Colorado’s Natural Medicine Health Act is, at its core, a bold and hopeful piece of legislation. Voters passed Proposition 122 in 2022 because they understood something that institutional medicine has been slow to accept: that psilocybin, in the right hands, with the right preparation and integration support, can be genuinely transformative. As a licensed natural medicine facilitator in this state, I believe that deeply.
And precisely because I believe it, I’m worried about what’s coming.
Since DORA and the Department of Revenue opened the licensing pipeline, applications have poured in. Approximately 500 individuals are currently completing their training and practicum hours in approved programs across Colorado — all of them working toward facilitator licensure. That’s before accounting for those who have already received their licenses, or the wave of additional applicants expected as the program matures.
On paper, this looks like success to some. On the ground, it raises a question that isn’t being asked loudly enough: what happens to client safety when facilitators start competing for clients the way any other service industry does?
This work is rooted in harm reduction. That is not a tagline — it is the ethical foundation that the entire model stands upon. The three-phase structure, the screening protocols, the integration support, the careful titration of set and setting: none of it is optional. It exists because psilocybin, particularly at therapeutic doses, is a powerful and unpredictable ally. Even a carefully prepared journey can surface profound psychological material. Even a “good” session can become destabilizing in the days that follow without adequate integration support.
What happens to that foundation when, as is inevitable, there are more facilitators than there are clients to work with?
Market pressure does predictable things to service industries. It drives prices down. It compresses session structures. It rewards volume and visibility over depth and care. It incentivizes facilitators to work outside their actual competency in order to fill their calendars. It creates the conditions — slowly, quietly — for harm.
We don’t have to imagine this. We can watch it happening in Oregon right now.
Oregon has been running its regulated psilocybin program since mid-2023, and the early data tells a complicated story. As of mid-2025, approximately 367 facilitators had been licensed — with nearly half of those approvals coming in just the first half of 2025 alone. At the same time, service centers have been closing, facilitators have been declining to renew their licenses, and the average price per psilocybin session (including preparation and integration) has fallen year over year, from $3500.00 or more in 2023 to as low as $1000.00 in 2026.
Those declining prices aren’t just an economic footnote. They reflect a market under pressure — providers competing on cost rather than on quality, care, and ethical rigor. One Oregon service center owner put it bluntly: most of her facilitators see one to two psilocybin clients per month. It’s not financially sustainable as a primary practice. That reality pushes facilitators toward cutting corners in ways that are often invisible to clients: rushing preparation, skimping on integration, accepting clients who should be referred out.
Researchers have already raised flags about whether Oregon’s training requirements are sufficient for facilitators to competently screen for contraindications like emerging mania, psychosis, or cardiovascular risk — even before competitive pressure enters the equation. Add market dynamics, and the concern deepens considerably.
To be fair, Colorado’s architects studied Oregon’s rollout carefully, and the NMHA reflects that. Colorado’s rules require more rigorous training: 150 didactic hours, 40 hours of supervised practice, and a separate clinical facilitator track for licensed mental health and medical providers. The program explicitly integrates psychedelic healing into a broader therapeutic framework, rather than siloing it — a meaningful philosophical and practical distinction from Oregon’s original model.
These are meaningful improvements. They raise the floor. But they don’t resolve the structural tension at the heart of what’s coming.
A well-trained facilitator working under financial pressure is still a facilitator working under financial pressure. And the people most likely to be harmed when that pressure causes errors in judgment are the clients who arrive most vulnerable — the ones carrying trauma histories, psychological fragility, or complex clinical profiles.
The conversation in this field tends to focus on access: how do we get more people into healing? That’s a worthy conversation. But it has a shadow side that deserves equal airtime: what kind of healing, and at what standard?
A few things I’d argue we need as Colorado’s market takes shape:
Tiered competency expectations. A 150-hour training program qualifies someone to hold space for a reasonably healthy adult seeking growth or clarity. It does not qualify someone to facilitate a session for a trauma survivor with a complex psychiatric history. We need honest, clear differentiation — not just between facilitator and clinical facilitator licenses, but in how facilitators communicate their competency to prospective clients.
A culture of care and referral, not retention. In a market with too many facilitators competing for clients, the incentive runs toward taking on anyone who walks through the door. The profession needs to cultivate the opposite ethic — one that prizes caring for client wellbeing, knowing your limits and referring out as a mark of clinical integrity, not failure.
Integration as non-negotiable. The compressed session model — driven by cost and convenience — is one of the more predictable casualties of market saturation. Integration is where the healing actually consolidates. It is not an optional add-on. Regulators, training programs, and practitioners all need to hold this line.
Honest public education about what this work is. Psilocybin facilitation is not a wellness experience. It is not a retreat. At its best, it is a profound psychological and sometimes spiritual encounter that requires significant preparation, a skilled and present practitioner, and meaningful follow-through. The more this work gets positioned as a commodity, the more facilitators act with motivations mismatched with reality — and the more likely clients are to be harmed by that mismatch.
None of this is an argument against Colorado’s program. I believe in it. I built my practice around it. The NMHA represents a genuine opportunity to expand access to healing that can be genuinely life-changing, for people who have often run out of other options.
But this moment — with the licensing pipeline full and the client base largely absent, with time still to shape the culture before the economics take over — is exactly when these conversations need to happen. The psychedelic healing community in Colorado has an opportunity to model something that most emerging industries don’t: an ethic that puts client safety ahead of market share.
The question isn’t whether there will be enough facilitators. There will be. The question is what kind of facilitators they’ll be, and what they’ll be willing to do — or not do — when the market tells them to choose between their integrity and their livelihood.
That’s the conversation worth having. Now, before we need to have it in hindsight.
Erin Witter is a Licensed Natural Medicine Facilitator, Certified Addiction and Recovery Integration Specialist, and the founder of Colorado Psychedelic Healing. He works with clients navigating psilocybin facilitation and integration in Colorado’s regulated natural medicine program.
