)

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)

New in the draft

Two-year graduation plan

June 12 recommendation

no counterpart

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)

New in the draft

Third-party evaluation report with application

June 12 recommendation

no counterpart

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)

New in the draft

Practicum placement arrangements

June 12 recommendation

no counterpart

July 9 rules draft

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

New in the draft

Certified faculty requirement by June 30, 2027

June 12 recommendation

no counterpart

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)

Psilocybin educational programs; required reporting and curriculum approval; relinquishment of certificate (7.35.3.X) 5
New in the draft

Required reporting of program changes with prior department approval

June 12 recommendation

no counterpart

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)

New in the draft

Curriculum approval process, two-year validity, resubmission limits

June 12 recommendation

no counterpart

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)

New in the draft

Grounds for denying an educational program application

June 12 recommendation

no counterpart

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)

New in the draft

Educational program certification renewal window

June 12 recommendation

no counterpart

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)

New in the draft

Voluntary relinquishment of program certification

June 12 recommendation

no counterpart

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)

Psilocybin educational programs, healing centers, other approved locations; evaluation and assessment by the department (7.35.3.X) 3
New in the draft

Department assessments and inspections

June 12 recommendation

no counterpart

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)

New in the draft

Curriculum fidelity and record retention review during assessments

June 12 recommendation

no counterpart

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)

New in the draft

Revocation of certification after assessment

June 12 recommendation

no counterpart

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)

Requirements for third-party evaluators of educational programs (7.35.3.X) 3
New in the draft

Evaluation team composition and qualifications

June 12 recommendation

no counterpart

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)

New in the draft

Evaluator conflict-of-interest prohibitions

June 12 recommendation

no counterpart

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)

New in the draft

Evaluation report contents

June 12 recommendation

no counterpart

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)

Educational requirements for certifying clinicians, practitioners, and facilitators (7.35.3.X) 2 15 3 3
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)

Practitioner and facilitator practicum requirements (7.35.3.X) 4 3 2
Changed

Total practicum hours (100 facilitator, 120 practitioner)

June 12 recommendation

"must include a minimum of one hundred (100) hours of supervised practice training for Facilitators and one hundred and twenty (120) hours for Practitioners" (p. 7)

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)

Hour totals are identical; the draft adds the clause requiring completion before applying for certification.

Carried over unchanged

80 hours of administration and same-day therapy sessions (14 patients, 8 sessions)

June 12 recommendation

"a minimum of eighty (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 fourteen (14) different patients over a minimum of 8 different administration and same-day therapy sessions" (p. 7)

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)

Carried over unchanged

Individual and group administration session mix

June 12 recommendation

"A minimum of six (6) different patients during a minimum of six (6) individual administration and same-day therapy sessions; and, A minimum of two (2) different group administration and same-day therapy sessions with four (4) or more patients in each group" (p. 7)

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)

Carried over unchanged

20 hours of preparation and post-integration therapy sessions

June 12 recommendation

"a minimum of twenty (20) hours of in-person preparation and post-integration therapy sessions ... a minimum of six (6) different patients during individual sessions ... at least one (1) group preparatory and one (1) group post-integration session with a minimum of four (4) or more patients" (p. 7)

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)

Carried over unchanged

Practitioner supervisory hours (additional 20 hours)

June 12 recommendation

"Practitioners must complete an additional minimum of twenty (20) hours as a practitioner supervising facilitators during in-person administration and same-day therapy sessions." with "A minimum of two (2) different patients" individually and "A minimum of one (1) group administration and same-day therapy sessions with a minimum of four (4) or more patients" (pp. 7-8)

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)

Changed

Practicum location

June 12 recommendation

"All practicum hours must take place in an approved Healing Center." (p. 8)

July 9 rules draft

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

Changed

Practicum standards

June 12 recommendation

"Practicum supervisors and students shall follow all rules and best practices that apply to facilitation including but not limited to standards for confidentiality and limits on scope of practice." (p. 8)

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)

The draft text reads "Hi-TEC" as extracted; verify the spelling against PDF page 5.

New in the draft

Department waiver of practicum requirements (subsection G)

June 12 recommendation

no counterpart

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)

The section's subsections are lettered A, B, C, D, E, G, H; there is no subsection F.

New in the draft

Waiver of practicum hours for applications received by June 30, 2027 (subsection H)

Deadline moved 7/9

June 12 recommendation

no counterpart

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)

At the July 9 meeting, the board moved this waiver deadline from June 30, 2027 to December 31, 2027. Board chair Ian Dunn noted December 31 is a legislative backstop, not the target date. The draft text above, showing June 30, 2027, predates that decision. (Transcript, July 9 meeting)

Educational programs; mentoring requirements; record-keeping (7.35.3.X) 3 3
Carried over unchanged

10 hours of post-graduation mentoring at no added charge

June 12 recommendation

"All educational programs must provide each practitioner and facilitator student with 10 hours minimum of mentoring sessions after graduation and practicum hours are completed." and "These sessions may not have additional charges beyond the cost of the educational program itself." (p. 8)

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)

For extra hours, the recommendation reads "If students wish for more than 10 hours" (p. 8) and the draft reads "If students require for more than 10 hours" (p. 6).

Changed

12-month validity of mentoring hours

June 12 recommendation

"These 10 hours are only valid for up to 12 months after graduation and practicum hours are completed." (p. 8)

July 9 rules draft

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

The draft omits "graduation and" from the start of the 12-month period.

Carried over unchanged

Record retention list and five-year period

June 12 recommendation

records for "All course syllabi" and enrollment records including "Name of each student", "Date of start and completion for each student", "Examination results for each student", "Dates, locations, and number of patients seen during each of the practicum sessions"; "These records must be maintained for five years." (p. 8)

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)

Changed

Recording facilitators supervised by practitioner students

June 12 recommendation

"For Practitioner students, the facilitators they supervise during practicum also needs to be recorded." (p. 8)

July 9 rules draft

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

Carried over unchanged

Certificate upload and providing records on request

June 12 recommendation

"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. 8)

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)

Changed

Consent and confidentiality of records

June 12 recommendation

"Ensure consent and confidentiality" (p. 8)

July 9 rules draft

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

Reciprocity for certifying clinicians, practitioners and facilitators (7.35.3.X) 6
New in the draft

Reciprocal certification pathway

June 12 recommendation

no counterpart (the June 12 recommendation contains no reciprocity section)

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)

New in the draft

Partial practicum credit and New Mexico supervisory hours for reciprocal applicants

June 12 recommendation

no counterpart

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)

New in the draft

Waiver of practicum hours for reciprocity applications received by December 31, 2026

Deadline moved 7/9

June 12 recommendation

no counterpart

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)

At the July 9 meeting, reciprocity was resolved without objection and the board moved this waiver deadline from December 31, 2026 to December 31, 2027, the same date agreed for the subsection H practicum waiver. Board chair Ian Dunn noted December 31 is a legislative backstop, not the target date. The draft text above, showing December 31, 2026, predates that decision. (Transcript, July 9 meeting)

New in the draft

Department waiver of practicum requirements for reciprocity applicants

June 12 recommendation

no counterpart

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)

New in the draft

Recognition of other governments' programs, including Oregon and Colorado

June 12 recommendation

no counterpart

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)

New in the draft

Two-year approval of reciprocal educational programs

June 12 recommendation

no counterpart

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)

Testing out of the didactic portion of the required curriculum 2
New in the draft

Test-out option and price cap

June 12 recommendation

no counterpart (the June 12 recommendation contains no testing-out section)

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)

New in the draft

Test-out completion and retake rules

June 12 recommendation

no counterpart

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)

Certifying clinician, practitioner, and facilitator prohibition 2
New in the draft

Family relationship prohibition

June 12 recommendation

no counterpart

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)

New in the draft

Ownership interest prohibition

June 12 recommendation

no counterpart

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)

Application process (general) 5
New in the draft

Electronic application, two-year approval, resubmission limits, appeal

June 12 recommendation

no counterpart

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)

New in the draft

Grounds for denial of an individual application

June 12 recommendation

no counterpart

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)

New in the draft

Certification renewal window for individuals

June 12 recommendation

no counterpart

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)

New in the draft

Voluntary relinquishment by certificants

June 12 recommendation

no counterpart

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)

New in the draft

Public listing of certificant contact information

June 12 recommendation

no counterpart

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)

Certifying clinician application requirements 3 1
Changed

Professional license

June 12 recommendation

"Have a current and valid license from a recognized New Mexico licensing board which allows diagnosing the qualifying medical condition within their licensure scope of practice (as outlined by their governing licensure Board)" (p. 1)

July 9 rules draft

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

Changed

Controlled substance number

June 12 recommendation

"Have a New Mexico Controlled Substance number" (p. 1)

July 9 rules draft

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

The draft phrase reads "verification of results" as extracted; verify against PDF page 8.

Changed

Training completion and program status terminology

June 12 recommendation

"Complete required NMDOH training and continuing educational training requirements annually; and, Apply, receive, and maintain a valid permit from the NMDOH medical psilocybin program as a diagnostic clinician." (p. 1)

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)

The recommendation uses "permit"; the draft uses "certification" and "certificant".

New in the draft

W-9, test-out documentation, sex offender attestation, personal data

June 12 recommendation

no counterpart

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)

Practitioner application requirements 1 1
Changed

Professional license scope

June 12 recommendation

"Have 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)" (p. 1)

July 9 rules draft

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

New in the draft

Practitioner application documentation items

June 12 recommendation

no counterpart (the recommendation listed only training completion and "Apply, receive, and maintain a valid permit from the NMDOH medical psilocybin program as a practitioner", p. 1)

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)

Facilitator application requirements 1
Changed

Facilitator application documentation items

June 12 recommendation

"Complete required NMDOH training and continuing educational training requirements; and, Apply, receive, and maintain a valid permit from the NMDOH medical psilocybin program as a facilitator." (pp. 1-2)

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)

Neither document requires a professional license for facilitators.

Reciprocal practitioner or facilitator application requirements 1
New in the draft

Reciprocal application packet

June 12 recommendation

no counterpart

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)

Patient application and record 4
New in the draft

Patient application packet

June 12 recommendation

no counterpart

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)

This section uses "Diagnosing Clinician" while the rest of the draft uses "certifying clinician".

New in the draft

Electronic recording of patient services

June 12 recommendation

no counterpart

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)

New in the draft

Clinician-patient relationship and telemedicine limit

June 12 recommendation

no counterpart

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)

New in the draft

Grounds for prohibiting a clinician from certifying patients

June 12 recommendation

no counterpart

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)

Denial of an initial patient application; record review (7.34.3.x) 1
New in the draft

Administrative review of denied patient applications

June 12 recommendation

no counterpart

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)

The heading is numbered "7.34.3.x" in the extraction while the part is 7.35.3.

Prohibitions, restrictions and limitations on the use of psilocybin by qualified patients (7.35.3.x) 1 1
New in the draft

Patient use prohibitions

June 12 recommendation

no counterpart

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)

Extraction unclear

First listed prohibition item

June 12 recommendation

no counterpart

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)

As extracted, this item lacks a liability phrase such as "criminal prosecution for", and the section contains two subsections lettered B.

Marked unclear in extraction: extraction unclear, verify against PDF page 11

Application requirements for healing centers (7.35.3.X) 2
New in the draft

Healing center application packet

June 12 recommendation

no counterpart (the June 12 recommendation contains no healing center provisions beyond the practicum location sentence, p. 8)

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)

New in the draft

Outdoor administration session requirements

June 12 recommendation

no counterpart (the recommendation referenced natural environments only as a training trigger for wilderness certifications, pp. 3, 5)

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)

Other approved location requirements (7.35.3.X) 1
New in the draft

Other approved locations (patient residence)

June 12 recommendation

no counterpart

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)

General requirements for healing centers and other approved locations 3
New in the draft

Firearms prohibition at healing centers

June 12 recommendation

no counterpart

July 9 rules draft

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

New in the draft

Consumption location and presence during treatment

June 12 recommendation

no counterpart

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)

New in the draft

Daily log, product sourcing, and posting requirements

June 12 recommendation

no counterpart

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)

Service center safety and emergency plan 1
New in the draft

Safety and emergency plan contents and 48-hour incident report

June 12 recommendation

no counterpart (the recommendation listed "Emergency response plans" only as a training topic, pp. 2, 3, 5)

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)

The heading reads "Service Center Safety and Emergency Plan"; "service center" is not used elsewhere in the draft.

Storage 1
New in the draft

Locked storage of psilocybin products

June 12 recommendation

no counterpart

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)

The second list item ends with "or," followed directly by the refrigeration item as extracted; verify the list structure against PDF page 14.

Adverse health event reporting 1
New in the draft

Two-business-day adverse event reporting

June 12 recommendation

no counterpart

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)

Complaint reporting 1
New in the draft

Complaints to the department

June 12 recommendation

no counterpart

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)

Disciplinary actions and appeal process (7.35.3.x) 2
New in the draft

Notice of contemplated action and grounds for discipline

June 12 recommendation

no counterpart

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)

New in the draft

Hearing rights, process, and timelines

June 12 recommendation

no counterpart

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)

Severability (7.35.3.x) 1
New in the draft

Severability clause

June 12 recommendation

no counterpart

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)

Recommendation content with no counterpart in the July 9 draft (additional items) 3
Not carried over

Wilderness certifications as an individual training requirement

June 12 recommendation

"For those conducting sessions in natural environments: Wilderness First Aid certification; or, Wilderness First Responder certification" listed within the practitioner and facilitator training modules (pp. 3, 5)

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)

Not carried over

Billing and coding training content

June 12 recommendation

"Billing/coding" listed in the New Mexico Module for all three roles (pp. 2, 3, 5)

July 9 rules draft

no counterpart

Not carried over

Basic first aid certification

June 12 recommendation

"Basic First Aid certification" (pp. 3, 5) and "Basic First Aid" within continuing certification upkeep (p. 9)

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)

Where this draft came from

How the draft got here

How this draft got here (June 26 vote and meeting log) motion, tally, verbal agreements, full log

On June 26 the Advisory Board voted 3-2 to accept the June 12 committee recommendation, minus three items later resolved or tabled on July 9. This is the record of that vote and of everything raised across the June 25 and June 26 meetings.

"I move to adopt these recommendations minus the practicum requirement, the controlled substance number requirement, and the reciprocal timeline."

Motion by Brenda Burgard (per the meeting-note summary), June 26 board meeting.
3
in favor
2
against
Carried
recommendation accepted, minus the three

The record names only one member's vote: Larry Leeman's "reluctant yes." The two votes against are not named in the transcript, so they are not attributed here. Leeman added on the record: "I'm voting in favor, but I also favor more discussion. It's not closed off in the future."

Verbal agreements: edits agreed in discussion, not final text 13 items
  • Diagnostic-clinician continuing ed: annuallyevery two years Drafting correction (Dominic Zurlo) · June 26
  • Wilderness first aid: required simply for natural-environment sessionsrequired based on EMS access / remoteness (roughly > 1 hour from EMS) Chris Peskuski; Larry Leeman agreed · June 26 · verbal agreement
  • Facilitator curriculum: add peer-support training as an option Chris Peskuski; department agreed · June 26 · verbal agreement
  • Facilitator ethics: add personal bias and the patient Bill of Rights James Brown / Ian Dunn · June 26 · verbal agreement
  • Faculty experience: the two required faculty must have experience with 40 individual patients June 26 add-on; verification method open · verbal agreement
  • Third-party evaluation: add CME/CEU approval as an alternative pathway Dr. Ann Metz, Warnock, Dr. Fatemi, Lisa Ginsberg; department agreed · June 25 · verbal agreement
  • Inspections: exempt active practicum / dosing from unannounced inspection; notice required Catherine Warnock, Dr. Fatemi · June 25 · verbal agreement
  • Reciprocity: non-English documentation must be translated and apostilled Ian Dunn · June 26 · verbal agreement
  • Mobile treatment units: restore accidentally deleted language under "other approved locations" Chris Peskuski · June 25
  • Home / alternate location: clarify the care team (diagnostic clinician + practitioner) determines medical necessity June 25 · verbal agreement
  • Consent form: non-permitted staff present during treatment must be disclosed June 26 · verbal agreement
  • Healing centers: add the patient Bill of Rights; add English + Spanish / ADA language access James Brown; Skye · June 26 · verbal agreement
  • Reporting: add product ID as a required field in adverse-event reports Greg; Hanifa · June 25-26 · verbal agreement
Deferrals log: everything raised across June 25 and June 26 full table
ItemStatusRaised / carried byDate
CS number requirementKept by dept. 7/17Denali Wilson, Chris Peskuski, Dan Jennings, Dr. Fatemi; dept. defends6/25, 6/26, 7/9, 7/17
Practicum hours (100 / 120)To committee 7/17Scott Shannon, Larry Leeman, Brenda Burgard; dept.6/26, 7/9, 7/17
Reciprocal permit timelineResolved 7/9Larry Leeman; dept.6/25, 6/26, 7/9
20-hour supervisory practicum (make optional)OpenDr. Ann Metz; dept. declined6/25
Practicum-instructor experience minimum (~40 patients)Verbal agr.Catherine Warnock6/25
Faculty 40-patient experience (how to verify)Open threadDept. add-on6/26
Third-party evaluator → CME/CEU alternativeVerbal agr.Dr. Ann Metz, Warnock, Dr. Fatemi, Lisa Ginsberg6/25, 6/26
Practicum inspection carve-out (notice required)Verbal agr.Catherine Warnock, Dr. Fatemi6/25
Peer-support training as a facilitator optionVerbal agr.Chris Peskuski6/26
Wilderness first aid trigger (EMS access)Verbal agr.Chris Peskuski, Larry Leeman6/26
Personal bias + patient Bill of Rights in ethicsVerbal agr.James Brown, Ian Dunn6/26
Apostille / translation of foreign credentialsVerbal agr.Ian Dunn6/26
Staff consent disclosureVerbal agr.Raised 6/25; dept. to clarify6/26
Language access (English + Spanish; ADA)Verbal agr.Skye6/26
Product ID in adverse-event reportsVerbal agr.Greg; Hanifa6/25, 6/26
Mobile treatment unit language (restore)To restoreChris Peskuski6/25
Medical-necessity determiner (care team)Verbal agr.Jessica (chat)6/25
Dosage decision authority (care team; not rule)Resolved verballyHanifa6/25
Mentoring structure (program vs. dept. pool)OpenDenali Wilson6/26
Condition-specific endorsements (EOL, PTSD)DeferredLarry Leeman6/26
Test-out option for didactic modulesPresented, no objectionDept.; Dr. Fatemi6/25
BLS vs. CPR / BVM levelNot changedChris Peskuski; dept. kept BLS6/25
Internal quality-review for centersNot a rule itemJames Brown6/25
Cap on number of educational programsResolved: no limitErica6/25
Healing + training center = two applicationsResolvedCatherine Warnock6/25
Diagnostic-clinician liability scopeResolved verballyChris Peskuski, Greg; Dr. Truckner6/25
Insurance requirement for centersNot requiredHanifa6/25
Volunteers / multi-use spacesResolvedChris Peskuski6/25
Billing: diagnosis vs. treatmentVerbal guidanceLarry Leeman (Q); Alana Dances (A)6/26
Insurance clawback risk (attestation)FlaggedDenali Wilson6/26
Background-check gap / Medicaid validationFlagged as gapAlana Dances6/26
Clinician renameRenamed "certifying clinician" in 7/9 draftHanitha (public) raised "eligibility clinician"6/26, 7/9
Testing / training with well personsMay need legislationLarry Leeman6/26