There are past discussions on this and I don’t think much has changed. Check out
and
In those two threads others have asked about the 90 day requirement but no one mentioned where it came from. I did a little digging and found the LCD for pumps repeats the requirement and comments to change the requirement were determined to be out of scope of the LCD. So maybe don’t base your request on an exception to L33794.
Hopefully someone will have better info for you. I hope you are successful.