Statement to the FDA
on the Future of Psychedelic Therapy

Sage Integrative Health Co-Founder and Clinical Director Genesee Herzberg, PsyD, recently offered public comment to the U.S. Food and Drug Administration as part of its public hearing on the potential future therapeutic use of psychedelic drugs in supervised and supportive settings.


Below is the statement she offered to the FDA, followed by a client narrative included in her written testimony on the role of consensual therapeutic touch in psychedelic therapy.

Statement from Genesee Herzberg, PsyD:

"I'm Genesee Herzberg, co-founder of Sage Integrative Health, Alchemy Community Therapy Center, and the Psychedelic Therapy Alliance. I have financial interests in psychedelic therapy training and clinical care.


I'm speaking on behalf of the leadership of the Psychedelic Therapy Alliance, a professional association of experienced psychedelic therapists, researchers, trainers, and supervisors who have collectively delivered tens of thousands of hours of psychedelic-assisted therapy in clinical trials and real-world practice.


I'd like to make three points:

  • Skilled therapeutic support is essential to safe and effective psychedelic therapy.

    Our collective experience tells us that a trained, skilled therapist or guide is essential to safe and effective psychedelic therapy.


    We're concerned about the movement toward removing the therapist from treatment. Recent research has relabeled therapists as "dosing session monitors," yet they are required to be licensed clinicians and rely on their therapeutic training.


    We urge the FDA to proceed with caution before allowing these medicines to be dispensed without a competent guide present.

  • Therapeutic touch must remain available to those who need it.

    Therapeutic touch must remain available to those who need it. Not everyone requires touch, but for some it is foundational to healing.

    We are appalled by the ethical violations and sexual misconduct by several prominent psychedelic therapists — including one in MAPS' Phase 2 research — and we share the concern that this could recur as the field grows.

    At the same time, we don't believe it's ethical to categorically deny a client's request for a hand to hold while processing trauma. In these vulnerable states, refusing all physical comfort can be experienced as abandonment.

    Rather than ban touch outright, we recommend a certifying body requiring every guide to complete training in ethics, consent, power dynamics, and therapeutic touch. And ongoing consultation.
  • Psychedelic therapy should allow for individualized care.
    Many protocol elements — including dose, session frequency, treatment length, and total number of sessions — were standardized for the needs of controlled trials.

    In real-world practice, these should be decided case by case, not locked into a rigid protocol. These decisions should rest with treating practitioners, not be dictated by trial sponsors.
  • The following client narrative was included in Genesee's written statement to the FDA. It speaks to both dimensions of therapeutic touch that matter deeply in psychedelic care: the ability to receive consensual physical support when it is wanted, and the ability to meaningfully say no when it is not:

    "There are a few things I think about when I consider touch in psychedelic therapy and how it’s impacted me. The first is the number of times I’ve been in a really hard, scary, terrified place, and your presence and touch has given me safety, helping me to not feel abandoned in the feelings. Without it in those moments, it would have been re-traumatizing versus what it was – a moment of repair and care and real connection that really mattered, and has really shifted things for me.

    I also think touch has helped me reach places I otherwise have trouble reaching. There’s something about a hand to my heart or forehead that opens channels to places that otherwise seem unreachable.

    And then also, I've had so many moments where a place in me has a boundary and says “stay away” or doesn’t want touch, and I don't know that it would feel the same if touch were not allowed. If it’s already not available to me, then me having a boundary around not wanting it doesn’t feel the same. …I’ve learned so much and grown so much – so many parts of me, especially young parts, have learned through this work that my consent matters. And that’s huge, that’s a huge learning process for these parts that didn’t otherwise learn that. If it were just an automatic, touch isn’t allowed, then that boundary doesn’t feel like it would matter so much.  It doesn’t really mean anything if there’s a rule around it. To not have control over it – being able to set my own boundaries knowing I get to ask for it and also I get to reject it – that’s a big piece of it for me.

    I think touch is huge for me in so, so many ways. I can't imagine having experienced the work that I've done without it."
WATCH THE HEARING:

FDA Public Hearing on the Therapeutic Use of Psychedelic Drugs

The U.S. Food and Drug Administration (FDA) held a public hearing on the potential future therapeutic use of psychedelic drugs in supervised and supportive settings. Sage Integrative Health Co-Founder and Clinical Director Genesee Herzberg, PsyD, offered public comment on behalf of the leadership of the Psychedelic Therapy Alliance, addressing the role of trained therapists and guides, therapeutic touch and consent, and the importance of individualized care in psychedelic therapy.
Made on
Tilda