Extensions of Approval
Some companies have received "disapproval" letters when they have tried to file for extension of approval under CL6.
There appears to be some challenges when putting this type of submission together appropriately so that it can be approved under the certified process. It cannot be successfully done by merely making the request for an extension of approval in the submission letter for the new forms. However, the Department assures that extensions of approval CAN be accomplished via certification, but the Re of the letter and the certification would need to be correctly prepared and the request clear from the submission package.
The more complicated question though, is determining when a company needs to request an extension of approval to begin with. If a policy and an application form are both approved in the same package, are they approved solely for use with each other? Then if another application is developed for the same policy would an extension of approval for that policy be required or would a mere reference to the policy be sufficient in the submission letter? When I make that determination I look back at the original submission letter and the original approval letter to see what representations and conditions were put forth, but the longer we live in a certified approval world, the less clear it becomes when a real extension of approval is required.
