We recognize and appreciate the rigor and diligence with which the Oregon Health Authority, Oregon Psilocybin Services (OPS), and the Oregon Psilocybin Advisory Board have conducted the important, albeit challenging, work of building out the operating regulatory framework to guide the implementation of ORS chapter 475A.
Overall, the process appears to have generated a prudent set of rules that would create a program that balances client safety with strong licensee oversight under a flexible set of program rules. As a first-in-the-nation exercise in developing such a robust framework, your work overall appears to have been successful and will provide a worthy template for other states to consider following.
Our review of the proposed permanent rules related to Oregon Psilocybin Services yielded the following observations for consideration as you approach final rulemaking.
Read the full testimony below or download the PDF here.