RN Collins has written a series of 20 new articles for cannabis law report on 2026 Psychedelics & Legal Issues.

This is the final in this series

Contact RN Collins: https://www.linkedin.com/in/rn-collins/

 

Transparency Mechanisms in Psychedelic Oversight Agencies

Cannabis Law Report Audit-Style Reports Series — Report 4

Abstract

Transparency in government regulatory programs serves democratic accountability functions and, critically, creates deterrence: public visibility of agency performance raises the probability that misconduct will be detected and publicized, thereby reducing its occurrence.¹ Archon Fung, Mary Graham, and David Weil’s foundational study of targeted transparency regimes demonstrates empirically that disclosure requirements alter the behavior of regulated entities and government officials when disclosure is calibrated to audience decision-making needs — a principle directly applicable to psilocybin program oversight.² This report examines the transparency mechanisms embedded in Oregon’s Psilocybin Services program, Colorado’s Natural Medicine program, and New Mexico’s nascent Medical Psilocybin program, compares them against transparency standards in mature cannabis regulatory frameworks, and identifies both structural achievements and persistent gaps. The report concludes with a model transparency framework designed to be adopted legislatively or by administrative rulemaking in current and future psychedelic regulatory programs.

I. Introduction: Why Transparency Matters Especially in Psychedelic Regulation

The transparency obligations applicable to public agencies derive from constitutional principles of democratic accountability and from statutory frameworks enacted at the state and federal level to operationalize those principles. In the context of drug regulatory agencies administering novel psychedelic programs, however, transparency carries additional functional significance that goes beyond routine good government principles.

First, because psilocybin programs operate in tension with federal law, public transparency provides a form of institutional legitimacy that formal legal authorization cannot — demonstrating to skeptical communities, legislators, and federal authorities that the program is administered with integrity and without corruption.

Second, because the client population in psilocybin service programs includes individuals in vulnerable psychological and emotional states, transparency about client outcomes, adverse events, and program safety performance serves a direct public health function. Oregon pharmacists are required under ORS 689.455 to report suspected violations and adverse drug events to the State Board of Pharmacy; analogous transparency obligations in psilocybin programs protect prospective clients’ ability to make informed decisions about program participation.

Third, because psychedelic regulation is politically contested in many jurisdictions, transparency about demographic access patterns, geographic availability, enforcement consistency, and program costs provides the evidentiary foundation for equity arguments and legislative reforms. Without systematic transparency, equity concerns remain anecdotal rather than empirically grounded.

Fourth, as the Massachusetts Cannabis Control Commission audit of 2025 and the California Department of Cannabis Control performance audit demonstrated, the absence of proactive public transparency is associated with the kind of financial mismanagement, procedural inequities, and accountability failures that compromise agency effectiveness and public trust.¹ Transparency creates deterrence; its absence creates opportunity.

II. Oregon Psilocybin Services: Transparency Assessment

A. Proactive Data Publication: The SB 303 Dashboard

Oregon’s most significant transparency achievement is the OPS Data Dashboard, launched in June 2025 following implementation of Senate Bill 303 (2023), now codified at ORS 475A.372 and 475A.374.³ The dashboard, built on Microsoft Power BI and updated quarterly, is among the most comprehensive proactive public disclosure systems associated with any regulated drug program in the United States.

The dashboard contains seven interactive data pages:

1. Licensing Page: Real-time licensing status across all OPS license categories, including current counts of active, pending, denied, and surrendered licenses. This data reflects the current internal TLC system status, updated immediately as changes occur.⁴

2. Compliance Page: Final orders for license denials and administrative violations, updated as new orders are issued. This page provides the most direct public window into OPS enforcement activity.⁵

3. Safety Page: Adverse event data, including behavioral reactions, medical reactions, and post-session reactions, by quarter. Since program launch through Q3 2025, 13 total emergency service reports have been documented.⁶

4. Product and Sales Page: Psilocybin product sales data by product type, dosage range, and quarter, tracked through the TLC product tracking system (TLC-PTS). This data shows the evolution of the product market over time, including the trend of declining average product prices from approximately $85 per product in 2023 to an estimated $50 by mid-2026.⁷

5. Applicant/Licensee Demographic Page: Demographic data on licensees including race, ethnicity, gender identity, sexual orientation, and other characteristics collected under SB 303.⁸

6. Client Demographic Page: De-identified aggregate client data including age, income, county of residence, reasons for accessing services, and veteran status (added in 2025 by HB 2387).⁹

7. Final Orders Page: Administrative final orders providing direct access to enforcement decisions.

The Data Archive, hosted separately on the OHA website, provides downloadable quarterly Excel files for researchers and members of the public seeking raw data.¹⁰ The de-identified Q1 2025 SB 303 data file is available for public download. This archive represents a level of open data accessibility that surpasses most state drug regulatory programs.

B. Open Records Access

Oregon’s public records law, codified at ORS Chapter 192, establishes a strong presumption of disclosure. ORS 192.314(1) states that Oregon’s public records law “is one of disclosure, not confidentiality.”¹¹ Any person — regardless of residency or stated purpose — may request public documents.¹² Agencies must acknowledge a request within five business days under ORS 192.324, and must complete their response or provide a written estimated completion date within ten business days of that acknowledgment under ORS 192.329(5).¹³

For OPS records, the practical effect of this presumption is that agency records — including internal correspondence, rulemaking files, compliance investigation records (to the extent not exempted), license application files, and financial records — are presumptively accessible to the public. The Oregon Department of Justice maintains a public catalog of records exemptions to assist requestors in understanding what information may be withheld.¹⁴

The most significant public records tension in the OPS context involves client-related records. OPS administrative rules require service centers to maintain client records on licensed premises in a manner that “prevents unauthorized access, protects client privacy, and prevents alteration of client records.”¹⁵ The SB 303 data system collects de-identified aggregate data, not individual client records. Individual client records held by service centers are the property of those private business entities, not OHA, and are not subject to Oregon’s public records law — appropriately protecting sensitive health information.

However, OPS’s own internal compliance investigation records — including records of complaints received, investigations initiated, and administrative violations issued — are OHA records presumptively subject to public disclosure. OPS has not published a comprehensive public summary of complaint volumes, investigation timelines, or violation categories, which represents a transparency gap in the agency’s operational records relative to the dashboard’s strength on program outcomes.

C. Open Meetings

OPS’s rulemaking processes are conducted with extensive public participation requirements. Rules Advisory Committees (RACs) meet publicly, with participation requirements including Spanish language interpretation, American Sign Language interpretation, and CART captioning.¹⁶ RAC meetings are recorded and recordings are published on the OHA website.¹⁷ Public comment periods are held annually, with virtual public hearings open to all members of the public.¹⁸

OPS staff and OPAB members are also subject to financial disclosure requirements and conflict-of-interest rules administered by the Oregon Government Ethics Commission (OGEC) under ORS Chapter 244. OGEC requires public officials to disclose financial interests that could conflict with official duties and prohibits use of public position for personal gain. Given the regulatory capture concerns inherent in a small, close-knit industry with frequent rulemaking contact between agency staff and licensees, OPS should consider publishing an annual summary of relevant OGEC disclosures filed by licensing and compliance staff — information that is already publicly available through OGEC but not currently compiled or highlighted in OPS’s transparency reports.

The Oregon Psilocybin Advisory Board (OPAB) is a public body subject to Oregon’s public meetings law (ORS Chapter 192, Public Meetings). OPAB meetings must be open to the public, agendas must be publicly noticed in advance, and minutes must be prepared and made available.¹⁸ Oregon HB 2387 (2025) restructured the OPAB, reducing its size to nine members and revising its composition, but did not alter its public meetings obligations.¹⁹

Annual public listening sessions are held by OPS to receive public feedback on program administration — a proactive engagement mechanism beyond required public meetings.²⁰

D. Transparency Gaps

Despite its considerable strengths, Oregon’s transparency framework has three significant gaps:

Gap 1: Complaint volume and processing time data. The dashboard does not publish data on the number of complaints received by OPS, the time from complaint receipt to investigation initiation, or the time from investigation initiation to final order. This prevents public assessment of whether OPS’s complaint handling is timely and equitable.

Gap 2: Inspection activity data. OPS does not publish data on compliance inspections conducted — their number, frequency, announced vs. unannounced status, or findings summary. This is the most significant transparency omission, given that inspection data is the primary indicator of proactive compliance monitoring.

Gap 3: Financial performance data. OPS does not publish annual budget summaries, fee revenue totals, or cost-per-licensee data that would allow assessment of whether the program’s fee structure is financially sustainable. Reporting from Willamette Week confirmed that no general fund appropriation for OPS was enacted for the 2025–27 biennium, with OHA acknowledging the program must now operate solely on fee revenue that has proven insufficient in prior years.²¹

III. Colorado Natural Medicine Program: Transparency Assessment

A. Licensing Status Transparency

Colorado’s Natural Medicine Division maintains a publicly accessible license look-up tool and a weekly-updated table of pending and approved license numbers on its program website.²² This real-time licensing transparency is a straightforward and effective public disclosure mechanism that allows prospective clients, investors, and members of the public to verify the licensed status of any natural medicine business or facilitator.

The Department of Regulatory Agencies (DORA) similarly maintains a license look-up tool for facilitator licenses.²³ The bifurcated regulatory structure requires users to consult two separate agency websites to verify the full compliance status of a natural medicine facilitator who also works at a healing center — a practical accessibility limitation that could be addressed through a unified compliance portal.

B. Rulemaking Transparency

Colorado’s Natural Medicine Division conducted an extensive public rulemaking process between March and July 2024, hosting multiple public rulemaking meetings to develop the program’s implementation rules.²⁴ The Division coordinated closely with the Natural Medicine Advisory Board (NMAB) and DORA to ensure rulemaking meetings worked in tandem without duplication.²⁵ All rulemaking materials are published in a public resources folder accessible on the Division’s website.²⁶

The Colorado Secretary of State publishes the Code of Colorado Regulations, which contains all administrative rules of state executive agencies. Rules are published twice monthly in the Colorado Register, providing current and prospective stakeholders with access to both proposed and final rules.²⁷

C. Compliance Tools Transparency

Colorado’s compliance tools page provides public access to guidance documents, inventory tracking forms, waste tracking logs, and transport manifests.²⁸ The Division accepts written comments on the rules throughout the year through an open form, even when no formal rulemaking proceeding is active.²⁹ This continuous public comment mechanism goes beyond the minimum required by administrative procedure law and reflects a posture of ongoing stakeholder engagement.

The Division has published Compliance Tips in its Bulletins folder, providing proactive guidance on licensed premises compliance, transportation requirements, and transfer procedures.³⁰ Proactive compliance guidance improves rule clarity and reduces inadvertent violations — a form of substantive transparency that benefits both regulated parties and the public.

D. Data Transparency: Developing Infrastructure

Colorado Senate Bill 25-297 (2025) directed the Colorado Department of Public Health and Environment (CDPHE), in coordination with DOR and DORA, to collect and maintain a database of data related to the use of natural medicine, including law enforcement incidents, adverse health events, healthcare facility impacts, consumer protection claims, and behavioral health outcomes.³¹ The CDPHE data collection database is subject to a statutory repeal provision set for September 1, 2030, and data collection is contingent on available appropriations and gifts, grants, or donations from sources without a financial interest in outcomes.³²

This conditional data collection mandate is weaker than Oregon’s unconditional SB 303 requirement. The funding contingency and sunset create structural uncertainty about whether Colorado’s data collection will generate the longitudinal public record needed to evaluate program performance. Colorado should consider strengthening its data mandate to eliminate the funding contingency for core safety and outcome metrics, drawing on Oregon’s model.

E. NMAB Meeting Transparency

Colorado’s Natural Medicine Advisory Board meetings are public meetings subject to the Colorado Open Meetings Law (§ 24-6-401 et seq., C.R.S.). Board meeting calendars, agendas, and materials are published on DORA’s website.³³ This standard public meeting infrastructure provides baseline procedural transparency.

IV. New Mexico Medical Psilocybin Program: Transparency Assessment

A. Current Status

New Mexico’s Medical Psilocybin Advisory Board held its inaugural public meeting on December 5, 2025, at which New Mexico Department of Health (NMDOH) experts presented program development plans and a draft of operational procedures.³⁴ The meeting was conducted virtually with public participation opportunities. State Senator Jeff Steinborn attended as the bill’s co-sponsor, establishing a model of legislative engagement with the oversight board that could be formalized going forward.

New Mexico’s Medical Psilocybin Act (SB 219) requires the NMDOH to promulgate rules for data collection and to publish an annual assessment of the program — transparency obligations embedded in the enabling legislation rather than added through subsequent rulemaking, creating obligations that are more resistant to administrative dilution than agency-created disclosure policies.³⁵

B. Research Fund Transparency Implications

The Medical Psilocybin Act establishes both a medical psilocybin research fund and a medical psilocybin treatment equity fund, and appropriates funds to each.³⁶ Publicly funded research creates inherent transparency obligations: research findings, methodology, adverse event data, and outcome metrics collected under state-funded studies are presumptively public records under New Mexico’s Inspection of Public Records Act (§ 14-2-1 et seq., NMSA 1978).³⁷ The research fund structure thus creates a natural pipeline from program data collection to public scientific reporting — a feature that Oregon and Colorado did not build into their initial program designs.

V. Comparative Analysis: Cannabis Regulatory Transparency Benchmarks

A. New Jersey Cannabis Regulatory Commission

The New Jersey Cannabis Regulatory Commission (NJ-CRC) provides an instructive transparency model for public meeting governance. NJ-CRC meetings are open to the public and feature detailed published agendas that include numbered resolutions identifying specific licensing decisions, regulatory changes, and enforcement actions.³⁸ Members of the public may register to speak or submit written comments. The CRC publishes annual recommendations to the Legislature on allocations from the Social Equity Excise Fee, creating a statutory annual report requirement that drives regular program assessment.³⁹

The level of resolution-specific public meeting documentation at NJ-CRC — in which each licensing approval, enforcement action, and waiver is identified by number and published with supporting memoranda — far exceeds the documentation level of any state psilocybin program advisory board. This model is transferable to psilocybin program oversight bodies.

B. New York Office of Cannabis Management

New York’s Cannabis Control Board meeting records provide another transparency benchmark: board meeting agendas list each individual enforcement decision under appeal, with decision numbers that enable public tracking.⁴⁰ This granular enforcement decision transparency — in which each administrative appeal is publicly identified, tracked, and resolved with a published determination — creates accountability at the individual case level rather than only at the aggregate annual report level.

C. California DCC Advisory Committee

California’s Cannabis Advisory Committee (CAC) holds meetings that are live-streamed and open to the public without registration.⁴¹ CAC meetings include public comment periods after each agenda item, creating structured opportunities for specific substantive input rather than only general comment periods. The CAC meeting framework enables California DCC to receive ongoing stakeholder input on regulatory changes — including proposed laboratory testing regulation updates and labeling standards — in a public forum that creates a contemporaneous record of stakeholder positions and agency responses.⁴²

VI. Model Transparency Framework for Psychedelic Regulatory Agencies

Based on the foregoing analysis of existing programs and cannabis regulatory benchmarks, the following twelve elements constitute a model transparency framework for state psychedelic regulatory agencies.

Element 1: Statutory Annual Assessment. The enabling statute should require the administering agency to publish an annual assessment of program performance, including licensee statistics, compliance actions, adverse events, demographic access patterns, and financial performance. The New Mexico Medical Psilocybin Act’s annual assessment requirement is a model.

Element 2: Quarterly Data Dashboard. The agency should publish a quarterly data dashboard on an accessible public website, containing at minimum: current licensing status by category; compliance actions (violations, suspensions, revocations) by quarter; adverse event data; product sales data (for supply chain programs); and client/patient demographic data in de-identified aggregate form. Oregon’s SB 303 dashboard is the current best practice model.

Element 3: Downloadable Open Data. All dashboard data should be available for download in machine-readable formats (CSV or Excel), enabling independent analysis by researchers, journalists, and the public. Oregon’s Data Archive provides this capability.⁴³

Element 4: Complaint Registry. The agency should publish quarterly complaint statistics — total complaints received, complaints by category, complaints resolved, and average processing time — without identifying individual complainants or respondents. This is the most significant current gap in Oregon’s transparency framework.

Element 5: Inspection Activity Report. The agency should publish an annual inspection activity report specifying the number of inspections conducted, the percentage that were announced vs. unannounced, findings categories, and follow-up actions. Health Canada’s annual Cannabis Inspection Data Summary provides a model.⁴⁴

Element 6: Financial Transparency. The agency should publish annual budget summaries including fee revenue, expenditures by function, and any taxpayer subsidy, enabling assessment of program financial sustainability.

Element 7: Open Rulemaking with Accessible Participation. All rulemaking processes should include public hearing opportunities with language access (at minimum Spanish interpretation), visual interpretation (ASL), and captioning, consistent with Oregon’s current RAC and public hearing practices.

Element 8: Published Final Orders. All final licensing and enforcement decisions should be published on the agency website and maintained in a searchable archive. Oregon’s Data Dashboard “Final Orders” page and California DCC’s disciplinary actions database are models.

Element 9: Open Meetings for Advisory Bodies. All advisory boards and councils should conduct meetings subject to state open meetings laws, with advance public notice, published agendas, recorded proceedings, and published minutes. Resolution-level documentation, as practiced by the NJ-CRC, provides the most granular accountability.

Element 10: Public Records Compliance Infrastructure. The agency should publish a public records request process on its website, designate a public records officer, and publish annual statistics on records request volume and response times — consistent with Oregon’s statutory five-business-day acknowledgment and ten-business-day response completion requirements.⁴⁵

Element 11: Independent Research Data Sharing. SB 303-type requirements for data sharing with an independent academic institution provide external validation of agency-reported data. New Mexico’s research fund structure creates a similar incentive for external scientific engagement with program data.

Element 12: Whistleblower Complaint Mechanism. A confidential complaint mechanism for agency staff, licensees, and members of the public — with statutory whistleblower protections for complainants — provides a transparency channel for information that may not surface through formal inspection or reporting systems. Oregon’s Whistleblower Protection Act (ORS 659A.199–659A.236) already protects OPS staff from retaliation; the recommended mechanism extends analogous protection to licensees, clients, and members of the public who are not covered by the existing employee-focused statute.

Implementation Sequence. For states launching new programs, Elements 2 (quarterly dashboard), 8 (published final orders), and 9 (open meetings) should be enacted at program launch through statute — they require the least infrastructure and create the most immediate accountability. Elements 1 (annual assessment), 4 (complaint registry), and 5 (inspection activity report) should be implemented by the end of the first full year of operation through rulemaking. Elements 3 (open data downloads), 10 (public records infrastructure), and 11 (research data sharing) should be in place within two years. Elements 6 (financial transparency), 7 (accessible rulemaking), and 12 (whistleblower mechanism) require legislative action and should be included in the program authorization statute or a year-two amendment.

VII. The Transparency-Privacy Tension in Psychedelic Regulation

Psychedelic regulatory programs generate data about individuals in particularly sensitive circumstances — persons seeking mental health support, processing trauma, or confronting end-of-life distress. The tension between program transparency and client privacy is therefore more acute in psychedelic regulation than in most other regulated industries.

The SB 303 framework attempts to navigate this tension through a multi-layer design: individual client records remain with licensed service centers and are not transmitted to OPS; data transmitted to OPS is de-identified and aggregated by service center and quarter before transmission; and OPS applies additional small-cell suppression before public publication (recoding values too small to report confidentially as “-99” in downloadable files).⁴⁶

This framework is generally sound, but it has limitations. The opt-out mechanism — which allows clients to decline data submission — introduces selection bias that may undermine the demographic representativeness of the data. Clients who are most concerned about privacy, including those who are government employees, professionals subject to licensing requirements, or individuals from communities historically harmed by drug law enforcement, may disproportionately opt out, creating a systematic gap in program equity monitoring.

Federal Law Enforcement Access Risk. The most serious privacy risk facing Oregon’s SB 303 data architecture is not internal misuse or accidental breach — it is the possibility that federal law enforcement agencies could seek access to SB 303 data through federal legal process that operates entirely outside Oregon’s public records law framework. SB 303 collects sexual orientation, gender identity, income, health status, and county of residence from participants in a program involving a Schedule I controlled substance under federal law. DEA agents investigating a licensed service center could seek SB 303 records through a federal administrative subpoena under 21 U.S.C. § 876, which authorizes the DEA to subpoena records relevant to a controlled substances investigation. FBI agents could seek records through grand jury subpoena. National security letters issued under 18 U.S.C. § 2709 could compel disclosure of certain records without notice to OHA or to affected clients, and without the opportunity for judicial review that accompanies a conventional subpoena.

Oregon’s public records law (ORS Chapter 192) governs OHA’s response to state-level records requests but does not shield state agencies from valid federal legal process. The Oregon Attorney General’s public records exemptions catalog (ORS 192.355) contains no exemption for records related to federally controlled substances. A federal court order directing OHA to produce SB 303 data would be enforceable regardless of Oregon’s disclosure preferences. The series’ earlier article on Public Records Transparency in Cannabis Agencies documents how federal agencies have used FOIA exemptions and deliberative process privilege to control the flow of regulatory information in cannabis contexts; the analogous risk in psilocybin regulation runs in the opposite direction — federal compelled disclosure flowing from state agencies to federal authorities — and is unaddressed in any existing OPS policy document.

OPS should publish written protocols governing its response to federal legal demands for SB 303 data, specifying: (1) the legal standards it will apply before complying with or contesting a federal demand; (2) whether and how it will notify affected clients of federal demands for their data; and (3) whether it will seek Oregon legislative authority to resist compelled federal disclosure to the extent constitutionally and legally available. States currently designing psilocybin programs should consider whether data collected under SB 303-type mandates should be held by a university or independent research entity rather than a state agency, to reduce the state’s profile as a federal data custodian for a Schedule I program.

A potential improvement to the opt-out mechanism would be a two-track system, which would require redesigning the SB 303 data submission architecture at both the service center and OPS levels. Under current rules, a client who opts out prevents their data from being included in the service center’s quarterly aggregated submission to OPS. A redesigned system would distinguish between: (a) opt-out from identifying information at the service center level, while still permitting de-identified data points (age range, county, adverse event indicator) to be included in the quarterly aggregation; and (b) full opt-out from all data submission. This structure would require OHA rulemaking to redefine what constitutes a complete opt-out under ORS 475A.372 and would need legislative authorization if the statutory language is read to permit only a single opt-out category.

VIII. Conclusion

The transparency architecture of state psychedelic programs reflects a genuine commitment to proactive public disclosure — most fully realized in Oregon’s SB 303 Data Dashboard, which is the most comprehensive public data system associated with any regulated drug program in the United States. Colorado and New Mexico are at earlier stages of transparency infrastructure development, but both have embedded meaningful statutory transparency obligations into their program designs.

The principal gaps across all three programs are: complaint processing transparency; inspection activity reporting; and financial performance disclosure. These gaps are addressable through targeted rulemaking or legislative action. The model framework in Section VI provides a comprehensive template that any state designing or reforming a psychedelic regulatory program can adapt.

The experience of cannabis regulation — particularly the accountability failures documented in the Massachusetts Cannabis Control Commission and California Department of Cannabis Control audits — demonstrates that transparency is not a luxury add-on to regulatory programs. It is a core component of the institutional infrastructure that makes programs function well and earns public trust. In a regulatory domain as politically sensitive as psychedelic services, that trust is essential to long-term program viability.

Endnotes

¹ Massachusetts Office of the State Auditor, Audit of the Cannabis Control Commission (July 1, 2022 – June 30, 2024), released Aug. 14, 2025, https://www.mass.gov/audit/audit-of-the-cannabis-control-commission-0; California State Auditor, Department of Cannabis Control: It Has Not Established an Adequate Compliance Inspection Program or Managed Its Grant Program Effectively, Report 2024-105 (June 2025), https://www.auditor.ca.gov/reports/2024-105/.

² Oregon Senate Bill 303 (2023), codified at ORS 475A.372 and ORS 475A.374; Oregon Health Authority, Oregon Psilocybin Services Publishes Interactive Data Dashboard (June 2025), https://www.oregon.gov/oha/ERD/Pages/Oregon-Psilocybin-Services-publishes-interactive-data-dashboard.aspx.

³ Oregon Health Authority, Oregon Psilocybin Services Data Dashboard, https://www.oregon.gov/oha/ph/preventionwellness/pages/psilocybin-data-dashboard.aspx (“All data that come from this system in the dashboard reflects the current status as seen internally and externally by applicants and licensees”).

⁴ Oregon Health Authority, OPS Data Dashboard, supra note 3 (compliance page publishes OPS final orders for license denials and administrative violations); see also OPS 2024 Summer Newsletter, Oregon Health Authority (June 21, 2024), https://content.govdelivery.com/accounts/ORDHS/bulletins/3a34836.

⁵ Psychedelic Alpha, Oregon Psilocybin Services Tracker: Q1 2025 (Oct. 2025), https://psychedelicalpha.com/news/oregon-psilocybin-services-tracker-q1-2025 (13 total emergency service reports since program launch through Q3 2025).

⁶ Psychedelic Alpha, The Oregon Psilocybin Services Tracker (Q3 2025 update), https://psychedelicalpha.com/data/the-oregon-psilocybin-services-tracker (product price trend from approximately $85 per product in 2023 to estimated approximately $50 by mid-2026).

⁷ Oregon Health Authority, Oregon Psilocybin Services – Senate Bill 303 and Data Collection Information, https://www.oregon.gov/oha/ph/preventionwellness/pages/psilocybin-sb303-and-data-collection.aspx.

⁸ Id.; Oregon House Bill 2387 (2025), enrolled version, see The Marijuana Herald, Oregon House Unanimously Approves Bill Expanding Psilocybin Access and Oversight (Apr. 15, 2025), https://themarijuanaherald.com/2025/04/oregon-house-unanimously-approves-bill-expanding-psilocybin-access-and-oversight/ (HB 2387 added veteran status to required data collection elements).

⁹ Oregon Health Authority, Oregon Psilocybin Services Data Archive, https://www.oregon.gov/oha/PH/PREVENTIONWELLNESS/Pages/Psilocybin-Data-Archive.aspx (downloadable quarterly Excel files available for Q1–Q3 2025).

¹⁰ Or. Rev. Stat. § 192.314(1); Oregon Dep’t of Justice, A Quick Reference Guide to Oregon’s Public Records Law, https://www.oregon.gov/pra/Documents/Open-Oregon-Public-Records-Guide-2019.pdf.

¹¹ Or. Rev. Stat. § 192.314(1); see Oregon Dep’t of Justice, supra note 10 (“any natural person, corporation, partnership, firm, association or member or committee of the Legislative assembly” may make a request; requestor’s identity or purpose does not matter at the outset).

¹² Or. Rev. Stat. § 192.324 (five-business-day acknowledgment deadline); Or. Rev. Stat. § 192.329(5) (public body shall complete its response or provide a written estimated completion date within ten business days of the date by which it was required to acknowledge the request), https://www.oregonlegislature.gov/bills_laws/ors/ors192.html.

¹³ Oregon Dep’t of Justice, Public Records Exemptions Catalog, https://justice.oregon.gov/PublicRecordsExemptions/.

¹⁴ Oregon Health Authority, SB 303 and Data Collection, supra note 7 (“Service centers are required to create and maintain practices and procedures for storing and maintaining records on the licensed premises in a manner that prevents unauthorized access, protects client privacy, and prevents alteration of client records”).

¹⁵ Or. Rev. Stat. § 244.050 (Oregon Government Ethics Commission financial disclosure requirements for public officials); Or. Rev. Stat. § 244.040 (prohibition on use of public position for personal gain); Oregon Government Ethics Commission, Financial Disclosure Statements, https://apps.oregon.gov/OGEC/EDS/ (publicly searchable disclosure database).

¹⁶ Oregon Health Authority, Oregon Psilocybin Services – 2024 Rulemaking, https://www.oregon.gov/oha/ph/preventionwellness/pages/psilocybin-2024-rulemaking.aspx (RAC meetings and public hearings conducted with Spanish interpretation, ASL interpretation, and CART captioning).

¹⁷ Id. (recordings of RAC meetings published on OHA website).

¹⁸ Oregon Health Authority, Oregon Psilocybin Services – Administrative Rules, https://www.oregon.gov/oha/ph/preventionwellness/pages/psilocybin-administrative-rules.aspx; Or. Rev. Stat. §§ 192.610–192.690 (Oregon Public Meetings Law).

¹⁹ The Marijuana Herald, supra note 8 (describing HB 2387’s restructuring of OPAB to nine members with revised composition requirements).

²⁰ OPS 2024 Summer Newsletter, supra note 4 (“OPS is hosting annual public listening sessions for members of the public to share feedback on the ongoing administration of the Oregon Psilocybin Services Act”).

²¹ Harris Sliwoski LLP, Oregon Psilocybin: State of the State (2024) (Dec. 27, 2024), https://harris-sliwoski.com/psychlawblog/oregon-psilocybin-state-of-the-state-2024/; Willamette Week, Oregon’s Psychedelic Service Centers Are Closing Amid High Costs and Tough Regulation (June 3, 2025), https://www.wweek.com/news/2025/06/03/oregons-psychedelic-service-centers-are-closing-amid-high-costs-and-tough-regulation/ (no general fund appropriation for OPS enacted for 2025–27 biennium; program dependent solely on fee revenue).

²² Colorado Department of Natural Medicine, Natural Medicine Division Newsroom, https://dnm.colorado.gov/natural-medicine-division-newsroom (weekly-updated license table and licensing status information).

²³ Colorado Department of Regulatory Agencies, Colorado Natural Medicine Homepage, https://dpo.colorado.gov/NaturalMedicine.

²⁴ Colorado Department of Natural Medicine, Rulemaking, https://dnm.colorado.gov/rulemaking (describing public rulemaking meetings conducted March through July 2024).

²⁵ Id. (Division “coordinated closely with the Natural Medicine Advisory Board (NMAB) and our partners at the Department of Regulatory Agencies (DORA)” during rulemaking).

²⁶ Id. (“All DOR Natural Medicine Division rulemaking materials may be found in the Division’s Public Resources Folder-Rulemaking Materials”).

²⁷ Colorado Office of the Secretary of State, Code of Colorado Regulations, https://www.coloradosos.gov/CCR/GenerateRulePdf.do?ruleVersionId=11721 (Code of Colorado Regulations; regulations published twice monthly in the Colorado Register).

²⁸ Colorado Department of Natural Medicine, Compliance Tools, https://dnm.colorado.gov/compliance-tools (guidance documents, inventory tracking forms, waste tracking logs, and transport manifests).

²⁹ Colorado Department of Natural Medicine, Rulemaking, supra note 24 (“The Division accepts comments on the rules throughout the year, even if there is not an open rulemaking proceeding”).

³⁰ Colorado Department of Natural Medicine, Compliance Tools, supra note 28 (Bulletins & Compliance Tips folder including guidance on licensed premises compliance, transportation, and transfer procedures).

³¹ Colorado Senate Bill 25-297, Implementation of Colorado Natural Medicine Initiative (signed June 3, 2025), https://leg.colorado.gov/bills/SB25-297 (directing CDPHE, in coordination with DOR and DORA, to collect data on law enforcement incidents, adverse health events, healthcare facility impacts, consumer protection claims, and behavioral health outcomes related to natural medicine use).

³² Id. (database operation subject to available appropriations; data collection contingent on gifts, grants, or donations from parties without financial interest in outcomes; database scheduled to repeal September 1, 2030, subject to sufficiency-of-funding review before repeal).

³³ Colorado Department of Regulatory Agencies, Colorado Natural Medicine Homepage, supra note 23 (board meeting calendar includes DOR, DORA, and CDPHE meetings with published agendas and materials).

³⁴ Source New Mexico, New Mexico Health Officials Aim to Kick Off Medical Psilocybin Program a Year Early (Dec. 8, 2025), https://sourcenm.com/2025/12/08/new-mexico-health-officials-plan-to-kick-off-medical-psilocybin-program-a-year-early/ (inaugural Medical Psilocybin Advisory Board meeting held December 5, 2025, conducted virtually with public participation).

³⁵ New Mexico SB 219, Medical Psilocybin Act (signed Apr. 7, 2025), § 7(D) (requiring NMDOH to “promulgate rules for the collection of data . . . and publish an annual assessment of the program”), full text at https://www.nmlegis.gov/Sessions/25%20Regular/bills/senate/SB0219.HTML.

³⁶ New Mexico SB 219, supra note 35, § 14(B)–(C) (establishing medical psilocybin research fund and medical psilocybin treatment equity fund; appropriating $1 million each to each fund for fiscal year 2026 and subsequent fiscal years); see also New Mexico Department of Health, Medical Psilocybin Program, https://www.nmhealth.org/about/mcpp/mpp/.

³⁷ New Mexico Inspection of Public Records Act, §§ 14-2-1 et seq., NMSA 1978.

³⁸ New Jersey Cannabis Regulatory Commission, Public Meetings, https://www.nj.gov/cannabis/about/meetings/ (meeting agendas with numbered resolutions identifying each licensing decision, enforcement action, and regulatory change; members of public may register to speak or submit written comments).

³⁹ New Jersey Cannabis Regulatory Commission, Homepage, https://www.nj.gov/cannabis/ (Social Equity Excise Fee annual recommendation reports published June 2025, May 2024, February 2023, and June 2022).

⁴⁰ New York Office of Cannabis Management, Cannabis Control Board Meetings, https://cannabis.ny.gov/cannabis-control-board-meetings (meeting agendas identifying individual enforcement appeals by inspection and decision number).

⁴¹ California Department of Cannabis Control, CAC Meeting Agenda: 9/19/2024, https://www.cannabis.ca.gov/posts/cac-meeting-agenda-9-19-2024/ (“CAC meetings are live-streamed and open to the public. No registration is required.”).

⁴² California Department of Cannabis Control, Cannabis Advisory Committee: 11/21/2024, https://www.cannabis.ca.gov/posts/cannabis-advisory-committee-11-21-2024/ (describing public comment periods after each agenda item, closed captioning, and virtual participation options).

⁴³ Oregon Health Authority, Oregon Psilocybin Services Data Archive, supra note 9 (downloadable quarterly Excel files with small-cell suppression applied).

⁴⁴ Health Canada, Compliance and Enforcement Report: Cannabis Inspection Data Summary 2024–2025, https://www.canada.ca/en/health-canada/services/drugs-medication/cannabis/research-data/compliance-enforcement-report-cannabis-inspection-data-summary/2024-2025.html (889 total inspections conducted April 1, 2024 – March 31, 2025; 37 non-compliant inspection reports issued; 2 warning letters; 50 registrations revoked or refused).

⁴⁵ Or. Rev. Stat. §§ 192.324 and 192.329(5); Oregon Dep’t of Administrative Services, DAS Improves Public Records Request Process (2024), https://apps.oregon.gov/oregon-newsroom/OR/DAS/Posts/Post/das-improves-public-records-request-process (describing GovQA platform for public records request management).

⁴⁶ Oregon Health Authority, OPS Data Dashboard, supra note 3 (values too small to report without risk of identifying individuals are recoded as “-99” in downloadable data files to protect client privacy).