The DEA’s marijuana-rescheduling hearing, presided over by Chief Administrative Law Judge Derek C. Julius, has drawn testimony and public commentary from a wide range of interested parties over the past two years, including state officials, patient advocates, industry groups, and pharmaceutical developers. According to a wire release distributed by Newswire and syndicated across a number of local-news mirror sites, sworn testimony in that proceeding included remarks from Duane Boise, President and CEO of MMJ International Holdings, Inc.

The core argument attributed to that testimony is direct: an oft-cited figure of six million state-registered medical marijuana patients has been used in public discussion of the rescheduling debate as evidence of broad medical acceptance, when a registry count documents a legal registration, not a physician-supervised course of treatment or a clinical outcome.

The testimony’s central claim, in Boise’s words as quoted in the release, is that “a registry card is not a clinical trial. A recommendation is not an FDA-approved prescription.” The argument is that six million registrations do not, on their own, establish that six million patients received individualized physician oversight, ongoing follow-up, or outcomes tracked against a clinical standard.

In support of that point, the testimony cites physician-participation data suggesting that in several major state programs, approximately 96% to 98% of physicians write no marijuana certifications at all, and that in at least one state, three physicians reportedly account for more than a quarter of all recommendations issued.

MMJ International Holdings is a pharmaceutical developer that reports having spent more than eight years and over $10 million developing a standardized oral cannabinoid drug candidate, a soft-gel capsule combining 5 mg CBD and 2.5 mg THC, and holds two FDA Investigational New Drug filings along with Orphan Drug Designation for a Huntington’s disease program. The company is also a petitioner in federal litigation challenging the DEA’s April 2026 marijuana-rescheduling order and an appellant in separate litigation concerning a CMS cannabinoid program.

That matters because MMJ has a direct financial and legal stake in how this evidentiary debate resolves. A company pursuing the FDA drug-development pathway for cannabinoids has a competitive interest in the state-licensed marijuana registry pathway being viewed as clinically insufficient. None of that makes the underlying point about registries and clinical trials wrong, but it means this testimony should be read as advocacy from an interested party, not as neutral, disinterested analysis, and its specific statistics should be weighed accordingly.

This testimony does not establish that medical cannabis is ineffective, that the patients holding those six million registrations are not benefiting from cannabis use, or that state medical marijuana programs should be dismantled. It also does not, by itself, determine how the DEA rescheduling proceeding will ultimately resolve, since that hearing has drawn testimony and argument from many parties on multiple sides.

Just as important, the specific physician-participation and recommendation-concentration percentages cited in the release could not be independently verified against the primary hearing transcript or exhibit for this review. They are consistent with patterns previously reported in some state cannabis programs, but they are presented here as the testifying party’s characterization of the record, not as independently confirmed figures.

Setting the messenger aside, the substantive distinction this testimony is pointing at, between a state registration count and a body of physician-supervised clinical evidence, is one this practice has emphasized for two decades of caring for medical cannabis patients. A patient holding a state registry card has met that state’s administrative requirements, which vary widely in rigor from a single telehealth visit to an ongoing relationship with a certifying physician. That variability is real, and it is a legitimate reason not to treat six million registrations as equivalent to six million documented clinical outcomes.

Evidence-based cannabis care means holding both truths at once: patient access matters, and registry size is not a substitute for clinical evidence. Overstating what registry data proves does not serve patients, and it gives critics of medical cannabis an easy, and sometimes fair, target.

For clinicians managing medical cannabis patients, the practical takeaway is to keep access metrics, how many patients are registered, how easy certification is to obtain, clearly separate from efficacy metrics, what the peer-reviewed literature actually supports for a given condition. A large registry does not strengthen the evidence base for any specific indication, and a small or declining registry in a given state does not weaken it.

This distinction is also useful when patients cite state patient counts as reassurance about safety or effectiveness. It is an opportunity to walk through what the actual peer-reviewed evidence says for their specific condition, rather than relying on registration totals as a proxy for clinical validation either way.

This testimony arrives amid an extended, multi-party DEA marijuana-rescheduling proceeding that has drawn contested evidentiary arguments, procedural disputes, and testimony from state officials, advocacy groups, industry, and pharmaceutical developers over an extended period, following an April 2026 DEA rescheduling order that is itself the subject of ongoing federal litigation, including litigation brought by MMJ International Holdings.

Readers following this proceeding should expect more testimony from more interested parties before it resolves, each with its own institutional interest, and should apply the same disclosure-first, verify-the-numbers approach to future testimony and press coverage that this piece applies here.

The tension between registry-size arguments and clinical-evidence arguments has run through the cannabis-rescheduling debate for years, with advocates on multiple sides selectively emphasizing whichever data supports their position. This testimony is a new data point in that pattern rather than a departure from it.

CED Clinic has covered the DEA rescheduling hearing’s evolving evidentiary record before, including commentary on what the hearing transcript has meant for clinical practice and on where the underlying research agenda should go next; this testimony fits into that same ongoing story rather than standing apart from it.

I do not disagree with the core distinction this testimony is drawing. In twenty years of caring for medical cannabis patients, I have never treated a state registration as a substitute for a clinical assessment, and I would be uncomfortable if the field leaned on registry size as its main evidentiary argument. The physician-participation pattern described here, a small number of high-volume certifiers accounting for a large share of recommendations in some states, tracks with what I have observed anecdotally in how uneven certification practices can be across the country.

What I want readers to hold onto is the second half of the picture: this argument is being made by a company that stands to benefit if state programs are discredited relative to the FDA drug-development track it is pursuing. That does not make the argument false. It means I read the specific numbers with real caution, and I would want to see the primary hearing record before treating the physician-participation statistics as settled. Evidence-based cannabis care requires being just as skeptical of testimony that flatters my own instincts as I am of testimony that does not.

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