Editor’s note: This is an op-ed. Shannon Hughes and Dori Lewis are co-founders of Elemental Psychedelics, which trains psilocybin facilitators in Colorado. Lewis owns Reflective Healing, a licensed micro healing center in Fort Collins. Hughes has served as a non-voting member of the Natural Medicine Advisory Board’s Qualifications, Training, and Licensing Subcommittee. Psychedelics Today runs its own professional training programs. The views expressed are the authors’ own.
Colorado did something genuinely special. Oregon launched the country’s first regulated psilocybin program; Colorado was the first to pair one with statewide decriminalization for personal use. The state wrote new rules and began licensing the people who would deliver care. We have spent these early years inside the system training facilitators, supervising their practice, and running one of Northern Colorado’s first licensed micro healing centers under the new rules. Building a regulatory floor in a field carrying this much historical complexity is difficult and a real achievement for Colorado.
And yet the question we hear most often in our community is not a technical one. With a sense of growing frustration, our colleagues are asking “is it even worth it?” The system as it currently exists is expensive to enter and to stay in, and dense with regulation. Skilled, values-driven people look at the cost of training and of operating a healing center alongside the stack of annual fees and paperwork, and they ask, reasonably, why they would participate in a system that taxes their values while burning up their time and resources. Moreover, how can mushroom work possibly reach the people who need it most within a system loaded with barriers to entry? The experience of rising costs, dense regulation, and rushed, checklist-style training has us concerned that we’ve drifted from this field’s initial promise toward the very model it was meant to be an alternative to.
Since serious discussions about mainstreaming psychedelic medicines began, there have been two primary, possible pathways for the development of psychedelics in this country. One is the pharmaceutical path, which treats this as an industry to be built, standardized, and scaled for massive profit. The other, which Colorado’s voters chose and which we’re grateful to be part of, was meant to be about community healing and providing many different doors to access.
We’d like to return to what this system was supposed to be, because we’re worried we may be losing the thread.
What a license does not teach
This shows up first in the distance between what training certifies and what practice requires. A license confirms that someone has met a starting standard. Everything that makes psychedelic care competent and sustainable comes after it. For example, a question that frequently surfaces in our consultation is deceptively simple. “Who is a good fit for this medicine, and who isn’t?” It sounds like it should have a definitive answer. It doesn’t.
Recently a facilitator asked us about a prospective client, a man in his forties with a history of suicidal thoughts and a suicide attempt a decade ago. They listed a number of current medications, including prescription medications for sleep and anxiety. The facilitator rightly took pause because his history and medications raised concerns on the required safety screen, and initially decided this person was not a good fit for psilocybin services. However, upon careful exploration with him beyond the screening form (his current stability, internal resources, and support system), he looked, in our clinical view, like a reasonable candidate for further assessment, including any medical or behavioral-health consultation the rules require. The initial screen raised questions that a fuller assessment could address, and knowing how to work through those questions is not something anyone learns in a single lecture. We watch capable, well-meaning new facilitators become so anxious about missing a contraindication that they turn away people who could be served safely and well. Screening is a skill built through supervised repetition and honest consultation, not delivered inside a single lecture for required hours.
The math on both sides
The second point here has to be cost, and it cuts on both sides of the equation. Client interest in this work is strong, but the path from curious interest to actually receiving care is narrow. Between the management of appropriate expectations, the extensive time commitment, the potential travel to a licensed healing center, and the several thousand dollars of disposable income someone may need just to begin, plenty of people who want this service never make it from curiosity to a genuine assessment of readiness, let alone actually going through with the work. The people delivering that care face their own math. Between facilitator licensing, healing center requirements, and layered regulatory fees, the annual cost of simply staying compliant is significant, and it falls hardest on the smaller practices the system most needs and was meant to support. When the fixed cost of the door is high, we lose the opportunity for a broader, more diverse facilitator community.
None of this is an argument for no oversight. We strongly believe in structures of accountability for fully legal psychedelic care. It is an argument for asking, honestly, what we are actually regulating and who it keeps safe. Some requirements clearly protect clients. Others are harder to justify. Why are we keeping waste-disposal logs and reporting trace amounts of psilocin to the state, for a substance that people are legally free to grow in their own homes and share with friends? This is not a drug with high rates of diversion to an underground market. Every hour and dollar spent tracking things that keep no one safer is an hour and dollar that drives up the cost of care.
Three adjustments
So we’d offer three adjustments, none of which lowers the standard or quality of care:
Ease the burdens that don’t serve safety. Shifting healing center and facilitator license renewals from an annual to a biennial cycle, while lowering the total fees paid over two years, would relieve real pressure on small practices without touching quality. Consider the contrast: Licensed Professional Counselors and physicians in Colorado renew every two years, while natural medicine facilitators renew annually; many also need a separate handler license. Shannon has carried versions of this into rule-making conversations, and the principle is simple: the state can hold essential oversight while not charging for compliance that doesn’t contribute to safety.
Invest in competence through time, not just hours. If the thing we most need is more experienced practitioners, we should stop rushing people toward full licensure. Let the training license expire in three or four years rather than two, and require a minimum period, not just a minimum number of hours, for consultation. Currently, Rule 2.8(D)(1) requires 40 consultation hours but sets no minimum span. For example, Dori’s AASECT certification in sex therapy required fifty supervision hours spanning no less than two years, precisely so that learning happens in real time, alongside real practice. A practicum crammed into a single weekend, or 40 hours of consultation done in one intensive week, defeats the purpose. Those supervised hours could also do double duty. Structured like a counselor’s supervised practice, they could serve low-cost clients, with reduced pay traded for real experience. The exchange itself widens access.
Give the community room to solve what the state can’t. The best parts of this model are already relational. Facilitators are starting integration groups for one another, peer circles are forming, and people are improvising to fill the gaps the rules leave, like with microdosing that never fit neatly into the regulatory scheme. The state does not have to anticipate and regulate every corner of this system. Set the floor and the guardrails for safety, then let the community breathe, get creative, and meet its own needs. That, after all, was the original promise of the Natural Medicine Health Act.
What the rules get right
There is real wisdom already built into these rules that we’d hate to see lost in the frustration. The requirement to work out of a healing center is inconvenient for those of us who came up in the underground, but it is also a reasonable ethical safeguard, keeping us visible to a community of practitioners rather than isolated in our homes. Allowing clinical and non-clinical practitioners to collaborate, rather than cutting anyone out of their appropriate scope, keeps the field humane and whole. Building preparation and integration into the model, and letting peer circles count toward continuing education, all reflect an understanding that this work is relational at its core.
We came to this convinced that ethical psychedelic care lives in connection, mentorship, and community more than in protocol. More than a year into regulated services, turning that conviction into a workable blueprint feels more urgent, not less. A license can put a minimally qualified person in the room. It cannot, on its own, hand them the judgment to know who to serve, the consultation hours that grow that judgment, or the financial footing to still be practicing in five years. Those are the things that will decide whether Colorado’s experiment becomes a model for other states or a cautionary tale.
Colorado did the genuinely hard work of opening the door. Now comes the vital work of shaping a system that actually serves the people inside it. With the rest of the country watching, our task is to continually refine this framework piece by piece, without losing sight of why Coloradans chose this path in the first place: to build a diverse, ethical, and truly accessible ecosystem for natural medicine care.
