Mandatory reporting obligations for licensed psilocybin facilitators

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

For licensed psilocybin facilitators in Oregon who want to understand what the law requires them to report, to whom, and when.

The short answer

Oregon law places several distinct reporting obligations on licensed facilitators. They fall into four categories: reporting adverse events to OPS; contacting emergency services when a medical emergency occurs during a session; attempting post-session client contact within 72 hours; and reporting violations of ORS 475A and OAR 333-333 by other licensees. Each obligation has different triggers, different recipients, and different timing requirements. None require a facilitator to make routine disclosures about what happens in sessions — they are triggered by specific circumstances, not by default.

Adverse event reporting

An adverse event in Oregon’s psilocybin program is defined as a client’s behavioral reaction that required contacting emergency services or receiving care from a medical care provider during an administration session. The reporting obligation is limited to that threshold — a client who had a difficult experience, became distressed, or required significant facilitator attention but did not require medical care or emergency transport does not generate a mandatory adverse event report.

Adverse event reporting goes to OPS, not to law enforcement. The adverse event report must be initiated by the client — the client’s consent and participation are part of the mechanism. A facilitator cannot file an adverse event report unilaterally on behalf of a client who has not agreed to have that information reported.

This threshold was clarified in the January 2024 rulemaking cycle. The current standard is clear: if the client required medical care or had to be transported to a medical facility, the adverse event must be reported. If neither happened, no adverse event report is required.

Emergency services

OAR 333-333-5120 requires a facilitator to use their training to distinguish between typical psilocybin side effects and a medical emergency. Before contacting emergency services, the facilitator and service center must first take reasonable steps to mitigate safety issues — OPS amended the rules to require de-escalation steps first given the federal jurisdiction consequences of calling emergency services into an active psilocybin session. When a true medical emergency exists and cannot be managed otherwise, the facilitator must contact emergency responders immediately. See What happens when a client has a medical emergency during a session? for a full treatment of that sequence.

The 72-hour post-session contact

OAR 333-333-5250 requires a facilitator to attempt to contact every client within 72 hours of the conclusion of the administration session. The purpose is to offer the client information on integration sessions and other services, including peer support groups and community resources. This is an attempt requirement — the rule requires the facilitator to try to make contact, not to guarantee it succeeds. The contact is not a clinical check-in and does not require the facilitator to assess the client’s psychological state.

Misconduct and violation reporting

As of January 2025, OAR 333-333 imposes an expanded duty on licensees, licensee representatives, and permit holders to report violations of ORS 475A and OPS rules. This is a peer-reporting obligation — facilitators who observe or become aware of conduct by another licensee that violates the statute or rules are required to report that to OPS.

What triggers this duty is conduct constituting a rule violation — not disagreement with another facilitator’s approach, and not client complaints better directed through OPS’s complaint process. The duty covers regulatory violations: a facilitator witnessing another facilitator engage in prohibited conduct, operate without appropriate consent, violate scope of practice rules, or act in ways that endanger client safety.

OPS is the recipient for violation reports. Criminal conduct is a matter for law enforcement — OPS will refer criminal matters accordingly and only investigates violations of ORS 475A and OAR 333-333.

What is not a reporting obligation

A facilitator is not required to report the contents of client sessions to OPS or any other agency in the ordinary course. Client records stay at the service center and are subject to confidentiality requirements.

A facilitator is not required to report a client’s use of psilocybin to any law enforcement agency. State-licensed psilocybin services are legal under Oregon law.

A facilitator is not required to generate an adverse event report when a client has a difficult emotional or psychological experience that does not rise to the level of requiring medical care or transport. The threshold is medical intervention — not discomfort, not distress, not an experience the client or facilitator found challenging.

A facilitator is also not a mandated reporter in the general statutory sense that applies to healthcare professionals in clinical settings. The ORS 475A framework does not layer mandatory child abuse or adult abuse reporting obligations onto facilitators as a condition of their facilitation license. A facilitator who also holds a professional license in a field with mandated reporting obligations retains those obligations in their professional capacity — but the facilitation license does not create new ones.

Data reporting under SB 303

Service centers are required to collect and report quarterly demographic and session data to OPS under SB 303. This obligation falls primarily on the service center rather than on the individual facilitator, though facilitators are involved in the data collection process. The data is aggregate and de-identified before submission.

Confidentiality of OPS complaints

Under HB 2387 (effective January 1, 2026), complaints and investigation information held by OPS are confidential, subject to limited exceptions for sharing between OPS and the seven identified professional licensing boards when a dual-licensed facilitator is under investigation. Complaints to OPS may be made confidentially upon written request.

When public information may be enough

OAR 333-333-5120 (Facilitator Conduct), OAR 333-333-5250 (post-session contact), and OAR 333-333-4700 (Duty to Contact Emergency Services) are publicly available through the Oregon Secretary of State’s administrative rules database. OPS publishes guidance documents for licensed facilitators at oregon.gov/psilocybin.

When you should speak with a lawyer

If emergency services were called during a session and you are uncertain about your reporting obligations in the aftermath, consult an attorney before acting. If you have been told by a client that they believe a rule violation occurred and you are uncertain what to do with that information, legal counsel is worth consulting before you respond. The intersection between OPS reporting duties and any obligations under a separate professional license — particularly for dual-licensed facilitators — warrants specific legal advice.

You might also want to read

• What happens when a client has a medical emergency during a session?
• What to do if a client files a complaint against you
• What a facilitator can and cannot do during a session
• Scope of practice: what are facilitators legally prohibited from doing?
• Recordkeeping requirements for Oregon and Colorado facilitators
• Mandatory reporting obligations after a session incident (the operator's side)