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Project Entheos
REV 0.1

REV 0.1·WORKING DRAFT·JULY 2026·OPEN FOR COMMENT

ProjectEntheos

A community-authored standard for psychedelic wraparound care.

Not a product. A standard.

Written with the practitioners who have kept these medicines alive for thirty years. Offered to every sponsor running a trial — sold to none of them.

Fluence convenes this work. Fluence does not own it — see §07.


Why now

Psychedelic medicine has arrived at pharmaceutical scale. The expertise it is going to need accumulated somewhere else entirely.

$2.8B

Eli Lilly

AtaiBeckley

$1.2B

Otsuka

Transcend

$1.2B

AbbVie

Gilgamesh compound

Three acquisitions · roughly twelve months

Three acquisitions inside roughly a year moved psychedelic drug development from venture scale to pharmaceutical scale. None of the acquiring companies has run a psychedelic trial before.

The FDA has finalised clinical trial guidance for psychedelic drug developers and scheduled a public hearing — Considerations for Potential Future Therapeutic Use of Psychedelic Drugs — for 14 September 2026 at White Oak. Nothing in that process resembles a formal channel to the practitioners who have handled these experiences outside the clinic for three decades.

The field already has a record of what that costs. In 2024 the FDA declined to approve MDMA-assisted therapy for PTSD; the Complete Response Letter, made public in September 2025, cited problems with safety reporting and trial blinding tied to underestimating participant psychology and enthusiast bias at trial sites. The sponsor lost years. This is not a story about bad actors. It is a story about a category of expertise that was not in the room.

Pharma has never run a psychedelic trial before. The people with real expertise here are the ones the industry currently distrusts.
Project Entheos — working draft

This is not a blank page

There is no federal body making recommendations on wraparound care for regulated psychedelic medicine. But the standards work itself has been underway for thirty years — written down, published, and voluntarily adopted, largely outside federal attention.

  1. 1995

    Council on Spiritual Practices

    Code of Ethics for Spiritual Guides

    Written for underground facilitators and voluntarily adopted by guides for three decades. Covers intention, informed consent, tolerance, and peer review among guides. Every code below descends from it.

  2. 2021

    MAPS

    Code of Ethics for Psychedelic Psychotherapy

    Built directly on the CSP code and adapted for clinical psychedelic-assisted psychotherapy settings. Revised 2022.

  3. 2022

    Psychedelic Association of Canada

    Code of Ethics for guides

    Informed consent, scope of competence, and peer review of misconduct.

  4. 2023

    Oregon Health Authority

    Psilocybin Advisory Board

    The only working example of a regulator with a statutory practitioner and community advisory body. Oregon law requires the OHA to seat facilitators and service providers on a board that makes binding recommendations on rules and licensing.

    The precedent to generalise

  5. 2024

    JAMA Network Open

    Ethics and policy framework consensus statement

    “Developing an Ethics and Policy Framework for Psychedelic Clinical Care.” Peer-reviewed, and therefore citable in an FDA submission.

  6. 2026

    Project Entheos

    The Code of Reciprocal Care

    In draft. Open for comment.

Independent research with underground practitioners keeps surfacing the same four working priorities: reciprocity over extraction, equitable access, trauma-informed screening, and dedicated preparation and aftercare. The task is not to invent a standard. It is to bring one that already exists into a regulatory process that has no way to hear it.


How it is being built

Guiding principle

Not a Fluence product. A standard, co-authored by the community, that Fluence convenes and stewards in a secretariat role — closer to how a consensus-standards body works than to how a vendor sells a service.

  1. Founding Circle

    Now → September 2026

    Four to six trusted voices from peer-support, harm-reduction and Indigenous-reciprocity practice, convened quickly enough to have a real voice ahead of the September hearing. A seed for the council, not a substitute for it.

  2. Advisory Council

    Q4 2026 onward

    The full governance body: compensated seats for peer-support organisations, Indigenous reciprocity representatives, independent harm-reduction voices, and clinical and academic advisors. Paid seats with real authority to set standards — not an advisory panel in name only.

  3. The Code of Reciprocal Care

    Q1 2027 onward

    The standard itself: wraparound service requirements, reciprocity and benefit-sharing commitments, screening and aftercare protocols. Co-authored by the council, published openly, and referenced the way a practice standard is referenced — not licensed, not sold.


Draft service principles

A first draft, grounded in the models above. It is meant to be argued with and substantially rewritten by the Founding Circle and the Advisory Council — not delivered to them as something already decided.

Every clause below is open. Annotate any one of them and the response is recorded against that clause, so the council can see where the disagreement actually is.

  1. Annotate

    Embedded peer support

    Peer support specialists embedded in trial protocols alongside clinical staff, with standing equivalent to other trial personnel.

    BasisFireside Project and Zendo Project models

  2. Annotate

    Integration circles, not only follow-up

    Group integration circles after dosing, in addition to individual therapy follow-up rather than instead of it.

    BasisTHRIVE and EMBARK frameworks; underground integration-circle practice

  3. Annotate

    A harm-reduction line between sessions

    A harm-reduction-trained on-call line available to participants between scheduled sessions.

    BasisFireside's peer support line has handled more than 35,000 calls; roughly two-thirds of callers report de-escalating from distress

  4. Annotate

    Trauma-informed screening before dosing

    Trauma-informed screening protocols conducted before dosing, by staff trained to conduct them.

    BasisDocumented underground practitioner priorities

  5. Annotate

    Reciprocity where the medicine comes from

    A reciprocity and benefit-sharing commitment for any compound with Indigenous-medicine origins.

    BasisChacruna's Indigenous Reciprocity Initiative

  6. Annotate

    Facilitator training standards

    Facilitator training standards adapted from an existing licensing framework for clinical-trial contexts.

    BasisOregon's psilocybin facilitator licensing framework

The wraparound pathway

What the six clauses amount to, in the order a participant meets them.

35,000+

Calls handled by Fireside's peer support line

Roughly two-thirds of callers report de-escalating from distress.


September 14

The FDA is taking public comment on how psychedelic drugs should be regulated. We intend to be in it — and not on our own.

  1. 21 AUG2026

    Deadline to request an oral presentation slot

  2. 14 SEP2026

    Public hearing · FDA White Oak · hybrid

  3. 05 OCT2026

    Deadline for written comments

What the comment will say

  1. Name the gap. No federal mechanism brings practitioner or community expertise into psychedelic drug regulation, unlike Oregon's statutory advisory board.

  2. Name the risk. The 2024 Complete Response Letter shows what trial design costs when it underestimates participant psychology and community dynamics.

  3. Name the expertise. Three decades of harm-reduction and integration practice, documented in published ethics codes and in peer-reviewed research on peer support and integration outcomes.

  4. Recommend. That the FDA convene or formally recognise a practitioner and community advisory mechanism comparable to Oregon's, and treat wraparound and peer-support services as part of the safety case for approval rather than an optional addition.

Not yet filed

This outline has not been submitted. It needs review by the Founding Circle members whose credibility it would draw on, and by regulatory counsel, before anything is filed.

Phased implementation

Sequence matters here more than speed. Real outreach precedes public messaging at every phase.

  1. 0Now – Oct 2026

    Founding Circle & FDA filing

    • Convene the Founding Circle
    • Draft and submit the FDA comment
    • Publish this page
  2. 1Q4 2026 – Q1 2027

    Advisory Council formation

    • Formalise compensated council seats
    • Write a governance charter
    • Expand outreach beyond the Founding Circle
  3. 2Q1 – Q2 2027

    Code of Reciprocal Care, draft

    • Co-author the standard with the council
    • Pressure-test it against a live trial
  4. 32027, pegged to NDA timelines

    Pilot

    • Apply the Code with one active pharma partner trial
  5. 4Following a successful pilot

    Publish & scale

    • Publish the standard openly
    • Invite industry-wide adoption beyond any one convener's clients

Where this stands

Everything on this page is provisional. It is worth being exact about which parts, and why.

  1. The Founding Circle has not been named.

    Nobody has agreed to a seat yet. Nothing here should be read as the community speaking. It is one convener's opening draft, published so that it can be argued with in the open rather than settled in private.

  2. Seats are compensated.

    Community and harm-reduction advisors are paid for their time from the first meeting. Asking people to donate expertise to a process that pharmaceutical sponsors pay to participate in would reproduce the extraction this standard exists to prevent.

  3. Fluence holds pharmaceutical contracts.

    Fluence, which convenes this work, has commercial relationships with sponsors running psychedelic trials. We are stating that rather than managing around it. The governance charter will set out how those relationships are disclosed and firewalled from the council's authority.

  4. The principles are a draft, not a decision.

    The six service principles in §04 are a starting point for the council to rewrite. Comment is open on every one of them, and disagreement is the point.

  5. The facts on this page are being verified.

    Regulatory timelines, hearing procedure, and the scope of recent federal action are being independently confirmed with counsel before anything is filed with the FDA. Where we are not yet certain, this page says so rather than rounding up.


Join the founding conversation

Occasional updates, sent when something actually happens: when the Founding Circle is named, when the FDA comment is filed, and when the Code opens for public review.

Sign up on the Get Involved page →

Advisory Council seats are compensated. If you have done this work and want to be considered, say so — the form goes to a person, not a list.