More on Variable Material ("SOV")
In a conversation with Kathleen Nelligan of the NYSID this morning, she once again reiterated the need for specificity in SOVs. While she concurred on the importance of guidance being published on the website, she also said that the Department needs to know now what is going to be on the form when it is issued. They can't wait to enforce the standards until those standards are published. From the conversation, it is clear that if your company is in a position to fully define alternative text (including new addresses and phone numbers) that might appear, those should be included on the SOV up front. If however you thing something may change but you don't know what the new provision might be, e.g. where the service office might move to if it ever moves, you need to make clear on the SOV that your company will re-file the Memo prior to implementing any new text.
In some cases, failure to provide sufficient detail may get through the process and the SOV may be approved. But take note that the NYSID is likely to consider it use of an unapproved policy form if there is any modification that they determine is outside the scope of the SOV's explanation.
