Published text
Provision by provision
7.35.3.19 (A)
Hour totals, and when the practicum may start
DeferredNew gate
An individual who seeks to become certified as a practitioner or facilitator shall participate in supervised practice training, otherwise referred to as a “practicum”, after completing at least half of the didactic requirements and all of the simulated patient requirements of the educational requirements. The practicum shall consist of a minimum of 100 hours of supervised practice training for facilitators and 120 hours for practitioners and shall be completed prior to applying for certification. Students shall participate in a minimum of 80 hours of administration day sessions… with a minimum of 14 different patients over a minimum of eight different administration and same-day sessions.
Sets the totals, and bars a student from starting until half the classroom hours and all simulated patient hours are done. The gate is new in this draft, has no counterpart in the July 9 draft, and appears in neither July 17 transcript.
Published rule, p. 12
7.35.3.19 (B)
Preparation and integration hours
Deferred
Students shall participate in a minimum of 20 hours of in-person preparation and integration sessions… This shall include a minimum of six different patients during individual sessions. This shall include at least one group preparatory and one group integration session with a minimum of four or more patients.
The 20 hours here plus the 80 in (A) make up the 100-hour facilitator total.
Published rule, p. 12
7.35.3.19 (C)
Practitioner supervisory hours
Deferred
Practitioners shall complete an additional minimum of 20 hours as a practitioner supervising facilitators during in-person administration day sessions, which shall include a minimum of two different patients during individual administration day sessions, and a minimum of one group administration day sessions with a minimum of four or more patients in the group.
These 20 hours are the difference between the facilitator total of 100 and the practitioner total of 120. The board named them in the deferral motion.
Published rule, p. 13
7.35.3.19 (D)
Where the practicum may happen
Dependency
All practicum hours shall take place in an approved healing center or other approved location.
Ties every practicum hour to a facility that must first be certified under 7.35.3.11. Any change to placement, including a site-supervisor or apprenticeship model, changes this sentence.
Published rule, p. 13
7.35.3.19 (F)
Departmental discretion to waive or reduce
Deferred
The department may otherwise waive, temporarily suspend, or reduce the practicum requirements for individuals applying for certification, in order to facilitate the certification of individuals trained by other government-approved programs, and to build the initial infrastructure of the program.
Open-ended and undated. No standard governs when it applies, and nothing ends it.
Published rule, p. 13
7.35.3.19 (G)
In-state waiver, 40 contact hours
Conflicts
An applicant for certification shall not be required to satisfy the full New Mexico practicum hours requirement if the applicant: (1) Applies for certification by December 31, 2027; (2) Completes the didactic requirements by December 31, 2027; (3) Graduates from an educational program that the department certifies by December 31, 2027 or that the department has included on the department-approved list…; and (4) Demonstrates completion of at least 40 hours of contact time… including: (a) A minimum of two separate individual sessions… and (b) A minimum of one group session…
Requires two individual sessions and one group session. The out-of-jurisdiction waiver at 7.35.3.10 (D)(1) requires two individual and two group for the same 40 hours. Both cannot be the standard.
Published rule, p. 13
7.35.3.18 (C)
Didactic hours the practicum gates on
Raised 25 to 30
All practitioners and facilitators shall complete a psilocybin therapy module consisting of a minimum of 30 didactic hours and 5 hours of simulated patient experience, prior to applying for certification.
7.35.3.19 (A) gates practicum entry on "half of the didactic requirements and all of the simulated patient requirements," so this figure sets the gate. It was covered by the same 7-0 deferral vote and was published five hours higher than it stood that day. Three subjects were added: Trauma-Informed Care, Dosing, and Non-ordinary states of consciousness.
Published rule, p. 11
7.35.3.14
Who may possess and administer psilocybin
Students absent
Certification of a practitioner, facilitator, or healing center shall enable practitioners, facilitators, and owners and employees of healing centers to do the following… (C) Healing centers: Owners and employees of healing centers who are registered with the department may purchase… possess… and may sell or otherwise administer those products to qualified patients…
This is the only grant of authority to possess or administer psilocybin in the rule. It names three categories and a practicum student is none of them, because certification is what the practicum is a prerequisite for. Meanwhile 7.35.3.19 (A) requires students to "conduct supervised facilitation of administration day sessions."
The phrase "registered with the department" appears exactly once in all nineteen pages, in this subsection. Nothing in the rule creates that registration.
Published rule, p. 9
7.35.3.20 (H)(5)
Staffing ratio counting students
Depends on .14
…in group administration sessions a minimum of one practitioner for every eight patients and a minimum of one facilitator or qualified student for every two patients. For purposes of the foregoing provision, a student shall be deemed qualified if they are registered with a certified educational program and they have completed at least 50 hours of their practicum.
Counts students toward mandatory coverage, which means a session can lawfully rely on someone 7.35.3.14 does not authorize to handle the medicine. New in this draft. Denali Wilson raised the idea at the July 17 committee meeting and the department said it would take it back.
Published rule, p. 14
7.35.3.10 (D)(1)
Out-of-jurisdiction waiver, 40 contact hours
Conflicts with 19(G)
An applicant for certification as a practitioner or facilitator on the basis of an educational program from another jurisdiction, whose application is received by the department by December 31, 2027, shall not be required to complete the full practicum hours required by New Mexico, but shall demonstrate completion of at least 40 hours of contact time with a minimum of two separate individual sessions and two separate group sessions…
A second practicum waiver, sitting outside 7.35.3.19 in the out-of-jurisdiction application section. Same 40 hours, different session test. Amending 19(G) alone leaves this standing.
Published rule, p. 4
7.35.3.11
Creates the approved locations 19(D) requires
Dependency
An applicant seeking certification as a healing center shall submit a complete application through the electronic system designated by the department…
Every practicum hour must occur at a location certified under this section. No certified locations, no practicum. Any placement model that decouples the practicum from healing centers has to be written here as well as in 19(D).
Published rule, p. 5
New section
Authority for a student to handle psilocybin
Does not exist
The rule requires students to facilitate administration sessions and counts them toward staffing, and never authorizes them to possess or administer the medicine. The gap has to be closed by adding to 7.35.3.14, or by creating a training permit as its own section.
On July 17 the department said a training permit was unnecessary because students "already will have that kind of protection ability to be there as a part of being registered as a student with an educational program." No such provision was published.
The rule currently ends at 7.35.3.28, Severability. A new section numbered 29 would sit after it, which is unusual drafting; placing it in the training run is cleaner.
New subsection
The healing-center registration 14(C) requires
Does not exist
7.35.3.14 (C) conditions the authority of healing-center owners and employees on being "registered with the department." No section creates that registration, so on the face of the rule no owner or employee qualifies. It belongs in 7.35.3.11, which handles healing-center certification, or as a new subsection of 7.35.3.20.