Dual licensure: what HB 2387 changed for Oregon clinician-facilitators

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

For licensed healthcare professionals in Oregon who hold or are considering obtaining an OPS psilocybin facilitator license, and who want to understand precisely what HB 2387 changed, what it did not change, and what operating under dual licensure requires.

The short answer

Before January 1, 2026, any facilitator — regardless of their other credentials — was prohibited from exercising their professional license while providing psilocybin services. A licensed therapist who was also a facilitator could not provide psychotherapy during an integration session. A physician facilitator could not conduct clinical assessment during preparation. HB 2387, signed in 2025 and operative January 1, 2026, created a partial exception for professionals licensed by seven specific boards. They may now bring clinical work into preparation and integration sessions while holding their facilitator license simultaneously. The administration session remains facilitation-only for everyone. Operating under dual licensure requires affirmative notification to OHA — it is not automatic.

What the rules said before HB 2387

OAR 333-333-5130(2) prohibited any facilitator from exercising the privileges of another professional license during psilocybin services. This prohibition applied across all three session types — preparation, administration, and integration — without exception. The facilitation role was treated as entirely separate from any clinical role.

Alongside this, healthcare professionals were uncertain whether simply discussing psilocybin services with their patients — not facilitating, just discussing — could expose them to professional board discipline. HB 2387 addressed both concerns simultaneously.

The seven boards

HB 2387 created dual licensure provisions for facilitators who also hold licenses issued by these seven 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, operate under dual licensure. The notification is required — dual licensure does not activate automatically upon holding both licenses.

What dual licensure permits, session by session

During preparation sessions, a dual-licensed facilitator may provide health care or behavioral health care services in addition to and simultaneously with facilitation. A therapist-facilitator can conduct a preparation session that incorporates clinical therapeutic exploration alongside the required OPS procedural checklist. A physician-facilitator can conduct clinical contraindication assessment — reviewing medications, health history, and clinical risk — during the preparation session where that screening is most critical.

During administration sessions, a dual-licensed facilitator may conduct the session but may not provide health care or behavioral health care services during the session itself. The facilitation-only rule survives for the administration session in full. A therapist-facilitator cannot provide psychotherapy while a client is under psilocybin’s effects. A physician-facilitator cannot conduct clinical assessment or make clinical decisions in their professional capacity during the administration session.

During integration sessions, a dual-licensed facilitator may provide health care or behavioral health care services in addition to and simultaneously with facilitation. A therapist-facilitator can conduct an integration session that incorporates the clinical processing conversation their training supports — not just the non-directive facilitation approach.

The board discipline protections

HB 2387 prohibits the seven named boards from disciplining their licensees for lawfully providing psilocybin services as a licensed facilitator. Before this provision, the concern — particularly among therapists and counselors — was that holding a facilitator license or discussing psilocybin with patients could be read as conduct warranting board discipline. The statute now forecloses that for licensees of the seven boards, so long as the facilitator is acting lawfully under ORS 475A and OAR 333-333.

This protection runs in one direction: the board cannot discipline the clinician for lawful facilitation. It does not prevent OPS from taking action for violations of OPS rules. It does not protect a dual-licensed facilitator who violates OPS requirements during a session, even if the violation occurred while they were also acting in their clinical capacity.

HB 2387 established information-sharing provisions between OHA and the seven boards. When a dual-licensed facilitator is involved in an OPS investigation, OPS may share complaint and investigation information with the relevant professional licensing board, and vice versa. This information is otherwise confidential under the HB 2387 confidentiality provisions — it is not subject to public records disclosure.

The practical consequence is that a dual-licensed facilitator under OPS investigation should anticipate that their professional board may become aware of that investigation. A significant finding in one proceeding is likely to draw scrutiny in the other. A dual-licensed facilitator in this situation may need separate legal representation for each proceeding.

What HB 2387 did not change

The administration session remains facilitation-only. This is the most important limit of HB 2387: a dual-licensed facilitator cannot provide clinical services during the administration session regardless of what the preparation and integration sessions permit.

HB 2387 did not change the baseline requirements to obtain an OPS facilitator license. A physician or therapist must still complete an OPS-approved training program, pass the state licensing examination, submit the required application, and pay the required fees. There is no expedited pathway, credential recognition waiver, or professional exemption from facilitator training for healthcare license holders in Oregon. The full 160-hour training — 120 hours of instruction and a 40-hour in-person practicum — is required.

HB 2387 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, regardless of their clinical credentials.

HB 2387 did not change the records framework. Client records created during dual-licensed sessions — including any clinical notes created in the clinician’s professional capacity — are subject to OPS records storage requirements (stored at the service center under OAR 333-333-4820) as well as whatever records obligations the clinician’s professional board imposes. Where those obligations conflict or overlap, the clinician needs a clear practice protocol before beginning.

The notification requirement

A facilitator who holds a license from one of the seven boards must notify OHA before operating under dual licensure. The notification must be made in the form and manner prescribed by OHA. It is not sufficient to simply hold both licenses — the active notification step is required to activate the HB 2387 provisions. A facilitator who acts under dual licensure without completing this notification is not operating within the HB 2387 framework.

HB 4040 and potential expansion

During Oregon’s 2026 short legislative session, HB 4040 was introduced to add the Oregon Occupational Therapy Licensing Board and the Oregon Board of Physical Therapy to the dual licensure provisions, expanding the seven boards to nine. That bill was pending as of early 2026.

Practical considerations for dual-licensed practice

Structuring a dual-licensed practice requires attention to several questions that HB 2387 does not answer. Informed consent documentation needs to reflect which license the clinician is acting under during each session type — or whether both are active simultaneously — and the client’s understanding of that. Fee arrangements need to address how clinical services and facilitation services are priced and disclosed, given that psilocybin services are entirely out-of-pocket and clinical services may or may not be billable to insurance. HIPAA applies to the clinical services a covered entity provides but not to OPS facilitation services — a dual-licensed clinician who is a covered entity needs clean separation between those two service streams in their records and billing practices. Professional ethics codes for the relevant clinical discipline apply alongside OPS rules and may impose additional obligations the OPS rules do not address.

When public information may be enough

OHA’s HB 2387 Dual Licensure Fact Sheet is the clearest summary of what the law permits and requires and is available at oregon.gov/psilocybin. The full text of HB 2387 is available through the Oregon Legislative Assembly. OPS licensing staff can be reached through the TLC system at psilocybin.oregon.gov for notification process questions.

When you should speak with a lawyer

Dual licensure involves two separate regulatory frameworks — OPS and the professional licensing board — that do not map cleanly onto each other in every situation. Legal input is worth getting before you begin if you are uncertain how to structure informed consent and documentation when acting under both licenses with the same client; how your professional board has interpreted HB 2387 for your specific license type; how HIPAA applies to your combined practice; or whether any activities you perform in your clinical practice would cross into prohibited territory during an administration session. A dual-licensed facilitator facing an OPS investigation should retain legal counsel before responding and should assess whether separate representation for any board proceeding is also needed.

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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.