The draft rules provide for two full-scope facilitator licenses, “Facilitator” and “Clinical Facilitator.” As a baseline, both licenses require a Basic Life Support (BLS) certification, 150 hours of didactic education on natural medicine services, 40 hours of supervised practice, and 50 hours of consultation with a supervisor. The Facilitator license will be available to anyone who completes an approved training program, while the Clinical Facilitator license will be available to individuals who hold a secondary license that involves diagnosing and treating medical or mental health conditions.
The rules also provide several educational equivalence pathways for people with significant prior experience facilitating with natural medicines. Both license types will be available through accelerated licensure, allowing facilitators to waive parts of the core requirements based on previous experience and education. The only requirement that cannot be waived is a 25-hour course specific to Ethics and Colorado Natural Medicine. Facilitators licensed in another state can apply for licensure in Colorado through an Occupational Credential Portability Program, which mirrors many other DORA-licensed professions in Colorado.
Two secondary licenses are permitted in the draft rules. The “Distinguished Educator” license is designed to allow experienced natural medicine practitioners to serve as faculty in facilitator training programs, specifically as practicum supervisors. This license is necessary at the launch of the program to ensure facilitation students are able to complete the supervised practice and consultation requirements, both of which require the student to work with an experienced supervising facilitator. The Distinguished Educator license is fairly restrictive, allowing the holder to provide facilitation services only in the context of a training program with which they are affiliated. The license must be renewed annually, and licensees may not independently own a healing center.
A temporary “Training License” is available to students who have completed the 150-hour education and BLS certification requirements. Following completion of the 40-hour supervised practice, an individual holding a Training license will be permitted to provide natural medicine services while they are completing the consultation period. During the consultation period, a Training Licensee may provide, and charge for, natural medicine services while meeting regularly with their consulting supervisor to discuss their experiences facilitating. The exact mechanics and requirements of the Training license are somewhat murky in the draft rules, however the overall intent and direction is laudable.
The content and regulation of training programs is also detailed in the draft rules.
Facilitator training programs must offer at least 150 hours of didactic education on the following topics:
- Facilitator Best Practices (5 hours)
- Ethics and Colorado Natural Medicine Rules and Regulations (25 hours)
- Relational Boundaries and Introduction to Physical Touch (10 hours)
- Physical and Mental Health and State (25 hours)
- Drug Effects, Contraindications, and Interactions (5 hours)
- Introduction to Trauma Informed Care (10 hours)
- Introduction to Suicide Risk (5 hours)
- Indigenous, Social, and Cultural Considerations (10 hours)
- Screening (5 hours)
- Preparation (10 hours)
- Administration (10 hours)
- Integration (10 hours)
- Group Facilitation (10 hours)
- Facilitator Development and Self-Care (10 hours)
To receive “Approved Facilitator Training Program” status from the Office of Natural Medicine, training programs must satisfy requirements related to reporting, organization, and administration. Approved programs must have, among other things, a governing body and at least two full-time faculty members, one of whom must be the “Program Director.” The director of an approved training program must hold a Facilitator license, or a secondary professional license that would qualify them for a Clinical Facilitator license. Specific duties are imposed on the director by rule. Beginning January 1st, 2026, approved programs will be required to employ at least one full-time faculty who is a licensed facilitator. Mechanisms for ensuring continued compliance with the requirements of approved status, as well as procedures for withdrawal and reinstatement of approval, are defined.
Ahead of the full approval process being implemented in March 2025, training programs may apply for pre-approval by submitting an application to the Office of Natural Medicine which will ensure facilitators are able to be trained and licensed in time for the January 1st, 2025 launch of the regulated program.