What a facilitator can and cannot do during a session

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

For licensed facilitators and people preparing to work in Oregon’s psilocybin program who want to understand the specific legal permissions and prohibitions that apply session by session.

The short answer

Oregon’s rules define what facilitators are permitted to do in precise, session-specific terms. The permissions are broader than many expect in some areas — facilitators can use supportive touch, conduct group sessions, and offer resources after the experience — and narrower than many assume in others. A facilitator may not diagnose, interpret a client’s experience, transfer the product to the client, or practice any other licensed profession while facilitating. The rules in OAR 333-333 govern each session type separately: preparation, administration, and integration each carry their own requirements and limits.

The preparation session

A facilitator must complete at least one preparation session with every new client before that client’s first administration session. After the initial preparation, no additional preparation session is required before subsequent administrations with the same client during a 12-month period — the facilitator must only confirm that the client’s information is still current before each follow-up session.

During the preparation session, the facilitator is required to:

• Conduct the session privately with each individual client
• Collect a completed client information form
• Review the informed consent document, the Client Bill of Rights, and product information
• Review fee documentation and the applicable service center emergency plan
• Complete a transportation plan — which may not authorize the client to operate any motor vehicle, bicycle, or other self-operated vehicle after the session
• Complete a safety and support plan with the client
• Discuss the client’s intentions, expectations, and internal and external factors that could affect the experience
• Discuss the service center’s policy on firearms and weapons
• Discuss the process for verifying license status and making complaints
• Obtain written consent for any activities or circumstances requiring it

Written consent is required before the administration session for: participation in a group session; use of supportive touch; presence of training practicum students; video or audio recording; sharing of identifiable client data; use of different facilitators across session types; secondary dosing; and presence of service center licensee representatives during the administration.

The preparation session must be private — only the client, the facilitator, client support persons who will be present at administration, and (with the client’s written consent) practicum students may attend.

The administration session

The administration session is where the client consumes psilocybin. Facilitators do not transfer the product — that is the role of a licensee representative of the service center. A facilitator who is also a licensee representative is prohibited from transferring products to a client while acting in the facilitator role. Payment for the product must occur before the session begins. Any portion of the product not consumed must be returned to the service center and destroyed at the session’s conclusion.

The facilitator’s role during the administration session is defined by the non-directive approach. Under OAR 333-333, this means the facilitator maintains a consistent disposition with the client while avoiding giving direct advice or directly interpreting the client’s statements, behaviors, or needs. The facilitation is supportive and observational, not therapeutic or directive.

During the administration session, a facilitator may:

• Monitor the client throughout the session
• Use supportive touch if the client has provided prior written consent — touch is limited to the defined categories (hands, arms, feet, and certain other areas specified in OAR 333-333-5120) and is not permitted during active psilocybin effects without prior consent obtained during preparation
• Administer secondary doses if the client consented in advance, up to the agreed maximum not exceeding 50 mg of psilocybin analyte total
• Determine when the session may conclude, in consultation with the client, after the minimum duration has passed
• Continue the session past 11:59 PM if necessary for client safety, but must notify OPS by 4:00 PM the following day

During the administration session, a facilitator may not:

• Transfer psilocybin products to the client (service center representative’s role)
• Leave the client unsupervised
• Diagnose, treat, or interpret the client’s experience
• Practice medicine, psychotherapy, or any other licensed profession
• Allow video or audio recording without prior written client consent
• Allow persons other than the client, facilitator, client support persons, and authorized practicum participants to be present without the client’s written consent

Session duration is tied to dose. At less than 5 mg of psilocybin analyte, the minimum duration is one hour. At the highest doses — greater than 35 mg up to the 50 mg ceiling — the minimum is six hours. The facilitator and client together determine when the session concludes, once the minimum duration has passed and the client’s safety is not at risk.

Group administration sessions

Group sessions are permitted under OAR 333-333-5230, subject to strict rules. No group may exceed 25 clients, regardless of how many facilitators are present. The facilitator-to-client ratio varies by dose — at less than 5 mg of psilocybin analyte, one facilitator may work with up to 25 clients; at doses of 35 mg or more, the ratio is 1 to 2.

All clients must be present at the start of the session; no one may join after it begins. Clients may not touch one another except for supportive touch with prior written consent. If a client becomes disruptive, the facilitator must make reasonable efforts to move that person to a separate area. Every client in a group session must have the opportunity to request individual support from a facilitator at any point.

The integration session

Integration sessions are optional. If the client participates, the facilitator must use the non-directive approach and follow the requirements of OAR 333-333-5130. The facilitator may provide the client with information about peer support groups and community resources in support of ongoing integration — this is permitted and encouraged. The facilitator may not provide clinical interpretation, diagnosis, or therapeutic direction.

Regardless of whether the client participates in a formal integration session, the facilitator must attempt to contact every client within 72 hours of the administration session’s conclusion to offer information about integration services and other resources.

What facilitators cannot do in any session

The rules prohibit facilitators from doing any of the following at any point during the provision of psilocybin services:

• Diagnosing a client’s medical or psychological condition
• Providing psychotherapy or other clinical treatment
• Practicing under any other professional license (a licensed therapist who is also a facilitator may not provide therapy during facilitation)
• Making health-related claims or misrepresenting credentials — prohibited under OAR 333-333-6040
• Allowing clients to leave following a session by operating any motor vehicle or bicycle

When public information may be enough

OAR 333-333-5000 through OAR 333-333-5260 set out the session requirements in full. These rules are publicly available through the Oregon Secretary of State’s administrative rules search. If you want to understand the precise text of a specific requirement — what the informed consent document must say, what supportive touch encompasses, how secondary dosing is handled — the rules are the primary source.

When you should speak with a lawyer

If you are uncertain whether a specific practice or service you want to offer falls inside or outside your scope as a facilitator, that is a legal question. The line between facilitation and the practice of psychotherapy, medicine, or counseling is not always obvious in practice, and OPS has not published formal guidance on every edge case. A facilitator who also holds a healthcare license faces additional complexity, particularly given HB 2387’s dual licensure provisions. An attorney familiar with ORS 475A and OAR 333-333 can help map what is and is not permissible for your specific situation.

You might also want to read

• Facilitator scope of practice: where is the legal line?
• What does it mean to be a licensed psilocybin facilitator?
• Can a licensed therapist or physician also be a facilitator?
• What are a facilitator’s mandatory reporting obligations?
• Facilitator contracts: what should be in your client agreements?