M06 — Boundaries & Physical Touch · Inner EDGE Navigator · T1 + T2
iETA — Inner EDGE Navigator Training Program  ·  Module 06 — T1 + T2

Tier 1 Cover Sheet & Tier 2 Instructor Guide  ·  v1.0  ·  Student Guide (T3) delivered separately

Tier 1 Module Cover Sheet Faculty & Student Reference  ·  Regulatory Anchor
Phase 2 — Core Competencies of Facilitation Phase 2
Module 06: Boundaries & Physical Touch
The module every facilitator needs most and the one many want to rush past. Boundaries are not rules you follow — they are the structural condition that makes participant safety possible. This module builds competency in the three boundary domains (physical, emotional, digital), the Touch Contract as a living consent document, the severity spectrum from crossing to reportable violation, and the digital practices that protect participants after the session ends. The skills here directly extend M05's scope clarity and connect forward to M10's preparation protocols.
10 hrs total 7.5 sync / 2.5 async Phase 2 · v1.0
Learning Objectives By module completion
PC2 — Participant-Centered Communication & Cultural Humility PC4 — Safety & Crisis Response PC6 — Professionalism & Reflective Practice
  • 1
    Define the three boundary domains — physical, emotional, and digital — and map specific facilitator behaviors, risk zones, and bright lines within each domain. Understand CO C.1 · C.2
  • 2
    Distinguish boundary crossings from boundary violations — and identify the specific conditions that elevate a crossing to a reportable violation — using the severity framework. Analyze CO C.2 · C.4 · C.5
  • 3
    Design and deliver a complete, participant-directed Touch Contract conversation — including personalized touch preferences, capacity limitations post-ingestion, co-facilitator and recording options, and documented opt-out mechanisms. Create  Apply CO C.3 · C.8 · C.9 · B.4
  • 4
    Evaluate boundary breach scenarios for severity and determine appropriate repair steps, reporting obligations, and documentation requirements proportionate to severity level. Evaluate CO C.4 · C.5 · C.6 · B.5
  • 5
    Apply digital boundary standards — including communication channel limits, post-session contact protocols, and minimal-data documentation practices — to scope-compliant facilitation. Apply CO C.7 · J.11 · J.13
Regulatory Crosswalk CO NMTP Section C primary  ·  NV ATPP comparative
SourceCodeStandardModule Coverage
CO NMTPC.1Professional relationship boundaries — facilitator obligations to uphold relational limits in all phases of serviceL1 — primary
CO NMTPC.2Definitions, types, and risk profiles of boundary crossings versus boundary violationsL1 — primary · L3 supporting
CO NMTPC.3Introduction to the Touch Contract and participant-directed touch decision-makingL2 — primary
CO NMTPC.4Potential harm to participants from boundary and touch violationsL3 — primary
CO NMTPC.5Consequences for facilitators who breach relational boundaries — licensure, civil, and criminal exposureL3 — primary
CO NMTPC.6Consequences for facilitators who breach the Touch Contract specificallyL3 — primary
CO NMTPC.7Active monitoring of client-facilitator boundaries, specifically related to ongoing consent and touchL4 — primary
CO NMTPC.8Participant-directed discussion of Touch Contract addressing personalized boundaries, capacity limitations post-ingestion, and co-facilitator or video recording optionsL2 — primary · M10-L2 supporting
CO NMTPC.9Practical training and experience in appropriate use of touch during natural medicine facilitationL2 — primary · OSCE
iETAB.4Touch consent and Touch Contract — introduced in M02-L4, depth developed here and operationalized in M10L2 — depth layer
iETAJ.11Communication channel policies — scope-appropriate contact limits across all channelsL4 — primary
iETAJ.13Minimal-data documentation practices and data retention standards for participant recordsL4 — primary
Prerequisites & Forward Connections

Direct prerequisites: M02-L4 (informed consent and Touch Contract introduction); M05 (scope discipline under pressure). Students who have not completed M02 through M05 should not begin M06. Forward connections: Touch Contract design connects directly to M10 (Preparation), where it becomes part of the pre-session protocol. Digital boundary standards introduced in L4 connect to J.11 and J.13 compliance in M11 (Administration) and M14 (Supervision & Quality Assurance). The boundary frameworks in L1–L3 are assessed again at program exit.

⚠ Facilitator Preparation Note

Boundary content activates personal material in students — both experiences of boundary violations they've suffered and, sometimes, behavior they are not proud of. Create space for self-reflection without creating pressure to disclose. Students should know from the start of L1 that this module is about professional role clarity, not personal confession. If a student discloses something in the context of this module that suggests professional concern, the instructor must follow program protocols for supervisor consultation. This content is not ethically neutral. Teach it that way.

Module at a Glance 4 lessons + OSCE · 10 hrs total
Lesson 1
Boundary Frameworks
2.0 hrs · 1.5 sync + 0.5 async
Lesson 2
Touch Contracting & Consent Flow
3.0 hrs · 2.0 sync + 1.0 async
Lesson 3
Boundary Breaches & Repairs
2.5 hrs · 2.0 sync + 0.5 async
Lesson 4
Digital Boundaries & Data Hygiene
2.5 hrs · 2.0 sync + 0.5 async
Colorado NMTP — Section C Compliance Note

Module 06 satisfies the full Section C requirement (10 hrs) for relational boundaries and physical touch in the Colorado Natural Medicine Treatment Program. Completion of all four lessons with OSCE passage (≥70%) constitutes the documented competency evidence required for program completion records. Touch Contract practice in L2 satisfies C.3, C.8, and C.9. The OSCE performance station provides direct competency evidence for C.9. Instructors must retain all OSCE rubrics with assessor signatures per program documentation requirements.

── T1 ends  ·  T2 begins ──
Tier 2 Instructor Guide Facilitator Copy  ·  Not for Distribution  ·  All Tools Included
Module 06 — Phase 2: Core Competencies Phase 2
Boundaries & Physical Touch — Instructor Guide
Four lessons covering the three boundary domains, Touch Contract design and delivery, the crossing-to-violation severity spectrum, repair and reporting protocols, and digital boundary standards. All lesson plans, exercises, scenario card banks, Touch Contract template, and full OSCE assessor package are in this file.
10 hrs total 4 Lessons + OSCE
Tier 2 What This Module Asks of You
Module 06 · Boundaries & Physical Touch
What This Module Asks of You
The facilitators who argue most passionately against rigid boundary rules are often the ones whose participants get hurt.

Boundary content is uniquely susceptible to a particular kind of student resistance: the belief that flexibility, attunement, and relational sensitivity justify deviation from clear professional limits. This argument is not always wrong in theory — good clinical work does require flexibility. But in the boundary domain, "I felt called to respond to this participant's needs in the moment" is one of the most common explanations given in regulatory complaints and ethics hearings. Your job in this module is not to argue for rigidity. It is to make the structural case: that clear, communicated, consistently held boundaries are what make participant safety possible — not a bureaucratic obstacle to it.

Students who want to be liked, who find boundary enforcement uncomfortable, who believe that their intuition is reliable enough to override the protocol — these students are the ones who most need this module to land. Watch for the student who is very fluent with the frameworks and simultaneously finds a reason that every specific limit should have an exception. The fluency isn't the issue. The pattern is.

Before You Begin

Review CO Section C in full before teaching L1. Know the specific regulatory language for C.3, C.8, and C.9 — these will come up. If you have professional experience with a boundary-related complaint or ethics consultation, you do not have to disclose it, but you should decide in advance how much of that perspective you'll bring into the room. Lived professional experience with this content, taught from that vantage point, is unusually effective. Prepare your Touch Contract demonstration script before L2. Practice it. Students learn the consent flow by watching it modeled, not by hearing it described.

Materials Needed (All Lessons)
  • Boundary domain mapping worksheets (L1)
  • Boundary scenario sort cards — 10 cards with key (L1)
  • Touch Contract blank template (L2, one per student, also in T3)
  • Consent dialogue practice prompt cards (L2)
  • Severity spectrum reference cards (L3)
  • Breach-and-repair scenario cards — 8 scenarios with key (L3)
  • Digital boundary policy audit worksheets (L4)
  • OSCE assessor packets — 2 per station (OSCE)
Pre-Session Instructor Prep
  • Review CO Section C requirements in the Alignment Matrix
  • Prepare your Touch Contract demonstration run-through before L2 — scripted fluency matters here
  • Prepare 2+ OSCE scenario versions before the assessment window
  • Check whether any students have personal boundary violation history — confirm support resources are available
  • Identify any students in previous sessions who argued for exception-based boundary reasoning — prepare calibration for that pattern
Lesson 1 Boundary Frameworks  ·  1.5 hr sync + 0.5 hr async
Lesson 1: Boundary Frameworks
2.0 hrs total · 1.5 hr sync / 0.5 hr async  ·  CO C.1 · C.2
This lesson establishes the conceptual architecture of the entire module. Students leave with a working definition of each boundary domain, a clear distinction between crossing and violation, and a concrete map of where the professional bright lines are. The goal is not to make every student perfectly comfortable — it is to ensure every student knows exactly where the lines are, regardless of how they feel about them.
Sync Time 1.5 hours — lecture (35 min) + warm-up (10 min) + exercise (30 min) + debrief (15 min)
Materials Boundary domain mapping worksheets · Boundary scenario sort cards (10 cards + key)
Warm-Up  ·  10 min
Prompt 1 "Name one thing a facilitator could do — not necessarily something illegal, just something — that would make you unwilling to send a participant to them. Don't think too hard about it. Just name it." Collect 5–7 responses quickly. Do not sort or evaluate them yet. Write them on the whiteboard.
After collecting responses: "Everything you've named is a boundary issue. Some of them are crossings — they might be recoverable with repair. Some of them are violations — not recoverable, and reportable. Some of them are bright lines — behaviors that, if crossed once, end a facilitator's career regardless of intent. Today we build the framework that tells you which is which, and why that distinction matters."
Lecture  ·  35 min
"Boundaries exist in facilitation for exactly one reason: because the power differential between a facilitator and a participant in an altered state is among the largest power differentials that exists in any helping profession. The participant is biologically and psychologically in a state of heightened suggestibility, emotional openness, and often physical vulnerability. The facilitator is not. That asymmetry is not incidental — it is the structural condition that makes boundary clarity not just professional courtesy, but a participant safety imperative."

Begin with the three domains. A physical boundary governs what the facilitator's body does relative to the participant's body — where they sit, whether and how they touch, whether touch is within or outside the Touch Contract, what the facilitator does if a participant reaches for them without prior agreement. A relational/emotional boundary governs the nature of the relationship itself — the scope of what is offered, the communication of what can be expected, the management of dependency and attachment dynamics, the limits of self-disclosure, and the prohibition on dual relationships. A digital boundary governs communication after the session ends — what channels are used, what content is appropriate, when contact is appropriate and when it constitutes continued therapeutic engagement that exceeds facilitator scope.

These three domains are not siloed. A relational boundary erosion almost always precedes a physical boundary violation. A physical violation almost always generates a documentation problem that becomes a digital boundary problem when the facilitator tries to manage it through private messaging. Teach the domains as interconnected, not as separate checklists.

Draw a simple Venn diagram on the board: three overlapping circles labeled Physical, Relational, Digital. Ask: "Can someone give me an example of a behavior that sits in the overlap of two of these?" The goal is to get students thinking in systems rather than categories.

The distinction between a boundary crossing and a boundary violation is one of the most important distinctions in professional facilitation practice, and it is also the one most frequently misunderstood — often in self-serving ways. A crossing is a deviation from standard practice that may or may not harm the participant, that often happens in the context of a genuine attempt to serve the participant's needs, and that can often be identified, named, repaired, and documented. A crossing is not automatically a career event. A violation is a deviation that causes harm or that involves an exploitation of the power differential — most typically sexual contact, financial exploitation, or deception that benefits the facilitator at the participant's expense. Violations are not recoverable through repair. They are reportable events.

The confusion happens in the middle — in the zone that begins as a crossing and escalates to a violation through a process called boundary drift. Drift is not dramatic. It looks like: running five minutes late because the conversation felt important, responding to a text message outside session hours because it "seemed urgent," meeting for coffee to check in because the participant seemed lonely, sharing a personal story to build connection because the participant seemed to need it. Each of these decisions, individually, might be defensible. Cumulatively, they constitute the erosion of the structural container that protects the participant. The facilitator who has drifted is not always a predator. They are often someone who liked the participant, wanted to help, and made a series of small exceptions without noticing where the sequence was going. The pattern is the problem, not just the incident.

Pause here. "Turn to a partner and identify one thing on the warm-up list we made that could be either a crossing or a violation depending on context. How would you know which it was?" Give 2 minutes, then collect one or two examples in the group.

Bright lines are the behaviors that are violations regardless of context, consent, or intent. In Colorado facilitation practice, these include: any sexual contact with a participant at any phase of the professional relationship, including after the relationship has formally ended; financial transactions that benefit the facilitator outside of the agreed-upon fee structure; any deceptive representation of facilitator credentials, scope, or the nature of the service being provided; and the use of the facilitator's authority position to coerce, pressure, or manipulate participant behavior outside the service agreement. The existence of the participant's apparent consent does not eliminate the violation. Consent in a context of significant power differential — and especially with a participant who is in or has recently been in an altered state — cannot function the same way consent does between peers. The facilitator's responsibility is to hold the limit even when the participant appears to be inviting something different.

Watch For in This Lecture
  • The consent argument: "But what if the participant really wants this?" The most sophisticated version of boundary rationalization always invokes participant autonomy. The response is: autonomy is a real principle, and it operates within a structural context. The power differential in the facilitation relationship, especially in altered states, means that facilitator-initiated crossing cannot be made acceptable by participant enthusiasm.
  • The comparison argument: "Other healing modalities do this." Different scope, different regulatory context, different accountability structures. This program operates within CO NMTP requirements. Stay grounded in the regulatory framework rather than debating comparative practices.
  • Self-disclosure: Some students will disclose boundary violations they've experienced as recipients. Receive these briefly and compassionately, and redirect: "That's exactly why this framework exists — and we're going to build the tools that prevent it. Let's keep moving."
  • Drift minimization: Students who describe the drift pattern and frame each step as reasonable. Don't push back on each individual step — push back on the framing that individual-step defensibility equals cumulative-pattern acceptability.
Boundary Framework Reference Card · Instructor Reference · T3 Version in Student Guide
PHYSICAL DOMAIN  ·  Governs body-to-body proximity and contact. Includes touch, positioning, physical boundaries during administration, and the Touch Contract. The default is no uncontracted touch — not the reverse.
RELATIONAL DOMAIN  ·  Governs the nature and scope of the relationship. Dual relationships, self-disclosure limits, managing dependency and attachment, communication about what the relationship is and is not.
DIGITAL DOMAIN  ·  Governs all communication outside the session — channels permitted, response time expectations, content limits, post-service contact duration and nature.
CROSSING  ·  Deviation from standard practice. May or may not cause harm. Often well-intentioned. Identifiable, nameable, potentially repairable. Documentation required. Repeat crossings in a pattern = drift.
VIOLATION  ·  Deviation that harms the participant or exploits the power differential. Not recoverable through repair. Reportable. Career consequences. Participant's apparent consent does not eliminate the violation.
BRIGHT LINES  ·  Always violations: sexual contact at any phase · financial transactions outside agreed fee · deception about credentials or scope · coercion or manipulation using facilitator authority.
DRIFT  ·  A cumulative pattern of boundary crossings, often well-intentioned, that collectively erode the professional container. Individual-step defensibility does not equal cumulative-pattern acceptability.
Exercise  ·  30 min  ·  Boundary Scenario Sort
Boundary Scenario Sort — T2 Instructor Use Only
Individual then pairs. Students receive the 10 scenario cards (below). They classify each independently: (A) Bright-line violation — reportable · (B) Violation — non-reportable but career-significant · (C) Crossing — repairable with documentation · (D) Not a boundary issue. Then compare and reconcile with a partner. Group debrief using the key.
  1. Distribute cards. Students classify independently. 12 min
  2. Pairs compare and discuss — focus on items where you disagreed. What determined the classification? 10 min
  3. Group debrief — reveal key, focus on the contested items. 8 min
T2 Only Boundary Scenario Sort Cards — 10 Cards + Key Do not distribute to students · Instructor-led exercise
Card 01
A facilitator and participant have a meaningful connection during their third session. Three weeks after formal service ends, the facilitator texts to invite the participant to dinner "as friends." The participant says yes.
Key: B — Violation (dual relationship)Post-service contact that initiates a social relationship exploits the residual power dynamic. Participant's agreement does not eliminate the violation. Supervision required.
Card 02
During a preparation session, the facilitator shares that they have personally experienced grief and know how difficult it is. They do not describe their specific loss in detail.
Key: D — Not a boundary issueBrief, purposeful self-disclosure that normalizes participant experience without centering the facilitator is within scope. No action required.
Card 03
A participant in an active session reaches for the facilitator's hand and the facilitator holds it for approximately 90 seconds before gently releasing. Touch was not in the Touch Contract.
Key: C — Crossing (physical, outside Touch Contract)Responsive to participant, but uncontracted. Must be documented. Should be discussed in supervision. Touch Contract needs to be reviewed before next session.
Card 04
A facilitator is also a licensed massage therapist. During integration they offer the participant a "grounding massage" and both agree it is helpful. They do not document it in session notes.
Key: B — Violation (dual relationship + scope)Offering a different licensed service within the facilitation relationship is a dual role violation. Undocumented physical contact compounds the problem. Supervisor consultation required immediately.
Card 05
A participant texts the facilitator at 11pm the night before their session with a question about what to eat. The facilitator responds at 7am the next morning.
Key: C — Minor crossing (digital channel management)Response was appropriate; the issue is that no digital contact protocol has been established. Facilitator should clarify contact expectations at the next session.
Card 06
A facilitator reduces their fee for a participant who is experiencing financial hardship. They document the adjusted rate in the service agreement and note it in the session record.
Key: D — Not a boundary issueAdjusted fee with documentation and a clear service agreement is a legitimate practice decision, not a financial boundary violation. The documentation distinguishes it from exploitative financial arrangements.
Card 07
A participant in a state of strong emotional activation attempts to embrace the facilitator. The facilitator accepts the embrace and holds the participant for approximately two minutes. Touch Contract allowed shoulder-level contact only.
Key: B — Violation (outside Touch Contract)Allowing contact that exceeds the Touch Contract in response to participant initiation does not constitute consent. Full-body embrace was outside the agreed scope. Document, report to supervisor, review protocol with participant before next session.
Card 08
A facilitator tells a prospective participant that natural medicine "will cure your PTSD" and that they have "helped dozens of people completely recover."
Key: A — Bright-line violation (deception / truthful communications)This misrepresents scope, overstates efficacy, and violates CO B.7 and B.8 (truthful communications / realistic expectations). Reportable. No ambiguity about classification.
Card 09
A facilitator mentions during a preparation session that they also facilitate couples retreats and asks whether the participant's partner might be interested in services.
Key: C — Crossing (dual role solicitation)Soliciting a referral to another service within a current therapeutic relationship is a crossing. Not severe, but requires self-reflection. Facilitator should discuss this pattern in supervision.
Card 10
Following a very difficult session, a facilitator sends the participant a personalized poem they wrote for them, along with a voice note expressing how meaningful the work has been.
Key: B — Violation (relational boundary, self-disclosure, dependency cultivation)Post-session communications that express personal meaning to the facilitator and invite reciprocal response reverse the appropriate relational direction and risk cultivating dependency. Supervisor consultation required.
Debrief  ·  15 min
Debrief Questions
Which card was most contested in your pair? What made it hard to classify?
Where on the whiteboard list from our warm-up did you find bright lines? Were any of them things you initially classified as crossings?
Card 06 was "not a boundary issue" even though it involved money. What made it okay? What would have made it a violation?
If you were the supervisor for the facilitator in Card 10 — how would you approach that conversation?
Async Assignment — Due Before Lesson 2

Personal boundary inventory: Write one page addressing the following privately — this is not submitted, it is for your own use before L2. (1) In what boundary domain do you feel most confident? Why? (2) In what domain do you feel least confident, or most likely to drift? What patterns in your personal life might be relevant? (3) Review the cards from today's exercise. Were there any you classified incorrectly? What did that tell you? Bring one insight from this reflection to L2 — you will not be asked to share the specifics, but you will be asked to bring your own awareness into the Touch Contract work.

Lesson 2 Touch Contracting & Consent Flow  ·  2.0 hr sync + 1.0 hr async
Lesson 2: Touch Contracting & Consent Flow
3.0 hrs total · 2.0 hr sync / 1.0 hr async  ·  CO C.3 · C.8 · C.9 · B.4
This is the most practically complex lesson in the module. The Touch Contract is not a form — it is a conversation. Students must be able to conduct that conversation with fluency, specificity, and genuine participant-directedness. The consent dialogue roleplay is the central exercise and requires instructor modeling before student practice. Do not skip the modeling. The difference between a good consent dialogue and a compliance-checkbox performance is entirely in the quality of execution.
Sync Time 2.0 hours — lecture/demo (50 min) + consent dialogue roleplay (55 min) + debrief (15 min)
Materials Touch Contract blank templates (one per student, T3 version also included) · Consent dialogue practice prompt cards
Opening  ·  5 min
Prompt "Think of a time when someone asked for your permission in a way that made you feel genuinely heard — not asked to check a box, but actually consulted. What made it feel different?" Brief, 2–3 responses. Use it to set the frame: the Touch Contract conversation is about the second kind of asking, not the first.
Lecture & Demonstration  ·  50 min
"The Touch Contract is not a consent form. A form asks for a signature. The Touch Contract is a conversation — a participant-directed conversation in which the facilitator creates genuine space for the participant to understand what they're agreeing to, to personalize it to their actual body and their actual history, and to retain the ability to change their mind. The conversation must happen before medicine is ingested — not because the regulation requires it, but because after ingestion, the participant cannot consent in the same way. That's not a legal technicality. It is a neurological and ethical reality."

The Touch Contract has six required elements under Colorado regulation. First, participant-directed preferences: the participant specifies what types of touch they are comfortable with, in what locations on the body, and under what conditions. The facilitator does not offer a menu and ask the participant to check boxes — the facilitator opens the space and the participant defines it. Second, grounding and supportive touch options: the facilitator explains what kinds of touch are commonly offered (hand on shoulder, hand on arm, gentle pressure on upper back) and the participant indicates which, if any, feel acceptable. Third, capacity limitations post-ingestion: the facilitator explains directly that after medicine is ingested, the participant's ability to communicate and to revoke consent may be limited. This is not frightening information — it is accurate information. The facilitator also explains that they will check in verbally during the session, that the participant can say "no," "stop," or "not right now" at any time and the facilitator will honor it immediately, and that confusion or inability to respond to a check-in will be treated as a "no." Fourth, the co-facilitator option: the participant is offered the option to request a co-facilitator or second person present for any or all of the session. Fifth, the recording option: the participant is informed that some participants choose to have a video recording made of the session for their own later review or as an additional protection mechanism. Sixth, the opt-out mechanism: the participant is told clearly that the Touch Contract can be revised before the session, that the default if there is any ambiguity is no touch, and that they do not need to agree to any touch to receive the service.

Stop here. "Before I model the consent dialogue, I want you to notice what I just described. Every element of the Touch Contract begins with the participant's perspective and experience — not the facilitator's offering. The contract is participant-directed. The facilitator's role is to create the conditions in which the participant can actually access and express their own preferences — not to persuade them toward a particular arrangement."

What the Touch Contract does not include: it does not authorize full-body contact, it does not authorize sexual touch of any kind under any circumstances, it does not override a participant's capacity limitations (a participant who has ingested medicine and is in a non-verbal state has not thereby revoked their prior consent, but they also cannot actively expand it), and it does not replace ongoing verbal check-in during the session. The contract is the baseline. Ongoing attunement and check-in is the practice.

Now model the consent dialogue. The demonstration below is a scripted example — but deliver it naturally, not as a script. Students are watching for tone, pacing, and participant-directedness, not word-for-word compliance.

T2 Tool — Instructor Reference · T3 Version in Student Guide Touch Contract Conversation Guide & Template
Opening Frame (Instructor models)
"Before we talk about the medicine session itself, I want to have a conversation about touch — what it means in this context, what's available, and what feels right for you specifically. This isn't a form to fill out. It's a conversation we're going to have so that you can go into the session with a clear sense of what you've agreed to and how I'll show up physically. Does that make sense as a place to start?"
Element 1: Participant-Directed Preferences
"I want to understand your relationship with touch — not in general, but in the context of this kind of work. Some people find that a hand on the shoulder or arm is grounding during difficult moments. Others prefer no physical contact at all, and that works completely. Some people have histories or sensitivities that make certain kinds of touch activating in ways that wouldn't be helpful. I'm not going to guess — I want to hear from you. What feels true for you right now?"
Element 2: Grounding Touch Options
"The kinds of touch I use, when touch is part of the session, are: a hand on your shoulder, a hand on your forearm, or gentle pressure on your upper back. I don't use full-body contact. I don't hold you in ways that aren't specifically something you've asked for. For each of these — does it feel okay, does it feel welcome, or would you rather I don't use it? You can give me a 'yes,' 'no,' or 'only if I ask for it.' Any of those is fine."
Element 3: Capacity Limitations Post-Ingestion
"There's something important I want to name about what happens after you take the medicine. As the medicine works, you may be in states where communicating feels harder — where words don't come easily, where you might not be sure what you want or need in a moment. Because of that, everything we're agreeing to right now is what I'll follow during the session. If I'm unsure — if you seem like you want contact or you're reaching toward me — I'll check in verbally first, and if you can't clearly communicate a 'yes,' I'll default to not touching. You can also say 'stop,' 'no,' or 'not right now' at any point during the session and I will honor that immediately, no questions asked. Does that make sense and feel okay?"
Element 4: Co-Facilitator Option
"Some participants prefer to have a second person in the room — a co-facilitator or trained support person — either throughout the session or for specific parts of it. This isn't something you have to want, and it doesn't change the quality of what I offer. It's an option that's available if it would make you feel safer or more comfortable. Is that something you'd like to think about or discuss?"
Element 5: Recording Option
"There's also the option of having a video recording made of the session — for your own use only, not shared with anyone without your explicit written consent. Some participants find this useful for their integration work afterward; others prefer not to have the room recorded at all. What feels right for you?"
Element 6: Opt-Out & Default
"The last thing I want to make clear: nothing we've agreed to here is permanent. If you change your mind before the session — even the morning of — tell me, and we'll update this. The default in any situation of ambiguity is no touch. You don't have to agree to any touch at all to receive this service. My role is to be present and to support your experience, and I can do that well regardless of what you've decided here."
Watch For in Lecture & Demo
  • Students who treat the Touch Contract as a form: The temptation to reduce this to "did you get the signature?" is real, especially for students who are anxious about regulatory compliance. Redirect toward the quality of the conversation — the form is evidence that the conversation happened, not a substitute for it.
  • Rushed delivery in the model: If you find yourself speeding through the elements, slow down. The pace of the consent dialogue is itself information — it signals to the participant whether you actually want to know their answer, or whether you're moving through a checklist.
  • Students who are uncomfortable receiving detailed touch preferences: Some students find it activating to hear specifics of what a participant finds acceptable or not acceptable. This is worth naming: "Part of this work is being able to hear preferences around physical contact without making it about you. The participant's specificity is information that protects them. Your job is to receive it without discomfort."
Exercise  ·  55 min  ·  Consent Dialogue Roleplay
Consent Dialogue Roleplay — Full Practice with Feedback
Triads. One facilitator, one participant, one observer with the observation checklist. Rotate roles so each person conducts the consent dialogue at least once. Observer gives structured feedback immediately after each round using the elements framework. Instructor circulates and provides live coaching.
  1. Instructor models the full consent dialogue one more time — briefly, from memory, not from the guide. Students observe. 8 min
  2. Form triads. Round 1: facilitator conducts consent dialogue with participant using Prompt Card A (below). Observer takes notes. 12 min
  3. Observer gives structured feedback (2–3 min) — one specific strength, one specific adjustment. 3 min
  4. Round 2: rotate roles. Prompt Card B. 12 min + 3 min feedback
  5. Round 3: rotate roles. Prompt Card C. 12 min + 3 min feedback
  6. Group debrief. 2 min
T2 Only Consent Dialogue Practice Prompt Cards Distribute to participants in triads
Participant Prompt A
You are a 34-year-old participant preparing for your first natural medicine session. You have no significant trauma history related to physical touch, and you tend to feel calmer when you have physical contact during emotional experiences. However, you've never discussed this kind of thing formally before and you're slightly nervous about the conversation. You're open to touch but you want to make sure the facilitator actually hears your specific preferences, not just gets through a checklist.
Facilitator goal: Create genuine participant-directedness. This participant wants to be heard — notice whether you're listening or just moving through the elements.
Participant Prompt B
You have a history of physical and emotional abuse from a previous intimate partner. You've done significant therapy work on this and feel stable, but you're not comfortable with any physical contact from someone you don't know well — even grounding touch. You want to participate in the session without touch and you're slightly worried that the facilitator will push back or try to convince you that some touch would be helpful. You need to feel that "no touch at all" is a genuinely acceptable answer.
Facilitator goal: Receive and honor "no touch" without any attempt to reframe or persuade. This is the most important test of genuine opt-out culture.
Participant Prompt C
You're an experienced meditator and generally comfortable in your body. You're open to touch but you have a very specific preference: you find touch on your shoulders activating rather than grounding, and you prefer if touch happens only when you initiate it or ask for it. You also find it hard to say "no" in the moment — you tend to comply with things that feel slightly off rather than speaking up. You need a facilitator who acknowledges this explicitly rather than just assuming your silence will function as ongoing consent.
Facilitator goal: Address the "silence ≠ consent" dynamic explicitly. The Touch Contract must address what happens when the participant can't easily communicate refusal.
Debrief  ·  15 min
Debrief Questions
What was hardest about conducting the consent dialogue — the content, the pacing, or something else?
In Prompt B, the participant wanted no touch at all. How did that feel to navigate? Was there any moment you wanted to offer a "just a little bit" option?
In Prompt C, the participant disclosed that they have trouble saying no. How do you document that? How does it change what you agree to in the contract?
What's the difference between a Touch Contract conversation that made the participant feel safer and one that made the facilitator feel compliant?
Async Assignment — Due Before Lesson 3

Draft your Touch Contract template: Using the conversation guide from L2 as a foundation, draft the specific Touch Contract template you would use in your own practice setting. It must include all six required elements, written in your voice — not templated language. It should also include a brief facilitator notes field for capturing participant-specific disclosures (like Prompt C — "participant has difficulty refusing in the moment") that will inform your in-session attunement. This is a required portfolio artifact. Bring it to L3 for peer review in pairs.

Lesson 3 Boundary Breaches & Repairs  ·  2.0 hr sync + 0.5 hr async
Lesson 3: Boundary Breaches & Repairs
2.5 hrs total · 2.0 hr sync / 0.5 hr async  ·  CO C.4 · C.5 · C.6 · B.5
This is the lesson that most directly connects to legal and professional consequences. Students need to understand not only the severity spectrum but the repair pathway — what is repairable, under what conditions, and what the regulatory reporting obligations are. The scenario exercise in this lesson is the most demanding of the module. Do not rush the debrief.
Sync Time 2.0 hours — lecture (40 min) + breach severity exercise (45 min) + repair protocol exercise (15 min) + debrief (20 min)
Materials Severity spectrum reference cards · Breach-and-repair scenario cards (8 scenarios + key) · Peer review pairs for Touch Contract drafts from async
Lecture  ·  40 min
"The question this lesson answers is not 'what's the worst that can happen?' It's 'what do I actually do when something has gone wrong?' And it answers a harder version of that question: how do I know whether what just happened is something I repair — or something I report?"

Start with the severity spectrum. In facilitation practice, boundary events exist on a continuum from a minor crossing — a single, well-intentioned deviation that caused no harm — to a reportable violation that triggers mandatory disclosure to the regulatory body. Understanding where a given event lands on this spectrum is not just ethically important. It determines what the facilitator must do next.

Crossing Single, typically well-intentioned deviation. May not have caused perceptible harm. Often happens in the moment of responding to participant need. Response: Name it to yourself. Document it. Bring to supervision. Do not repeat the pattern.
Violation Exploitation of the power differential, or harm to the participant, regardless of intent. May or may not be reportable depending on specific nature. Response: Immediate supervisor consultation. Participant safety assessment. Documentation. Possible reporting obligation.
Reportable Violation Any sexual contact; financial exploitation; deceptive credential or scope representation; coercive or manipulative behavior. Response: Mandatory regulatory reporting. Do not attempt to repair through continued relationship with participant. Retain all documentation.

The harm to participants from boundary violations is not theoretical, and teaching it abstractly doesn't land. In the psychedelic facilitation context specifically, the harm profile of boundary violations is distinct from other helping professions for the following reason: the healing process itself requires participants to open psychological material that is typically defended. The facilitator's role is to create the container in which that opening is safe. When a facilitator violates a boundary in that context — particularly a physical violation or a relational exploitation — the participant's capacity to trust their own experience and their own judgment is often what is most damaged. They opened themselves under the assumption that the container was safe. The violation teaches them that their openness was used against them. Recovery from this kind of harm is more difficult than recovery from boundary violations in other contexts precisely because the violation occurred inside a healing frame. The violation corrupts the meaning of the experience.

Consequences for facilitators who breach boundaries are significant and range in severity. For crossings: supervision is required; documentation in the program record is required; repeated crossings in a pattern typically constitute grounds for additional training requirements or practice restrictions. For violations: supervisor consultation is mandatory; practice may be suspended during review; in cases of reportable violations, the regulatory body must be notified. The specific consequences in Colorado include: formal investigation, suspension or revocation of natural medicine service facilitator license, referral to law enforcement in cases involving sexual contact or criminal coercion, and civil liability. In addition to regulatory consequences, a boundary violation can expose the facilitator to civil suit by the participant. The co-presence of regulatory, civil, and in some cases criminal exposure is not designed to frighten facilitators away from the field — it is designed to create structural accountability for a profession where the power differential creates genuine potential for serious harm.

The Touch Contract-specific consequences deserve specific emphasis. Under CO C.6, breach of the Touch Contract constitutes a distinct category of violation — not merely a general relational boundary violation. This means that physical contact outside the Touch Contract, even contact that a participant might have been receptive to in the moment, is documented separately from other boundary events. The reason for this specificity is regulatory: the Touch Contract exists as a concrete agreement, and departure from a concrete agreement is categorically more serious than a deviation from an undefined standard. Know your own Touch Contract. Follow it even when it seems like the participant would welcome something it doesn't include.

Pause here. "What questions do you have before we go into the repair protocol? This is also a moment to notice if anything from the first part of this lecture feels personal — boundary violations you've witnessed or experienced as participants in other contexts. You don't need to share that, but bring your full awareness of what's real to the exercise."

The repair protocol applies only to crossings — not to violations. A violation is not repaired through a conversation with the participant. A violation requires supervisor consultation, potential regulatory reporting, and in most cases a cessation of the professional relationship, at least temporarily. Repair is not the right frame for a violation. Accountability is.

For a crossing, the repair protocol has three steps. First: name it. Either to yourself in a reflective documentation note, or in some cases directly to the participant — depending on whether naming it would serve the participant's wellbeing or would primarily serve the facilitator's need to manage their own discomfort. Second: bring it to supervision. Every crossing gets a supervision conversation, because the supervisor's perspective is the check on the facilitator's tendency to minimize. Third: adjust. Identify the specific structural or behavioral adjustment that prevents recurrence. A crossing that happens once can be a human error. A crossing that happens three times in the same domain is a pattern.

Watch For in This Lecture
  • Minimization of mid-spectrum events: "That's not really a violation, it's just a crossing." This is how drift is rationalized after the fact. The severity framework is for classification — the obligation to bring every crossing to supervision is not contingent on how serious the crossing was.
  • The "what about the participant's needs?" defense of violations: Some students will frame a clear violation as having been in service of the participant. The response: "The participant's short-term expressed preference is not the same as their wellbeing. A facilitator's job is to hold the structural container, not to respond to every expressed preference."
  • Students who seem personally implicated: If a student becomes unusually quiet or distressed during this lecture, check in briefly after class. This content activates both professional and personal material.
Exercise  ·  45 min  ·  Breach Severity Evaluation
Breach Severity Evaluation — 8 Scenario Cards
Small groups of 3–4. Each group receives all 8 scenario cards. They classify each using the severity spectrum (Crossing / Violation / Reportable Violation) and identify the first three required steps the facilitator should take. Groups then compare classifications in full group debrief. Focus debrief on cards where groups disagreed.
  1. Groups classify and determine response steps for all 8 cards. 25 min
  2. Groups report out card by card. Instructor tracks agreements and disagreements on whiteboard. 12 min
  3. Focus debrief on 2–3 contested cards. 8 min
T2 Only Breach & Repair Scenario Cards — 8 Scenarios + Key Do not distribute to students · Instructor-led exercise
Scenario 01
A facilitator is 10 minutes past the scheduled end of an integration session because the participant was in the middle of a significant disclosure and stopping felt wrong. The facilitator did not charge for the additional time.
Crossing. Response: Document the extended time, bring to next supervision. Consider discussing session time expectations with participant at next session to prevent future ambiguity.
Scenario 02
A participant in an active session becomes very still and appears to be in significant distress. Without checking in verbally, the facilitator places both hands on the participant's shoulders and leans in close to say "I'm here." Touch Contract allowed hand on arm only.
Violation (Touch Contract breach, CO C.6). Response: Document immediately. Supervisor consultation before next session. Review Touch Contract with participant. Verbal check-in protocol must be restored.
Scenario 03
Following a particularly meaningful session, the facilitator responds to a participant's Instagram message with a personal, emotionally warm reply that includes some self-disclosure about how much the work has meant to them.
Violation (digital/relational boundary). Response: Supervisor consultation. Discuss with participant that communications need to return to the agreed channel. Document the exchange and the correction.
Scenario 04
A facilitator's regular participant refers a close friend. The facilitator accepts the referral without disclosing the dual-relationship to either party and does not adjust their practice accordingly.
Violation (dual relationship, B.5). Response: Supervisor consultation immediately. Facilitator must decide whether to accept the referral with full disclosure or decline it. Document the decision and the reasoning.
Scenario 05
A participant asks, at the start of an integration session, whether the facilitator has ever experienced grief personally. The facilitator says "yes" without elaborating, and redirects to the participant's experience.
Not a breach. Brief confirmation of common human experience without detail is appropriate disclosure. The redirect preserves the participant-centered frame. No action required.
Scenario 06
A facilitator texts a participant to remind them about their upcoming session. The participant responds with an update about a personal situation that's been difficult. The facilitator responds with "I hear you — see you Tuesday."
Minor crossing (digital channel, unsolicited therapeutic content). Response: The facilitator handled the response appropriately. Consider establishing clearer communication expectations at next session. Document if the pattern repeats.
Scenario 07
During an active session, the participant appears to be reaching toward the facilitator in a way the facilitator interprets as wanting to be held. The facilitator holds the participant for approximately five minutes. The participant later says they don't remember this clearly. Touch Contract did not include holding.
Violation (CO C.6 Touch Contract breach + capacity concern). Response: Immediate supervisor consultation. Session should be reviewed. If participant cannot verify consent, this elevates toward reportable territory. Retain all session records.
Scenario 08
A facilitator, concerned about a participant's wellbeing between sessions, drives by the participant's home to "check in" without announcement. They do not make contact. The participant later discovers this when the facilitator mentions it.
Violation (surveillance / stalking behavior, relational boundary). Response: Supervisor consultation immediately. This behavior is not consistent with safe professional practice regardless of intent. Document. Assess whether the professional relationship can continue safely.
Debrief  ·  20 min
Debrief Questions
Scenario 07 raised questions about what happens when a participant can't clearly confirm or deny what happened. How does incapacity affect the violation classification?
Scenario 08 surprised some groups. What made it a violation rather than a crossing — given that the facilitator never made contact?
If you were the supervisor receiving a consultation call about Scenario 02 — what would you want to know first?
What distinguishes a crossing that belongs only in supervision from one that needs to be disclosed to the participant? What factors determine that?
Async Assignment — Due Before Lesson 4

Repair protocol for your practice: Write your personal breach response protocol — one page — for your specific anticipated practice setting. It must include: (1) your supervisor contact information and what you will say when you call, (2) your documentation standard for a crossing (what you will write and where), (3) your documentation standard for a violation, (4) your determination criteria for when something elevates from violation to reportable violation in your state. This is a required portfolio artifact. The difference between a facilitator who handles a crossing well and one who handles it badly is almost entirely determined by whether they had already thought about this before it happened.

Lesson 4 Digital Boundaries & Data Hygiene  ·  2.0 hr sync + 0.5 hr async
Lesson 4: Digital Boundaries & Data Hygiene
2.5 hrs total · 2.0 hr sync / 0.5 hr async  ·  CO C.7 · J.11 · J.13
The digital dimension of boundary practice is the most rapidly evolving and the most commonly underestimated. Students who hold clear physical and relational limits will often not have given equivalent thought to their digital footprint — what channels they use, how long they retain data, what they post on social media, and how their online presence interacts with their professional identity. This lesson builds that awareness and anchors it in specific, practicable policies.
Sync Time 2.0 hours — lecture (45 min) + digital policy audit exercise (45 min) + debrief (20 min) + module bridge (10 min)
Materials Digital boundary policy audit worksheets · Sample communication policies (in exercise)
Lecture  ·  45 min
"The session ends when the participant walks out. The professional relationship doesn't. What happens after the session — how you communicate, what you retain, what you post — is not separate from your boundary practice. It is your boundary practice, extended into the digital domain."

Start with communication channel policy. A facilitator who allows participants to reach them through any available channel — text, email, Instagram DM, WhatsApp, phone call, LinkedIn message — has not established a communication policy. They have established that communication is unlimited. The problem is not any individual channel. The problem is the implicit message that there is no limit. Participants in a facilitation relationship can develop significant dependency dynamics, and an unlimited communication environment accelerates rather than manages that dynamic.

A scope-compliant communication policy has three elements: the channel (which one or two specific channels are available for participant contact); the content (what kinds of messages the facilitator will respond to, and what kinds they will acknowledge but not address through that channel); and the timing (when the facilitator responds and what happens outside those windows). This policy should be established in writing during preparation, included in the service agreement, and reviewed during the Touch Contract conversation as part of the broader discussion of what the relationship includes and what it does not.

Common channel errors: using the same phone number for personal and professional contact; communicating through social media platforms where the participant can see the facilitator's personal content; responding at all hours in a way that implies always-available support; allowing voice or video contact without a prior agreement that it falls within scope. The facilitator who responds to a 2am text message — even once — has communicated something about availability that is difficult to retract.

Ask: "What channels do you currently use in your personal life that you would need to think carefully about before using with participants? Why?" Collect 3–4 responses. Don't evaluate — use them as examples in the next section.

Social media and dual-relationship risk deserves specific attention. A facilitator who has a public social media presence — in any capacity, including personal — needs a clear policy about whether and how participants can engage with that content. Following a participant on social media, accepting a follower request, liking a participant's content, or commenting on their posts all constitute out-of-session contact that may not be appropriate. The fact that social media is public does not mean there are no professional implications. The same power differential that governs in-person contact governs digital contact. A facilitator who "just liked their photo" has made a relational gesture with professional implications, regardless of intent.

Minimal-data documentation is the second major subject of this lesson. CO J.13 establishes that facilitators should collect only the participant information that is required for their professional function, retain it only as long as required by regulatory standards, and destroy it in a manner that protects participant privacy. This is not a passive compliance requirement — it is an active practice decision. Every field in a session note is a decision about what is necessary. Every retention period is a decision about when the data has served its purpose. Every method of record storage is a decision about who can access the participant's information and under what conditions.

The minimal-data standard applies to both digital and paper records. Session notes should contain: the date, duration, and type of session; observations relevant to participant wellbeing and scope-compliant actions taken; any contact outside the session and its nature; any departures from the standard practice protocol and the facilitator's response; and next steps agreed upon. Session notes should not contain: the facilitator's interpretations or hypotheses about the participant's psychology; clinical language or diagnostic impressions; personal information that is not relevant to the facilitation relationship; or detailed descriptions of the participant's emotional content that exceed what is needed for continuity of care.

"Take thirty seconds: what's one thing you'd normally write in a session note that you're now questioning? Hold that question into the exercise."

Data retention standards: Colorado's regulatory framework requires retention of session records for a period that aligns with standard healthcare documentation requirements. Know your specific state's requirements before you establish your practice. In general, records should be retained for a minimum of seven years from the last date of service. Destruction must be secure — for digital records, this means deletion from all backup systems and devices; for paper records, this means shredding. Records should be stored in a manner that limits access to the facilitator and, where applicable, their supervisor and designated practice administrator. Never store participant records in a system where other participants, household members, or unauthorized persons could access them.

Watch For in This Lecture
  • Students who haven't thought about this at all: This is common. Don't shame it. Meet them where they are and give them the specific, actionable policy language they need to start from zero.
  • Students with established practices that have significant gaps: Some students will already be in practice and will realize mid-lecture that their current digital setup is not compliant. Give them a clear pathway: "What you need to do is establish a written policy and a transition plan. That's the async assignment for this lesson."
  • The "it's all personal information, why does it matter?" question: The regulatory framework requires data minimization for two reasons — participant privacy protection and facilitator liability protection. Overly detailed records create more exposure, not less.
Exercise  ·  45 min  ·  Digital Policy Audit
Digital Policy Audit — Individual then Pairs
Students complete the audit worksheet individually, then compare with a partner to identify gaps and draft a specific one-paragraph communication policy. The goal is for each student to leave with a concrete, written communication policy they could actually use — not an abstract principle.
  1. Students complete the digital audit worksheet individually: (1) List every channel you currently use or would use for participant contact. (2) For each channel, note: does it mix personal and professional? Can participants see your personal content? Is your response time defined? (3) Identify your current documentation practice and compare to the minimal-data standard. Where are the gaps? 20 min
  2. Partners compare audits and draft a one-paragraph communication policy together — specific, written in first person, implementable tomorrow. 15 min
  3. Pairs share their policies with one other pair — give one piece of feedback. 10 min
Debrief  ·  20 min
Debrief Questions
What's the biggest gap you found in your own current digital practice? What specifically will you change?
How do you explain to a participant — in plain, non-bureaucratic language — why you have a communication channel policy?
What would you do if a participant followed you on social media? What if they sent you a DM on that platform about their session experience?
You discover that you've been keeping session notes that contain more psychological interpretation than the minimal-data standard allows. You have two years of records. What do you do?
Async Assignment — Due Before OSCE Window

Written communication and data policy: Finalize your communication policy from the exercise into a full written policy document — one page — that you could include in your service agreement and share with participants during preparation. It must include: designated contact channels; response time expectations; what content the facilitator will and will not address through each channel; social media policy (does the facilitator connect with participants on social media, and under what conditions); and data retention and destruction policy. This is a required portfolio artifact. A facilitator who doesn't have a written communication policy before their first participant contact is operating without a structural boundary in the domain where drift most commonly begins.

Full OSCE Summative performance assessment · Scheduled within M06 window · Assessor copy — not for student distribution
M06 OSCE — Touch Consent & Boundary Management Station
10-minute performance station  ·  4 domains × 25 pts  ·  Cut score: 70 overall / min 15 per domain  ·  One retake permitted

The candidate conducts a full Touch Contract conversation with a participant in preparation for their first medicine session. The participant has a specific history that creates complexity in the consent dialogue — a prior experience of unwanted physical contact in a therapeutic context that they disclose partway through the conversation. The candidate must conduct all six elements of the Touch Contract, respond appropriately to the mid-conversation disclosure, adjust the contract in response to participant-specific information, and verbally describe how they would document the conversation and what they would monitor in-session. The station is complete when the Touch Contract conversation concludes and the candidate has described their documentation and in-session monitoring approach.

Setting

Preparation session, first meeting. Candidate is the facilitator. Actor plays participant who is engaged and thoughtful but becomes quieter when touch is discussed. The participant's disclosure should feel natural, not performed.

Participant Baseline Presentation

Participant is eager, asks good questions, and is generally comfortable in the conversation. When the facilitator reaches the grounding touch section of the Touch Contract, the participant's energy shifts slightly — they become a bit quieter, look down briefly. This is the cue for the disclosure (below). The actor should wait for the facilitator to notice the shift OR for the facilitator to ask directly about the participant's comfort with the topic.

Participant Disclosure — Deliver when facilitator creates space or after 3 minutes in the touch section

"I want to be honest with you about something. I had a really uncomfortable experience with a therapist a few years ago — they would put their hand on my knee during sessions and it took me a really long time to tell them to stop. I'm not saying that will happen here. But I wanted you to know that I tend to not say anything in the moment, even when something doesn't feel right. I don't want to repeat that."

Assessor Notes on Participant Responses

If the candidate asks what types of touch feel okay: "I think a hand on the arm might be okay. I'm not sure about the shoulder. I don't think I want to figure it out in the moment."

If the candidate asks how to signal during the session that something doesn't feel right: "I honestly don't know. I freeze. I've always just frozen."

If the candidate asks whether the participant would prefer no touch at all: "I'm not sure. I don't want to decide out of fear. But I also don't want to just go along with something."

Domain Exemplary (23–25) Meets Standard (17–22) Below Standard (0–16) Score
1 · Touch Contract Completeness
All 6 elements covered · Participant-directed · Opt-out stated
Covers all six required elements in a fluid, participant-centered sequence. Each element is addressed as a genuine inquiry, not a checklist item. Opt-out and default (no touch = acceptable) stated clearly and without ambiguity. Co-facilitator and recording options offered without pressure. Covers 4–5 of the six elements. One or two elements are framed as information delivery rather than genuine inquiry. Opt-out stated but either not clearly or only when the participant raises it. Covers 3 or fewer elements. Consent dialogue functions more as informed consent form delivery than participant-directed conversation. Opt-out not clearly communicated. Co-facilitator and recording options absent.
2 · Disclosure Response
Receives disclosure · Does not minimize · Adjusts contract
Receives the participant's disclosure without minimizing, reassuring, or redirecting too quickly. Names specifically what the participant has shared ("you've described that you tend not to speak up in the moment, and that a prior therapeutic relationship involved unwanted contact"). Asks directly how they want to handle the possibility of freezing in-session. Adjusts the Touch Contract based on the disclosure — specifically the monitoring protocol and the default behavior. Receives disclosure with genuine care but misses one element: either minimizes briefly ("I'm sure that won't happen here"), adjusts the contract but doesn't address the in-session monitoring implication, or names what was said but doesn't ask how to incorporate it. Receives disclosure with visible discomfort, redirects quickly ("thank you for sharing that — let's continue"), reassures without acknowledging the structural implication, or fails to adjust the Touch Contract at all in response to the disclosure.
3 · Capacity & In-Session Monitoring
Post-ingestion capacity explained · Freeze response addressed · Monitoring plan stated
Explains post-ingestion capacity limitations clearly and without alarming the participant. Specifically addresses the freeze response — acknowledges that the participant has disclosed they may not be able to speak up, names that the default in any ambiguous moment will be no touch, and explains how the facilitator will check in verbally during the session. Proposes a non-verbal signal option if the participant finds that useful (e.g., a hand gesture for "stop"). Explains post-ingestion limitations. Acknowledges freeze response but offers only a verbal check-in protocol without specifically addressing what happens when the participant cannot respond. Non-verbal signal not offered. Explains post-ingestion limitations generically without connecting to this participant's specific disclosure. Does not address the freeze response explicitly. Monitoring plan is abstract or absent.
4 · Documentation Description
Spoken documentation · Factual · Captures disclosure · Scope-compliant
Delivers a spoken description of what they will document — minimum 3 elements: (1) the Touch Contract elements agreed to, specifically including what was included and excluded; (2) the participant's disclosure verbatim or very close to it; (3) the specific in-session monitoring protocol established as a result. No clinical interpretation. No diagnostic language. States that they would bring this disclosure to supervision before the session. Documentation description covers 2 of the 3 required elements. May include one phrase of clinical interpretation. Does not explicitly state they will bring disclosure to supervision before the session. Documentation description is vague ("I'd document what we agreed to"), omits the disclosure entirely, or includes significant clinical interpretation or diagnostic language.
Total Score (max 100)
Cut score: 70 overall · No domain below 15/25  ·  Retake: One retake permitted within the M06 assessment window using the alternate scenario (see below)  ·  Remediation required before retake
Alternate Scenario — Participant with Strong Touch Preferences

Setting: Preparation session, first meeting. Participant is a massage therapist who is very comfortable with physical contact and has a clear, specific set of preferences they've thought about in advance.

Participant baseline: Confident, clear communicator. Has thought carefully about what they want from touch in the session. Will state their preferences clearly and directly, including some preferences that are at the edges of what is in-scope (e.g., they ask whether hand-holding for extended periods is available).

Mid-conversation development: When the co-facilitator option is presented, the participant says: "Actually — yes, I think I'd feel safer with a second person there. Is that something you actually have available, or is it just an option on paper?" The candidate must respond honestly — including if the co-facilitator option is not practically available in their specific practice setting — without pressuring the participant toward a particular decision.

Edge case to handle: The participant asks whether they can request to hold the facilitator's hand during difficult moments. The correct response is to acknowledge the request without judgment, explain that the Touch Contract governs in-session contact and that extended holding beyond the agreed grounding touches is typically not within scope, and invite the participant to discuss what they're looking for so the contract can address it appropriately.

Correct OSCE response: The candidate conducts all six elements, handles the co-facilitator question honestly, addresses the holding request without dismissal or over-accommodation, and adjusts the contract to reflect the participant's specific preferences. Documentation description covers Touch Contract specifics, the co-facilitator agreement (or honest statement of availability), and the holding request and how it was resolved.

Domain 1: The most common failure is converting the consent dialogue into an information-delivery session. If the candidate is talking more than the participant for the majority of the station, they are not conducting a participant-directed Touch Contract — they are presenting one. The patient-directedness of the conversation is the criterion, not the content coverage.

Domain 2: The most consequential error is minimizing the disclosure — any version of "I'm sure that won't happen here" or "don't worry, we'll figure it out in the moment" should trigger a Domain 2 score below 15. The participant has disclosed a prior harm and a known vulnerability. The candidate's job is to receive that and respond structurally, not reassure.

Domain 3: A non-verbal signal option (hand signal, verbal code word) is the distinguishing feature of exemplary performance on Domain 3. It shows the candidate has actually thought through what "freeze" means in a session context and has built a structural accommodation for it — rather than defaulting to a verbal check-in protocol that the participant has already told them may not work.

Domain 4: Look for candidates who say they will bring the disclosure to supervision before the session. This is not optional in a case involving a prior therapeutic harm disclosure. Candidates who do not mention supervision in their documentation description should not receive full Domain 4 points.

For Candidates Below Cut Score
  • Written domain-specific feedback from assessor delivered within 48 hours of OSCE
  • 30-minute coaching session targeting the domain(s) below 15/25 — for Domain 2, this should include specific re-practice of receiving a disclosure without minimizing; for Domain 1, re-practice of participant-directed questioning
  • One retake using the alternate scenario within the M06 assessment window
  • Candidates who do not pass on retake may not begin M10 preparation content or supervised client contact hours until a remediation plan approved by program director is completed
  • All OSCE attempts must be documented with assessor rubrics retained in the student's program file
Bridge to Module 07

M06 completes the core boundary competency layer of Phase 2. Module 07 — Cultural Considerations & Inclusion extends the relational framework from individual boundary management to the structural and systemic dimensions of how facilitators show up across difference — cultural identity, Indigenous traditions, disability, access, and the specific ways that power dynamics in facilitation intersect with race, class, gender, and ability. The boundary clarity built in M06 is the foundation for M07: a facilitator who hasn't clarified their professional role and limits cannot begin to examine how their cultural position and assumptions shape how they exercise that role. Bring the structural thinking from M06 into the humility work of M07.


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