Introduction

The passage of Colorado’s Natural Medicine Health Act in November of 2022 (“Proposition 122” or “NMHA”) marked a significant milestone in psychedelic policy reform in the United States. After Oregon, Colorado became the second state to provide adults access to certain natural psychedelics, and the first to do so in a way that permits personal and communal use. At launch, the NMHA will allow psilocybin and psilocin, however, the state is required to consider the addition of Dimethyltryptamine, Ibogaine, and Mescaline (excluding Peyote) in the future. 

Although there has been a fair amount of controversy around the passage of the NMHA, one common theme for all involved is the desire for the Colorado program to improve upon Oregon’s. We saw this desire in the drafting of the NMHA, which included a number of differentiating policy positions. We saw it again with the Colorado legislature and Senate President’s passage of SB23-290—a 70-page bill that mostly expands on the key policy points of the NMHA.   

Now all eyes are on Colorado’s Natural Medicine Advisory Board (“NMAB”), the state-appointed board tasked with making recommendations for the implementation of this program. Will they continue this trend of improving upon Oregon? Will their recommendations create a program that is affordable, equitable, and safe? How will the NMAB address tiered facilitator licensing? What about natural medicine services at private homes and healthcare facilities? Can licensed counselors provide therapy coupled with natural medicines? Will the NMAB recommend more or less than the 120-hour training program of Oregon? Will they include other species outside of Psilocybe cubensis? Will the recommendations have a different set of regulatory requirements for indigenous practices? What about the ESG screen for corporations—will it have any teeth or just increase the costs of services? 

Additionally, with the passage of SB23-290, there is now a Federally Recognized American Tribes and Indigenous Working Group established. How is this new Working Group going to interact with the NMAB?

Finally, and arguably most important: What regulations will actually be promulgated by the two Colorado agencies tasked with implementing this measure?  

So many questions are still left unanswered as the clock ticks towards the program’s launch on January 1, 2025.  

This webpage and bulletin is dedicated to being a clearinghouse for the implementation of Colorado’s Natural Medicine Health Act, with a focus on the work of the Natural Medicine Advisory Board and its subcommittees.