How Colorado's Natural Medicine Health Act Actually Works
A deep dive into Proposition 122 — what the NMHA legalized, the distinction between personal use and regulated access, facilitator licensing, healing center standards, and what's still being figured out.
Colorado’s Natural Medicine Health Act (NMHA), enacted through Proposition 122 in November 2022, created one of the most comprehensive legal frameworks for psychedelic therapy in the United States. But the law is more nuanced than most people realize. Here’s what it actually does — and doesn’t — allow.
What Prop 122 Legalized
The NMHA operates on two tracks, each with different rules and timelines.
Track 1: Personal Use. As of 2024, adults 21 and older can possess, use, and grow (for personal use) psilocybin and psilocin — the two primary psychoactive compounds in psilocybin mushrooms. This decriminalization applies to possession and personal cultivation but does not extend to commercial sale. You can grow mushrooms for yourself. You cannot sell them.
Track 2: Regulated Access. The more significant (and complex) track is the regulated therapeutic access system — a state-licensed framework of healing centers, trained facilitators, and standardized products. This track began accepting license applications in 2024 and has been operational with licensed centers since 2025.
Which Substances Are Included
The NMHA initially covers psilocybin and psilocin. The Natural Medicine Advisory Board was tasked with evaluating whether to recommend additional substances — including DMT, ibogaine, and mescaline (from non-peyote sources) — for inclusion in the regulated access program. The law deliberately started narrow and included a mechanism for thoughtful expansion.
Peyote is explicitly excluded from the NMHA out of respect for the Native American Church and other indigenous traditions that consider peyote sacramental.
Healing Centers
Healing centers are the physical locations where supervised psilocybin therapy takes place. They must be licensed through the Department of Regulatory Agencies (DORA) and meet standards for physical space, safety equipment, emergency protocols, record-keeping, and client privacy.
A healing center is not a dispensary — clients do not purchase psilocybin and take it home. All consumption occurs on-site, under the supervision of a licensed facilitator. Sessions follow a structured protocol that includes preparation, the supervised experience, and a post-session period to ensure the client is grounded before leaving.
Facilitator Licensing
Facilitators are the trained professionals who guide the therapeutic experience. The licensing requirements include over 100 hours of specialized training covering psilocybin pharmacology and safety, preparation techniques, dosing session support, integration methodology, ethics and scope of practice, cultural sensitivity, and emergency response.
Facilitators do not need to be licensed mental health professionals, though many hold dual credentials. The NMHA created a distinct professional category, recognizing that effective psilocybin facilitation draws on a broader skill set than traditional psychotherapy alone — including somatic awareness, contemplative practice, and ceremony.
Supply Chain
The Department of Revenue (DOR) manages the supply side — licensing cultivators and manufacturers, establishing testing standards for potency and contaminants, regulating packaging and labeling, and overseeing the seed-to-sale tracking system. This ensures that the psilocybin administered in healing centers meets consistent quality and safety standards.
Who Can Participate
The regulated access program is open to adults 21 and older. There is no requirement for a clinical diagnosis, a doctor’s referral, or Colorado residency. The NMHA explicitly recognizes that psilocybin’s therapeutic potential extends beyond clinical conditions to include personal well-being and growth.
However, healing centers are expected to conduct appropriate screening. Contraindications (psychotic spectrum disorders, certain cardiovascular conditions, specific medication interactions) should be identified before any session.
What the NMHA Does Not Allow
The law does not legalize recreational sale or commercial distribution of psilocybin outside the licensed healing center framework. It does not change federal scheduling — psilocybin remains a Schedule I substance under federal law. It does not require insurance companies to cover psilocybin therapy. And it does not override employer drug testing policies.
The Advisory Board
The Natural Medicine Advisory Board plays a crucial ongoing role. Composed of diverse stakeholders — clinicians, researchers, community members, advocates, and public health experts — the board provides recommendations on program implementation, safety standards, equity and access, research priorities, and potential expansion to additional substances.
What’s Still Being Figured Out
Like any novel regulatory framework, the NMHA implementation is an evolving process. Questions being actively worked through include the scope of practice boundaries between facilitators and licensed therapists, insurance and third-party payment pathways, data collection and outcome tracking across the program, equity provisions to ensure access isn’t limited to those with financial resources, and navigating the tension between state legality and federal scheduling.
For the full legal text and background, see our comprehensive Colorado law guide. Ready to learn more about the therapy itself? Explore the process.