Oregon Measure 109: A Practical Guide for Facilitators Building a Practice

Oregon Measure 109 created the first legal framework for psilocybin services in the United States. Since services went live in 2023, the program has grown to approximately 300 licensed facilitators and 34 service centers. But building a sustainable practice within this framework requires more than a license. It requires understanding the documentation requirements, operational workflows, and compliance obligations that make the difference between a professional practice and one that is vulnerable to enforcement action.

This guide covers the practical realities of operating as a facilitator under Measure 109.

The Three-Session Structure

Oregon's framework establishes a mandatory three-session structure for psilocybin services:

Preparation Session

Before any psilocybin administration, the facilitator must conduct at least one preparation session. This session covers:

• Screening and intake: Review of the participant's medical history, current medications, mental health history, and contraindications. This is not optional. Facilitators are required to screen for conditions that could make psilocybin administration unsafe.
• Informed consent: The participant must understand what the experience involves, the potential risks and benefits, and their right to stop at any time.
• Intention setting: While not a regulatory requirement in the strict sense, preparation sessions typically include a discussion of the participant's intentions and expectations.
• Logistics: What to bring, what to wear, dietary recommendations, transportation planning (participants cannot drive themselves home after an administration session).

The preparation session is typically 60-90 minutes and can be conducted remotely in some cases, though many service centers require in-person preparation.

Administration Session

The administration session is the psilocybin experience itself. Key requirements:

• Duration: Sessions typically last 6-8 hours, though the regulatory framework does not specify a minimum or maximum duration. The facilitator must remain present for the entire session.
• Dosing: Psilocybin products are manufactured by licensed manufacturers and provided through licensed service centers. Facilitators do not procure or prepare the psilocybin themselves.
• Documentation: Facilitators must document the session, including dosage, start and end times, observations, and any notable events. These records are subject to OHA review.
• Safety: The service center must have safety protocols in place, including emergency procedures and access to medical support if needed.

Integration Session

Oregon does not mandate a specific number of integration sessions, but the framework recognizes integration as a core component of psilocybin services. Integration sessions typically involve:

• Reflecting on the experience
• Identifying insights and themes
• Developing plans for incorporating insights into daily life
• Addressing any challenging aspects of the experience
• Planning follow-up support

Most facilitators offer at least one integration session, with many providing ongoing integration support over weeks or months.

Documentation Requirements

Documentation is where many facilitators struggle. Oregon requires facilitators to maintain records for each participant, including:

• Intake and screening forms: Medical history, contraindication screening, medication review
• Informed consent documentation: Signed consent forms with specific disclosures required by OHA
• Preparation session notes: What was discussed, any concerns identified, readiness assessment
• Administration session records: Date, time, dosage, duration, facilitator observations, any adverse events
• Integration notes: Follow-up sessions, participant progress, ongoing support plans
• BAA documentation: Business Associate Agreements for HIPAA compliance

These records must be stored securely (HIPAA-compliant), retained for the period required by Oregon law, and available for OHA inspection.

Many facilitators start with paper forms and spreadsheets, but this approach becomes unmanageable as participant volume grows. Practice management platforms designed for psychedelic facilitation, like CoreJourney, provide structured templates for each documentation requirement and store everything in a HIPAA-compliant system with built-in audit trails.

Service Center vs. Independent Practice

Under Measure 109, psilocybin administration must occur at a licensed service center. Facilitators cannot administer psilocybin in their own homes or offices. This creates two operating models:

Service center employee or contractor: The facilitator works at a licensed service center, which provides the physical space, psilocybin products, and operational infrastructure. The facilitator focuses on the clinical work. This is the most common model, especially for newly licensed facilitators.

Service center owner-operator: The facilitator obtains both a facilitator license and a service center license, operating their own space. This requires significantly more capital, regulatory compliance, and operational overhead, but offers more autonomy and higher revenue potential.

In both models, the facilitator is responsible for their own documentation, participant records, and HIPAA compliance.

Common Compliance Gaps

Based on the first three years of Measure 109 operations, these are the most common compliance gaps facilitators encounter:

Inconsistent documentation: Some facilitators document thoroughly for administration sessions but skip detailed notes for preparation and integration. All three phases require documentation.

Unsecured participant records: Using personal email, consumer cloud storage, or unencrypted files for participant health information violates HIPAA requirements.

Missing BAAs: Many facilitators use scheduling tools, note-taking apps, or cloud storage without verifying that the vendor has signed a Business Associate Agreement.

No audit trail: If a participant files a complaint or OHA conducts an inspection, the facilitator needs to produce a complete record of all interactions. Without audit logging, this is difficult or impossible.

Building a Sustainable Practice

The facilitators who are building sustainable practices in Oregon share several characteristics:

• They invest in compliance infrastructure from day one, rather than retrofitting it later
• They use structured documentation workflows that make record-keeping consistent and efficient
• They track the full participant arc from inquiry through integration completion
• They build referral networks with other facilitators, therapists, and healthcare providers
• They treat integration as a revenue center, not an afterthought

The Oregon psilocybin market is still early. Facilitators who establish professional, well-documented practices now are building the credibility and track record that will define this field as it grows.