Can I facilitate psilocybin sessions if I am also a licensed therapist, nurse, or doctor?

Last reviewed: August 2026 · Psychedelic law changes quickly — verify current status before relying on this page.

For licensed healthcare and behavioral health professionals in Oregon or Colorado who want to understand whether and how their clinical license interacts with a psilocybin or natural medicine facilitator license.

The short answer

Yes — a licensed therapist, physician, nurse, psychologist, social worker, naturopath, or pharmacist can obtain a psilocybin facilitator license in Oregon or Colorado. No rule bars healthcare professionals from completing facilitator training and applying for licensure. What varies between the two states is how much clinical work a dual-licensed professional can do during sessions, and what protections exist against professional board discipline. In Oregon, HB 2387 (operative January 1, 2026) created specific dual licensure protections for seven named boards, allowing clinical work during preparation and integration sessions but not during the administration session. In Colorado, the Clinical Facilitator license track is a distinct pathway for licensed health professionals that allows broader integration of clinical practice into facilitation from the start.

Oregon: what the rules said before HB 2387

Before January 1, 2026, OAR 333-333-5130(2) prohibited any facilitator from exercising the privileges of another professional license during psilocybin services — across all three session types. A licensed psychologist who was also a facilitator could not provide psychotherapy during an integration session. A physician facilitator could not conduct clinical assessment during preparation. The facilitation role was treated as entirely separate from any clinical role, and mixing them was prohibited.

Many healthcare professionals were also uncertain whether discussing psilocybin services with their patients — not even facilitating, just discussing — could expose them to board discipline. HB 2387 addressed both concerns.

Oregon: what HB 2387 changed

HB 2387, signed in 2025 and operative January 1, 2026, created dual licensure provisions for facilitators who also hold licenses from seven specific boards:

Oregon Board of Licensed Professional Counselors and Therapists
Oregon Board of Naturopathic Medicine
Oregon Board of Psychology
Oregon Medical Board
Oregon State Board of Nursing
State Board of Licensed Social Workers
State Board of Pharmacy

A facilitator licensed by one of these boards who notifies OHA in the prescribed form and manner may, beginning January 1, 2026, conduct preparation sessions while simultaneously providing health care or behavioral health care services, conduct administration sessions (but may not provide health care services during the administration session itself), and conduct integration sessions while providing health care or behavioral health care services.

The notification to OHA is required — dual licensure is not automatic. A facilitator must affirmatively notify OHA before operating under dual licensure.

HB 2387 also prohibits the seven named boards from disciplining their licensees for lawfully providing psilocybin services as a licensed facilitator, and separately protects the discussion of psilocybin services with patients from board discipline. HB 4040, introduced during Oregon’s 2026 short legislative session, would expand the seven boards to nine by adding the Oregon Occupational Therapy Licensing Board and the Oregon Board of Physical Therapy. That bill was pending as of early 2026.

Oregon: what HB 2387 did not change

The administration session remains facilitation-only. A dual-licensed facilitator cannot provide therapy, clinical assessment, or diagnosis during the administration session regardless of their other credentials.

HB 2387 did not change the baseline requirements to become a facilitator. A physician or therapist must still complete an OPS-approved training program, pass the state licensing examination, and pay the required fees. There is no expedited pathway or professional exemption from training for healthcare license holders.

HB 2387 also did not change the prohibition on health-related claims under OAR 333-333-6040. A dual-licensed facilitator cannot represent psilocybin services as treating or managing any health condition.

Colorado: the Clinical Facilitator track

Colorado’s approach is structurally different. Rather than creating a dual licensure overlay on a single facilitator license, Colorado built a separate Clinical Facilitator license track for licensed health professionals. Applicants who hold an active Colorado license to practice as a medical doctor, psychologist, licensed counselor, nurse practitioner, physician assistant, or certain other specified health professions may apply for the Clinical Facilitator track, which has its own training requirements and an abbreviated consultation structure compared to original licensure.

Clinical Facilitators in Colorado may integrate natural medicine services into their existing clinical practice in ways that general Facilitators may not. The clinical track reflects Colorado’s intention to allow licensed health professionals to bring their full clinical training to the facilitation context from the outset, rather than creating a post-licensure overlay as Oregon did with HB 2387. An accelerated clinical facilitator pathway is also available for licensed health professionals who have undergone extensive post-graduate clinical training in facilitation.

What this means in practice

In Oregon, a therapist or psychologist who also holds a facilitator license can bring their clinical skills to preparation and integration sessions as of January 1, 2026. A therapist can conduct a preparation session that incorporates therapeutic exploration alongside the required procedural checklist, and an integration session that involves clinical processing conversation. The administration session stays within facilitator scope only — non-directive, no clinical intervention.

For physicians and nurse practitioners in Oregon, dual licensure allows clinical assessment during preparation (where contraindication screening occurs) and clinical support during integration, while keeping the administration session within the standard non-directive framework.

In Colorado, a Clinical Facilitator operates under a license that was designed from the start to accommodate clinical integration, making the practice structure cleaner from a regulatory standpoint — though the clinical boundaries during administration sessions are similarly constrained.

In both states, structuring a practice that uses both licenses requires attention to informed consent, documentation, billing (psilocybin services are entirely out-of-pocket), and the relevant board’s guidance. These are not abstract questions, and the answers vary by profession and individual practice structure.

When public information may be enough

OHA’s HB 2387 Dual Licensure Fact Sheet is at oregon.gov/psilocybin. The full text of HB 2387 is available through the Oregon Legislative Assembly. DORA’s Clinical Facilitator licensing information is at dpo.colorado.gov/NaturalMedicine.

When you should speak with a lawyer

Dual licensure in Oregon involves two separate regulatory frameworks — OPS and your professional licensing board — that do not always map cleanly onto each other. The questions most worth getting legal input on: whether your board has issued guidance on HB 2387 specific to your license type; how to structure informed consent and documentation when operating under both licenses with the same client; and whether your current clinical practice activities would cross into prohibited territory during an administration session. For Colorado Clinical Facilitators, the equivalent questions run through DORA’s rules and your Colorado professional licensing board.

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This article is for general informational purposes only and does not constitute legal advice. Laws and regulations governing psilocybin services change frequently. For advice about your specific situation, consult a licensed attorney.