Scope of practice: what are facilitators legally prohibited from doing?

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

For licensed facilitators, facilitators-in-training, and healthcare professionals considering the Oregon facilitator license who want to understand where psilocybin facilitation ends and the practice of other disciplines begins.

The short answer

Oregon law defines facilitator scope of practice as “practice boundaries related to psilocybin facilitation and avoiding the unlicensed practice of other disciplines including but not limited to medicine or psychotherapy.” That definition, codified in OAR 333-333-1010, is deliberately broad. It tells facilitators what they must stay away from more than what they are permitted to do. The rules prohibit diagnosis, treatment, and health-related claims outright. They require facilitators who hold other professional licenses to set those licenses aside entirely while providing psilocybin services. And they establish the non-directive approach as the standard for every session. The legal line runs between supporting a client through an experience and treating, diagnosing, or interpreting that experience as a clinician would.

What Oregon deliberately excluded

Oregon did not create a medical model. Measure 109 and ORS 475A built a supported adult use program — one in which any person 21 or older may access psilocybin services for any reason, without a prescription, referral, or diagnosis. The informed consent document that every facilitator must review with every client before an administration session states explicitly that psilocybin services “are not a medical or clinical treatment.” Service centers may not operate within healthcare facilities. Facilitators are not permitted to diagnose or treat health conditions under OAR 333-333-5130(1).

This was a policy choice, not an oversight. Legislators and rulemakers considered and rejected a medical model at multiple points during the development of the program.

The non-directive requirement

The non-directive approach is the operational expression of scope of practice during sessions. Under OAR 333-333, a facilitator must maintain a consistent disposition with the client while avoiding giving direct advice or directly interpreting the client’s statements, behaviors, or needs. This applies during administration sessions and integration sessions.

What that means in practice: a facilitator can be present, attentive, and supportive. A facilitator can respond to a client in distress, use approved supportive touch, and help ground someone through a difficult experience. What a facilitator cannot do is interpret the client’s internal experience, offer clinical analysis, suggest what a client’s visions mean, or direct the client toward particular psychological conclusions. The line falls between witnessing and interpreting.

The prohibition on practicing other licenses during facilitation

OAR 333-333-5130(2) prohibits a facilitator from exercising the privileges of any other professional license while providing psilocybin services. This prohibition applies broadly. A licensed counselor who also holds an OPS facilitator license cannot provide counseling during a preparation, administration, or integration session. A nurse practitioner facilitator cannot perform clinical assessment in that role. A physician facilitator cannot make diagnoses or recommend treatment.

The prohibition covers all three session types, not just the administration session. A facilitator-therapist cannot provide psychotherapy during an integration session on the grounds that the administration is over. The entire service — preparation through integration — falls within the scope of psilocybin services, and the rules apply throughout.

Facilitators who hold other professional licenses remain responsible for knowing what constitutes the practice of those licenses and ensuring they are not crossing into that practice. OHA has made clear that this is the individual facilitator’s responsibility to understand and manage — OPS will not adjudicate it in advance.

Referral obligations

While facilitators cannot provide clinical services, they are expected to recognize when a client’s situation exceeds facilitation’s scope and to act on that recognition. Facilitator training requires specific instruction in using the client information form to identify clients who may benefit from referral to specialized treatment services. When a facilitator’s scope is exceeded, referral — not improvised clinical intervention — is the appropriate response.

This is not a discretionary practice. Facilitators who recognize that a client presents needs beyond what the facilitation model can address have an obligation to point that client toward appropriate services. How that referral happens, and what resources are available to offer, is something facilitators are trained to handle.

The dishonest conduct rule

OAR 333-333-6040 prohibits facilitators from making health-related claims, misrepresenting their credentials, or engaging in dishonest conduct. This rule has direct implications for how facilitators describe their services. A facilitator cannot represent psilocybin services as treating, curing, or managing any health condition — including depression, PTSD, anxiety, or addiction — even if research suggests potential benefit and even if the client is hoping for those outcomes. A facilitator can describe what the services are and what the client can expect from the experience. Making therapeutic outcome claims crosses into dishonest conduct under the rule and can result in license action.

The same prohibition applies to marketing materials, websites, and any communications where a facilitator describes their practice.

The supervision prohibition

As of January 1, 2025, OAR 333-333-5120(14) and 5130(4)-(6) added an explicit prohibition on a licensed facilitator supervising individuals experiencing psilocybin outside a service center, unless a specific exception applies. This closes off an informal practice that some facilitators and aspiring facilitators had explored — being present during an experience that did not occur at a licensed service center. The prohibition is now codified. A licensed facilitator cannot lend their presence as supervision for an unlicensed administration.

Where the line sits in practical terms

The scope of practice rules create a model that looks unfamiliar to most clinical practitioners. The facilitator is not a therapist, not a guide in the traditional ceremonial sense, and not a bystander. OHA’s own description of the role is that facilitators support clients through the experience using a standard of care that other reasonable facilitators would use under similar circumstances — with a duty to put clients’ interests above their own.

That standard is not a clinical standard. No formal clinical standard of care for psilocybin facilitation has been defined in Oregon, because the program was not designed as a clinical program. What the rules provide instead are procedural floors — specific session requirements, consent obligations, prohibited conduct, and a non-directive approach — and leave the relational and experiential dimensions of facilitation to training programs and individual practice within those floors.

The gray areas are real. Integration sessions often resemble therapeutic conversation in tone and content. The line between offering a client information about peer support and interpreting a client’s experience is not always obvious in the room. These are the situations where a facilitator’s training, judgment, and understanding of the rules matter most — and where, if uncertainty persists, legal counsel is worth consulting.

When public information may be enough

OAR 333-333-5130 (Facilitator Scope of Practice) and OAR 333-333-6040 (Dishonest Conduct) are the primary rules governing this question. Both are publicly available through the Oregon Secretary of State’s administrative rules database. Reading those rules alongside the informed consent requirements in OAR 333-333-5040 gives a clear picture of the statutory and regulatory boundaries.

When you should speak with a lawyer

If you hold another professional license — in any health, mental health, or behavioral health field — and are weighing how to structure your practice alongside a facilitator license, the interaction is not straightforward. HB 2387 (effective January 1, 2026) created dual licensure protections under seven specified boards, but it did not dissolve the prohibition on practicing under both licenses simultaneously during a session. Understanding what the protection covers and what it does not requires legal analysis specific to your licensing situation. An attorney familiar with ORS 475A, OAR 333-333, and the relevant professional licensing statutes for your field is the right person to ask.

You might also want to read

• What can and can’t a facilitator legally do during a session?
• Can a licensed therapist or physician also be a facilitator?
• What does it mean to be a licensed psilocybin facilitator?
• What are a facilitator’s mandatory reporting obligations?
• Working as a guide, coach, or integration specialist: what’s legal?