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Natural Medicine Frequently Asked Questions

Leading the way

Psilocybin mushrooms

Colorado is only the second state in the nation (after Oregon) to legalize psilocybin mushrooms for personal use or use by healing centers after Gov. Jared Polis signed SB23-290 into law in May 2023. Colorado's Department of Revenue (DOR) and the Department of Regulatory Agencies regulate different aspects of the program, with DOR licensing and regulating natural medicine businesses – healing centers, cultivations, manufacturers, and testing facilities, and their owners and employees. The Department of Regulatory Agencies (DORA) licenses and regulates facilitators of natural medicine. For more information, visit DORA's Natural Medicine site.

As the DOR was creating the final rules for regulating natural medicine, many interested parties have asked questions about how to get licensed and about other aspects of the program. The most frequently asked questions are found below.
 

Questions and responses by topic

Applications

When will license applications be available?

  • On or before December 31, 2024. 
  • The Natural Medicine Division of the Department of Revenue (NMD-DOR) will begin accepting applications for regulated natural medicine business licenses, including Cultivations, Healing Centers, Manufacturers, and Testing Facilities  on or before 12/31/24. The NMD-DOR is responsible for licensing  (a) Natural Medicine Handlers;  (b) Natural Medicine Business Owners; and (c) Natural Medicine Business licenses (Cultivations, Healing Centers, Manufacturers, and Testing Facilities). 
  • The Department of Regulatory Agencies (DORA) will begin accepting applications for Facilitator licenses on or before 12/31/24. For additional information, please see the DORA Natural Medicine FAQ page.

What is the difference between a standard “Owner” license and an “Owner-Facilitator” license?

  • A person who is already licensed as a Facilitator (through DORA) and who wants to also own and operate their own Regulated Natural Medicine Business should apply with the NMD-DOR for an Owner-Facilitator license. Applications for an Owner-Facilitator license are subject to lower fees compared to the standard Owner license (because the applicant was already subject to certain vetting through DORA).
  • Any person not licensed by DORA as a Facilitator and who is interested in owning and operating a Natural Medicine Business license should apply for the standard “Owner” license.

I currently have my Training Facilitator License. Can I apply for an Owner’s License for a Natural Medicine Business with the NMD-DOR, or do I need to be fully licensed as a Facilitator first?

  • If you possess a DORA-issued Training Facilitator license, you may apply for an Owner’s License (you do not have to be fully licensed as a Facilitator upon applying). However, you will need to be fully licensed as a Facilitator (by DORA) upon renewal the following year in order to avoid paying the application renewal fee. 

I currently have my Training Facilitator License. Can I associate with (aka contract with) a Healing Center, or do I need to be fully licensed as a Facilitator first? 

  • If you possess a DORA-issued Training Facilitator license, you may contract with a Healing Center (you do not have to be fully licensed as a Facilitator upon applying). A Training Facilitator contracting with a Healing Center must comply with all DORA-related requirements while in that role.

How can I apply for a license with the NMD-DOR?

How can I pay for my fees?

  • Acceptable forms of payment include:
    >Checks (in the name of the applicant or applicant's attorney’s trust account)
    >Money order
    >Major credit cards (subject to service charge) 

Do you have an estimate of how long the application review will take? 

  • At this time, we cannot provide an estimated time for review. The Division is committed to facilitating efficient review and processing of applications. Applicants can support these efforts by aiming to submit complete applications and timely responding to Division communications. 
  • It should also be noted that Colorado statute and regulations provide that certain applications are prioritized if they meet certain criteria. As a result, applications will not be processed in the order they are received. For additional information regarding the criteria for priority review, please see Rule 2125(C) of the Natural Medicine Rules.
License Types

If I have (or am applying for) an Owner License, do I also need a Natural Medicine Handler License? 

  • No. If you possess an Owner License, you have all of the same privileges as a Natural Medicine Handler License and do not need both. Use this flow chart to help determine what type of individual license you may need to apply for: 240528 Draft License Diagram - Google Slides.
Healing centers

Who needs a license to work as an employee at a Healing Center?

  • Persons interested in working in a Healing Center as an employee are required to obtain a Natural Medicine Handler license if they will have access to or handle Regulated Natural Medicine and Regulated Natural Medicine Product. 

Can multiple Facilitators practice at the same Healing Center?

  • Yes. More than one Facilitator can practice at the same Healing Center (the same applies to Micro-Healing Centers). In order to operate (provide services), a Healing Center must be owned by or contract with at least one Facilitator, and there is no limit to the number of Facilitators that can be associated with that Healing Center. 

Should I apply for a Healing Center or Micro-Healing Center License?

  • Healing Center licenses may store more than 750 milligrams of Total Psilocin (about 10 grams of dried mushrooms) on site, with no upper limit, and are subject to standard security requirements (see Rule 8025). This license type could be a good fit for operators providing administration services as their primary mode of business. 
  • Micro-Healing Center licenses may store up to 750 milligrams Total Psilocin (about 10 grams of dried mushrooms) on site, and are subject to reduced security requirements. This license type is geared towards someone who is only planning to provide a limited number of administration sessions each week or year. 

Are Natural Medicine Business licensees required to hold professional liability insurance?

  • No. The Regulated Natural Medicine Rules do not require licensees to hold professional liability insurance.
Cultivations

Should I apply for a Standard or Micro-Cultivation License?

  • A standard tier cultivation license may store up to 5 kilograms of dried mushrooms on site. Mycelium, spores, and growing fruiting bodies do not count towards this storage limit. If your business needs to produce and store more than 5 kilograms, Rule 5015 outlines the process to request Division approval for tier increase. 
  • A micro-tier cultivation license is allowed to store up to 750 grams of dried mushrooms on site. There is no process to tier up from a micro-tier cultivation to a standard cultivation, so if you anticipate having more than that, consider the standard tier license. If you end up needing to store more than a micro-tier allows, you will need to apply and receive approval for a new standard tier cultivation license before you begin storing the increased amount of dried mushrooms.
Testing facilities

If I currently own a testing facility that does research and development testing (R&D) for cultivators and manufacturers, can my testing facility continue to do R&D testing if it becomes a licensed testing facility? 

  • Yes, Rules 5005 and 6005 provide for cultivators or product manufacturers to submit samples for research and development testing as long as it is Regulated Natural Medicine or Regulated Natural Medicine Product, and not from the personal use space.

Can I test “personal use” natural medicine on my licensed premises? 

  • No, currently the rules do not allow a licensed testing facility to test “personal use” natural medicine on the licensed premises. As the Division communicated during the 2024 rulemaking process, this is a topic we’ll revisit in a future rulemaking.
Product Manufacturers

Should I apply for a Manufacturer with an extraction endorsement license?

  • Yes, if you would like to create pressed tablets, chocolate, gummies, or tinctures.
  • No, if you would like to create only tea bags or capsules with powdered mushrooms.
Advertising

What is not allowed for business advertising? 

  • No advertising or marketing that appeals to individuals under 21 years of age. 
    Marketing may not include:
    >Pictures or images of children or minors
    >Cartoons or similar images typically marketed towards children
    >Pictures of toys 
  • No deceptive, false, or misleading statements can be made about products or services. This includes saying that the natural medicine or natural medicine product is “safe” because it was tested. 
  • No misappropriation of Federally Recognized American Tribes, indigenous people, their community, culture, or religions. This could look like:
    >Using the word “native” to describe your product or services if you are not from a Federally Recognized American Tribe or an indigenous community.
    >Using the word “curandera,” “curandero,” or “shaman” unless you are a traditional healer from an indigenous community. 
    >Using color motifs that are strongly related to native or indigenous culture and history without a personal tie to that community.
    >Anything else that could be perceived as misappropriation of native or indigenous culture. 

What is allowed to be advertised?

  • Licensed Healing Centers may advertise natural medicine services at the Healing Center. Please consult DORA regarding Facilitator advertising.
  • Licensed Natural Medicine Businesses may advertise growing supplies, spores, and other related products to other Licensed Natural Medicine Businesses. 
  • Licensed Natural Medicine Cultivations and licensed Natural Medicine Product Manufacturers may advertise their services to Facilitators and Healing Centers. 

 What expectations are there for advertising?

  • When creating an advertisement and identifying a targeted audience on your advertising platform, ensure that at least 73.6% of your audience is 21 years or older. Many advertising platforms provide audience demographic information and vary in how they provide that to businesses. Here is an example of how to find it in Google, but many other platforms provide similar information.

Can I have a sign on my building that tells participants where I am located?

  • Yes. Licensed Natural Medicine Businesses may have a sign to identify your business at your location. 

Is Outdoor marketing allowed? 

  • Yes, as long as a licensee confirms with their local jurisdiction that they are following any advertising rules in their city, town, or county; and 
  • A licensee must submit to the Natural Medicine Division both audience composition data and documentation that they are in compliance with any rules in their local jurisdiction prior to outdoor advertising.
Licensed Premises Information

What signage is my Healing Center required to have?

  • Healing Centers must display:
    >Signs identifying any administration area or restricted area as “Authorized Personnel Only.” 
    >A copy of the Healing Center’s License issued by the State Licensing Authority. 
    >Information regarding safe transportation after an Administration Session - this could look like a QR code, phone numbers, or other information about public transportation or ride shares. 
    >Additionally, Healing Centers must have instructions or guidance about how to file any complaints to either DORA or DOR, and how to file complaints related to Adverse Health Events to the Division. 

If I currently have an office to provide therapy, can I use that same office as a Healing Center?

  • Yes, you can provide Regulated Natural Medicine services at your office, as long as it is not within 1,000 feet of a licensed childcare facility or school and you are in compliance with any relevant zoning requirements, you do not need a separate location to provide natural medicine services. As long as you are able to lock the medicine in a safe place, and lock your door at the end of the day, you can apply for a micro-Healing Center license. 
Personal Use Versus Regulated Natural Medicine

Regulated Natural Medicine

Where can I access or provide Regulated Natural Medicine Services?

  • Most Regulated Natural Medicine will be available to participants at a Healing Center. In limited circumstances, Facilitators are allowed to provide administration services at another approved location (pursuant to rules adopted by DORA and/or the NMD - DOR’s State Licensing Authority). Wherever the session happens, Regulated Natural Medicine must be sourced from a licensed Natural Medicine Business such as a Cultivation or Product Manufacturer. 

Can a licensed Facilitator provide Natural Medicine Services to a participant at a location other than a Healing Center? 

  • Yes, certain locations are authorized by DORA for a Facilitator to provide natural medicine services outside of a Healing Center. A Facilitator will still need to obtain Regulated Natural Medicine or Regulated Natural Medicine Product from a Natural Medicine Business in order to provide the Regulated Natural Medicine to a participant, even outside of a Healing Center.  

Personal Use 

What are the parameters of personal use of natural medicine?

  • An individual over 21 years of age is allowed to cultivate their own psilocybin mushrooms in a 12’ x 12’ space that is locked to anyone under the age of 21. There is no personal possession limit.
  •  An individual may share with an adult (21+) in the context of counseling, spiritual guidance, community-based use, supported use, or related services.
  • No payment for natural medicine (“remuneration”) - except the law permits payment for bona fide harm reduction or support services used concurrently with sharing.
  • No open and public display or consumption.

Can I sell the natural medicine that I grow for personal use?

  • No. The sale of any natural medicine is prohibited under the law.

Can I give the natural medicine I grow to others?  Are there restrictions on when or how I can give it to someone else?

  • You can share your own natural medicine grown at home with other adults 21 years of age and older. You cannot charge for the natural medicine and they cannot pay you for natural medicine. 
Resources

NMD Rules in the Public Resources Folder
DORA’s Natural Medicine Website